Access and Guarding of Work Surfaces >> Access to Cargo Spaces and Confined Spaces

Confined space with small, inadequately guarded opening for access
Confined space with small, inadequately guarded opening for access.

Typical access into cargo spaces is provided by the ship's ladders. A ship's ladders may be continuous straight ladders reaching up to 90 feet and may be without climbing devices, platforms, or protective cages. Confined spaces often have only one small means of entry. Portable ladders may be used to gain access to these spaces. [29 CFR 1915.72]

Figure 2: Improper practice - Ships ladder blocked by hoses and equipment

Potential Hazards

  • Ship's ladders are often damaged or slippery.
  • Ship's ladders are often blocked by cargo or materials.
  • Cargo or materials are being moved while workers are using the ladder.
  • Portables ladders may shift or slip.
Figure 3: Improper practice - Worker on ladder that may shift or slip

Requirements and Example Solutions

Figure 4: Improper practice - Fixed ladder extending out of an enclosed space with less than 4-inch clearance behind the ladder rung
Figure 5: Ventilation duct passing through access opening

Potential Hazards

  • Limited egress from the space may be blocked.
  • There may be only one means of egress from the space.
Figure 6: Access to confined space blocked by ventilation hoses. (Improper practice if only access.)

Requirements and Example Solutions

  • More than one means of access must be provided to a confined space unless the structure of the vessel makes it impractical. [29 CFR 1915.76(b)(1)]
  • When the ventilation ducts must pass through the means of access, ducts must allow for free passage. [29 CFR 1915.76(b)(2)] See Figure 2.
    • Note: When there is only one means of access, collapsible ducts may be used to provide access.
  • If ventilation equipment blocks access to the space, airline respirators as well as a stand-by employee must be used. [29 CFR 1915.51(c)(3)]
  • Employees working alone in a confined space must be checked on at regular intervals [29 CFR 1915.84(a)]