Regional Emphasis Program for Longshoring

U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration

DIRECTIVE NUMBER: SFO-CPL-05-00-002
SUBJECT: Regional Emphasis Program for Longshoring
REGION: San Francisco
SIGNATURE DATE: September 22, 2025 EFFECTIVE DATE: October 1, 2025

ABSTRACT

Purpose: This renews and updates a Regional Emphasis Program (REP) for
programmed inspections of longshoring. This instruction covers all
relevant establishments under the jurisdiction of federal OSHA's San
Francisco Region.

Scope: This instruction applies to areas of federal enforcement in the San
Francisco Region.

References: See Paragraph III

Cancellations: This instruction cancels Region IX Enforcement Programs Notice CPL 04-
09-2408, dated October 1, 2018, and Region X Notice 21-10 (CPL 04),
dated December 31, 2018.

State Impact: No Impact

Action Offices: All San Francisco Regional and Area Offices

Originating Office: San Francisco Region Enforcement Programs

Contact: Paul Leary, Assistant Regional Administrator Enforcement Programs

By and Under the Authority of

James D. Wulff
Regional Administrator

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Executive Summary

The purpose and intent of this instruction is to provide an inspection scheduling system to
cover high-hazard activities within the context of current laws and OSHA policy. Safety and
health programmed inspections in longshoring are to be scheduled using these instructions.
Longshoring is a highly specialized and hazardous activity, covered by standards in 29 CFR 1917
and 1918. The San Francisco Region has jurisdiction over longshore employment for
stevedoring companies in California (jurisdiction in California is shared with Cal/OSHA), Hawaii,
American Samoa, Guam, CNMI, Washington, Oregon, Idaho, and Alaska.
For 2023, the fatality injury rate (fatal occupational injuries per 100,000 full-time workers) was
13.6 for transportation and material moving, which includes longshoring; the fatal injury rate
for all private industry was 3.5.
This instruction renews the scheduling system currently in use in the San Francisco Region.

Significant Changes

This directive combines existing Regional Emphasis Programs in the former Region 9 and the
former Region 10 for use in the San Francisco Region.

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Table of Contents

I. Purpose. ................................................................................................................................................ 2
II. Scope. .................................................................................................................................................... 2
III. References. .......................................................................................................................................... 2
IV. Cancellations. ...................................................................................................................................... 2
V. Action Offices. ....................................................................................................................................... 2
VI. Expiration. ........................................................................................................................................... 2
VII. Background. ........................................................................................................................................ 2
VIII. Jurisdiction .......................................................................................................................................... 3
IX. Procedures .......................................................................................................................................... 3
X. Program Evaluation.........................................................................................................................................4
XI. Coding...............................................................................................................................................................4
XII. Outreach...........................................................................................................................................................4
Appendix A .................................................................................................................................................... 7
Appendix B .................................................................................................................................................... 9

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I. Purpose
This instruction renews and updates the policies and procedures to be followed when
scheduling and conducting programmed safety and health inspections in longshoring.
The intent of this instruction is to reduce employee exposure to hazardous conditions
and to prevent injuries, illnesses and fatalities in this high-hazard industry.
II. Scope
This instruction applies to all federal OSHA Enforcement Offices located in the San
Francisco Region for inspections of longshoring sites.
III. References
A. OSHA Instruction CPL 02-00-164, April 14, 2020, Field Operations Manual.
B. OSHA Instruction CPL 02-00-025, Scheduling System for Programmed
Inspections, January 4, 1995.
C. OSHA Instruction CPL 02-00-051, Enforcement Exemptions and Limitations under
the Appropriations Act (Appendix A updated annually)
D. OSHA Instruction CPL 04-00-002, Procedures for Approval of Local Emphasis
Programs, effective November 13, 2018.
E. Memorandum dated December 3, 2014, on Procedures for Local and Regional
Emphasis Programs.
F. Memorandum dated November 12, 2014, on Establishment-Targeting Lists for
Emphasis Programs.
IV. Cancellations
A. Region IX Enforcement Programs Notice CPL 04-09-2408, dated October 1, 2018
B. Region X Notice 21-10 (CPL 04), dated December 31, 2018.
V. Action Offices
A. Responsible Office:
San Francisco Regional Office
B. Action Office: All San Francisco Region Area Offices
VI. Expiration
This REP will expire no later than five years from the date of implementation unless
renewed.
VII. Background
It is OSHA policy that programmed inspections be conducted primarily in high hazard
sectors of employment. For purposes of scheduling programmed inspections,
transportation and material moving, which includes longshoring, is considered a high-
hazard industry. Longshoring is a highly specialized and hazardous activity, covered by
standards in 29 CFR 1917 and 1918. For 2023, the fatality injury rate (fatal occupational
injuries per 100,000 full-time workers) was 13.6 for transportation and material moving,
which includes longshoring; the fatal injury rate for all private industry was 3.5.

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VIII. Jurisdiction
A. In most cases, the U.S. Coast Guard has jurisdiction over ships’ crew members. If
a Compliance Safety and Health Officer (CSHO) encounters any situation
involving the safety or health of ships’ crew members, a referral may be made to
the Coast Guard. CSHOs should consult with Regional Enforcement Programs and
the Regional Solicitor to determine if OSHA has any jurisdiction.
B. Federal OSHA does not have jurisdiction over employees of political subdivisions,
including Port Authorities.
C. Alaska: Federal OSHA has jurisdiction over longshoring and marine terminal
operations on and off the water, however there are specific exceptions. Federal
OSHA does NOT have jurisdiction over the loading or unloading of coal or other
minerals into or out of barges or vessels at mine-owned or mine-operated piers
and docks where jurisdiction is under the Mine Safety and Health Administration
(MSHA). One exception is at the Red Dog Mine where Federal OSHA has
jurisdiction over longshoring and marine terminal operations, even though it
involves mineral transfer operations typically under MSHA.
D. California: Federal OSHA has jurisdiction over shipboard activity; Federal OSHA
does NOT have jurisdiction over all marine terminals. Marine Terminals are
covered by Cal/OSHA, except for the Naval Base at Port Hueneme and the Coast
Guard Base Terminal Island (Los Angeles/Long Beach), where Federal Employees
conduct longshoring work.
E. Hawaii: Federal OSHA has jurisdiction over all marine terminal and shipboard
longshoring operations.
F. Idaho: Federal OSHA has jurisdiction over all longshoring and marine terminal
operations on and off the water, except loading/unloading coal or other minerals
into/out of barges or vessels at mine piers and docks.
G. Pacific Territories: Federal OSHA has jurisdiction over marine terminal and
shipboard longshoring activities in Guam, the Commonwealth of the Northern
Mariana Islands, and American Samoa. However, in Guam, Federal OSHA does
not have jurisdiction over local port authority personnel employed by the
Government of Guam.
H. Washington: Federal OSHA has jurisdiction over employers with operations
aboard vessels afloat and access to the vessels, including container ships, cargo
barges, and boom boats except the loading or unloading coal or other minerals
from barges or vessels at mine piers and docks.
IX. Procedures
A. The Area Offices will schedule longshoring inspections by random selection of
zones, using the procedures outlined in the Appendix. Based on the random list
of zones, inspections of employers within each zone will be scheduled as follows:
The order of inspections of employers within a zone is at the discretion of the
compliance officer. Appendix B contains a list of zones. All Area Offices are

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encouraged to coordinate with EP to update this list if they identify new sites or
employers; sites that have moved; or sites that are no longer operational.
B. Where federal OSHA has jurisdiction over marine terminals, every active
terminal within a zone will be inspected.
C. Employers may be subject to multiple inspections in a single zone within a
quarter if they are working at multiple ships or terminals when that zone is
randomly selected for inspection. Each ship will be counted as a separate
worksite and a separate inspection; where federal OSHA has jurisdiction over
marine terminals, each terminal will be counted as a separate worksite and
separate inspection.
D. Employers will be scheduled for programmed inspections within the same zone
no more than twice a year (once every other quarter).
E. If a compliance officer observes imminent danger or serious hazards at an
employer’s site which is not scheduled for inspection, the CSHO may make a self-
referral and conduct an inspection. This is not a programmed inspection, and as
such is not covered by the requirement related to inspections in consecutive
quarters in paragraph D above.
F. Active loading or unloading of a vessel or barge will have priority over Marine
Terminal inspections where no longshoring activity is active.
G. Complaints, reports of imminent danger, and unresolved complaints or referral
inquiries will be scheduled for on-site inspection as appropriate, in accordance
with the current FOM. All other complaints and referrals will be handled by
inquiry in accordance with policy.
H. Whenever possible, CSHOs will verify abatement immediately, during the on-site
inspection. On-site abatement is particularly important in longshoring
inspections, where conditions can change quickly. CSHOs must make every
attempt possible to compel immediate abatement, before inspections are
completed. It is critical that compliance officers verify abatement before
inspected ships leave port. A ship leaving port is not satisfactory abatement.
I. Employer and employee involvement is expected on inspections. If an employee
representative cannot accompany OSHA personnel during an inspection,
compliance officers should thoroughly document in the case file the steps taken
to request and encourage such involvement, and the reasons for continuing the
inspection without the participation of the employee representative. If
necessary, the compliance officer may delay the opening of the inspection for a
reasonable period, until an employee representative becomes available.
J. Programmed inspections will not be scheduled during a work stoppage, including
strikes or lockouts. In areas where Cal/OSHA has jurisdiction in marine terminals
(all zones in California outside of the federal jurisdiction area of Port Hueneme),
the Area Director may need to contact Cal/OSHA to coordinate enforcement
activity.

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X. Program Evaluation
A. At the midpoint of the effective period of this REP (two and a half years from the
implementation date) and at the end of the effective period, evaluation reports will
be completed that shall include the following elements:
a. Outline of the Program Goals.
b. A determination of the program’s effectiveness meeting its goal.
c. Data to support the achievement of the goal, including enforcement statistics
as required in CPL 04-00-002, Procedures for the Approval of Local Emphasis
Programs.
d. Statement whether the program should be continued, accompanied by a
brief rationale.
e. Description of any legal issues requiring review by the Solicitor before
continuing the program.
f. Any other comments or recommendations, including findings which might
have an impact on how OSHA or the industry operates.

B. This evaluation shall be submitted to the Regional Administrator for review, at which
time a decision will be made to continue, amend, renew or discontinue the REP.

XI. Coding

A. All inspections scheduled under this REP shall be marked with the primary emphasis
code LONGSHORESFO.

B. Unprogrammed inspections or inspections covered under other scheduling systems
which also cover the industries targeted by this REP shall have LONGSHORESFO
entered as a non-primary emphasis code.

C. Any other applicable REP, LEP or NEP code may be entered as a non-primary
emphasis code.

D. All other coding should be in accordance with relevant instructions and directives.

XII. Outreach
The Assistant Regional Administrator for Cooperative and State Programs and the
Assistant Regional Administrator for Enforcement Programs will ensure that Area
Directors, and all Outreach staff are familiar with this directive and actively promote the
REP when conducting outreach. Hazards, work practices, and machinery associated with
this industry and covered by this REP will be pointed out and discussed during outreach
sessions and meetings. Handouts and publications that address these hazards which are
already developed and available, will be provided at outreach sessions and meetings. A

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copy of this REP will be provided to interested parties upon request.

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Appendix A
Procedures for Scheduling Inspections

I. Procedures for Scheduling Inspections:

A. The Area Office will maintain a master list of zones eligible for inspection under
this REP. Due to the vast geographical locations involved, zones may be
subdivided into geographical areas for scheduling purposes.
B. At the beginning of each fiscal year the Area Office shall create a randomly
numbered list of all zones on the master list. Sites shall be randomly ordered
using the RANDBETWEEN function in Excel or an equivalent randomization tool.
Area Offices may also send their master list to EP for randomization. All steps in
the randomization process must be documented, and this documentation should
be maintained and filed with the master list, cycles, reasons for deferrals, and
related information.

C. Additions may be made to the master list, based on local knowledge or other
factors, including OSHA inspection history and annual OIS searches for zones
which have been inspected for unprogrammed activity but were not previously
on the list. These sites should be added to the master list for the following year.
D. The master list, including all additions and deletions, the randomized list, and the
scheduling cycles created for this REP, shall be filed electronically on the regional
shared drive or the regional SharePoint site and retained for three years. Area
Offices will coordinate with Enforcement Programs (EP) to ensure all
documentation is filed at least annually.
E. The Area Office will create scheduling cycles by selecting several zones from the
randomized master list. All scheduling cycles shall be filed electronically on the
regional shared drive.
a. Zones selected in a cycle can be inspected in any order, but all
zones in a cycle must be completed before another cycle is
created. Area Offices should consider programming goals and
available resources when setting the size of a cycle.
b. New cycles will be selected as required by the Area Office, upon
completion of the previous cycle, but at least once per fiscal year.
An uncompleted cycle may be carried over into the next fiscal
year, but the Area Office should adjust the number selected for
subsequent cycles based upon available resources.

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c. Selected zones may be deferred to the next cycle if the Zone has
been subject to a comprehensive programmed inspection (under
this or any REP) within the previous 12 months, or if the process
to be inspected is not active. All deferrals must be documented.
Additional criteria for deferral include:
• Appropriate equipment or trained personnel are not available to
conduct the inspection.
• An establishment is the last remaining establishment in a cycle,
the inspection would require travel more than 50 miles, and it
cannot be combined with other inspection activities.
• The establishment was cited as the result of a previous
comprehensive inspection, and the final abatement date has not
yet passed.
• The establishment has a matter pending before the Review
Commission.

F. If all zones on the master list are to be inspected during the fiscal year, the zones
may be inspected in any order. If an Area Office cannot complete all inspections
on the master list within a fiscal year, the Area Office will complete the list as
soon as possible in the first quarter of the next fiscal year and shall develop and
follow scheduling cycles for the remainder of that year and in subsequent years.

II. Deletions From Master List:
A. Establishments shall be deleted from the master list if, during an inspection, it is
determined that the site no longer falls within the parameters of the REP.
B. All additions and deletions must be documented.

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Appendix B
List of Zones

California

Zone 1 Zone 5 Zone 9
Benicia
Crockett
Stockton

Richmond Long Beach
Zone 2 Zone 6 Zone 10
Eureka Sacramento Los Angeles

Zone 3 Zone 7 Zone 11
Oakland
Alameda

San Francisco San Diego
Zone 4 Zone 8 Zone 12
Redwood City Terminal Island Port Hueneme

Hawaii

Zone 1 Zone 4 Zone 7
Hawaii (Big Island)
Hilo Harbor,
Kawaihae Harbor
CNMI Saipan

Oahu: Honolulu
Barbers Point
Kewalo Basin
Marine Corps
JBPHH Port
Zone 2 Zone 5
Kauai: Nawiliwili
Harbor
Lanai: Kaumalapau
Harbor
CNMI Tinian
Zone 3 Zone 6
Maui: Kahului Harbor
Molokai: Kaunakakai
Harbor
CNMI Rota

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Alaska

Zone 1 Zone 4 Zone 7
Craig
Gustavus
Haines
Juneau
Ketchikan
Meklakatla
Petersberg
Sitka
Skagway
Thorne Bay
Wrangell

Kodiak Barrow
Zone 2 Zone 5 Zone 8
Anchorage
Homer
Nikisi
Seward
Whittier

Adak
Akutan
Dutch Harbor
Sand Point
Nenana
Zone 3 Zone 6
Cordova
Valdez
Ya kutat
Bethel
Dillingham
Emmonak
Kotzebue
Naknek
Nome
Red Dog Mine
Unalakleet

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Washington

Zone 1 Zone 4
Anacortes
Bellingham
Everett
Friday Harbor
Port Townsend
Olympia
Zone 2 Zone 5
Seattle
Tacoma
Pasco
Walla Walla

Zone 3 Zone 6
Bremerton
Brownsville
Kingston
Port Angeles
Aberdeen-
Hoquiam
Grays Harbor
Ilwaco
Neah Bay
Peninsula
Raymond

Oregon

Zone 1 Zone 3
Columbia City
Kalama
Longview
Portland
Rainier
St. Helens
Vancouver
Arlington
Biggs
Boardman
Irrigon
Klickitat
Lewiston (Idaho)
The Dalles
Umatilla

Zone 2 Zone 4
Bay City
Brookings
Charleston
Coos Bay
Gold Beach
North Bend
Port Orford
Winchester Bay
Astoria
Garibaldi
Newport
Warrenton

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Appendix B