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Lifting two empty shipping containers together

Summary A marine operator proposed lifting two empty containers together using twist locks. OSHA said the operation could comply if it met eight conditions, including inspection, verified lock capacity, crane load limits, vertical lifting, and keeping workers clear beneath the load.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1993-09-02-0
Date issued
September 2, 1993
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent current policy.
Status last verified October 9, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 2, 1993

Mr. Michael T. Bohlman
Director, Marine Services
Sea-Land Service, Inc.
[Recipient address omitted]
Dear Mr. Bohlman:

The following information is provided in response to your letter of August 3, 1993 to Mr. Joseph Nolan of this office regarding the lifting of two empty containers that are vertically coupled by twist locks. We have reviewed the proposed operation and determined that it would comply with OSHA Regulations as long as you comply with the following provisions:

  1. The containers must be inspected for visible defects prior to hoisting and damaged containers shall not be hoisted in tandem. Ref.-29 CFR 1918.85(d).

  2. You must ensure that both containers are empty. Ref.-29 CFR 1918.85(b)(1).

  3. The weight of the containers when empty shall be permanently marked on the containers. Ref.-29 CFR 1918.85(a)(1).

  4. The twist locks must all operate in the same manner (be uniform) and they must have a positive, verifiable locking system.

  5. The load shall not exceed the capacity of the crane. Ref.-29 CFR 1918.85(c).

  6. The top container must be hoisted by the top fittings and the lifting forces shall be applied vertically from at least (4) such fittings. Ref.-29 CFR 1917.71(f)(1)(i).

  7. You must have available for inspection documentation from the manufacturer which verifies the capacities of the twist locks and corner castings.

  8. You must direct employees to stay clear of the area beneath the suspended containers. Ref.-29 CFR 1917.71(d)(2).

Please do not hesitate to call us at (202) 219-8131 or write to us at the following address if you have any questions or require further assistance:

Joseph Nolan, Chief
Division of Maritime Compliance Assistance U.S. Department of Labor - OSHA
Room N3610
200 Constitution Avenue, N.W.
Washington, D.C. 20210

We appreciate your continued interest in safety and health matters.

Sincerely,
Roy F. Gurnham, Esq., P.E. Director
Office of Construction and Maritime
Compliance Assistance

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