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In section 392.9, the motor carrier safety regulations require drivers to periodically check their cargo and securement devices to ensure that the cargo is properly secured, and make adjustments as necessary. Under that standard, these load checks must occur:

• Before driving;
• Within the first 50 miles after beginning a trip; and
• At every change in duty status, every 3 hours, or once the vehicle has been driven for 150 miles, whichever occurs first.

Before December 26, 2002, drivers were required to make their initial en-route load check within the first 25 miles. That changed to 50 miles effective January 1, 2004.

En-route load checks are not required of:

• Drivers of sealed commercial motor vehicles who have been ordered not to open the vehicles to inspect the cargo, or
• Drivers of vehicles that have been loaded in a manner that makes inspection of the cargo impracticable.

OSHA requires under 1910.22(d)(1) that inspections of ALL walking-working surfaces be done “regularly” and “as necessary” to ensure that they are in safe condition for employee use.

OSHA says that the term “regular inspection” means that an employer has some type of schedule, formal or informal, for inspecting walking-working surfaces that is adequate enough to identify hazards. As such, OSHA is allowing employers to determine when and how often these inspections are conducted. Once an employer makes this determination, inspections must be conducted according to that frequency.

In addition to regular inspections, employers must also conduct inspections “as necessary.” This means that they must be done when particular workplace conditions, circumstances, or events occur that warrant an additional check of walking-working surfaces in the workplace to ensure that they are safe for employees use. In other words, these inspections would not be conducted at fixed times as would regular inspections because situations could arise at any time that put workers at risk of slips, trips, and falls. For example, a parking lot would need to be inspected if it snowed to ensure that it was not unsafe due to ice or similar hazards.

The key is to ensure that walking-working surfaces are inspected often enough to identify and correct hazards in a timely manner.