United States Department of Agriculture

Agricultural Marketing Service

Federal Grain Inspection Service

Directive 9170.14 August 4, 2014

Distribution: FGIS, OSP, Industry Originating Office: FMD PPMAB

The U.S. Department of Agriculture (USDA) prohibits discrimination in its programs on the basis of race, color, 

national origin, sex, religion, age, disability, political beliefs, and marital or familial status. (Not all prohibited 

bases apply to all programs.) Persons with disabilities who require alternate means for communication of program 

information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice and 

TDD).

To file a complaint, write to the USDA, Office of Civil Rights, Room 326-W, 1400 Independence Avenue, SW, 

Washington, DC 20250-9410, or call (202) 720-5964 (voice and TDD). USDA is an equal employment opportunity 

employer.

FGIS ROLLING STOCK FALL PROTECTION

Contents

FGIS ROLLING STOCK FALL PROTECTION �������������������������������������������������������������������������1

1. PURPOSE����������������������������������������������������������������������������������������������������������������������������

2. DEFINITIONS�����������������������������������������������������������������������������������������������������������������������

3. BACKGROUND��������������������������������������������������������������������������������������������������������������������

4. POLICY ��������������������������������������������������������������������������������������������������������������������������������

5. RESPONSIBILITIES�������������������������������������������������������������������������������������������������������������

6. DOCUMENTATION ��������������������������������������������������������������������������������������������������������������

7. EXAMPLES��������������������������������������������������������������������������������������������������������������������������

8. QUESTIONS ������������������������������������������������������������������������������������������������������������������������

APPENDIX A����������������������������������������������������������������������������������������������������������������������������6
FGIS Directive 9170.14 August 4, 2014

Page 2

1. PURPOSE

This directive is issued by the Federal Grain Inspection Service (FGIS) to provide 

procedures for identifying rolling stock fall hazards and conducting a fall protection 

feasibility assessment. The requirements of this directive apply to FGIS employees onl

Official Agencies may adopt this policy, or use it as a guideline to establish their own 

policy to comply with local and national safety requirements.

2. DEFINITIONS

For the purposes of this directive, FGIS defines the following terms:

Fall Protection – a mechanical system designed to prevent falls. This may include a

mobile harness and pulley system, or a suspended walkway.

OSHA – Occupational Safety and Health Administration. An agency within the 

Department of Labor that sets safety standards for Federal and many private sector 

employees

Miles Memo – A 1996 memorandum from John B. Miles, Jr., former OSHA Directorate of

Compliance Programs, regarding enforcement of fall protection on moving (rolling) 

stock

PPE – Personal Protective Equipment. Equipment worn to minimize exposure to 

a variety of hazards. Examples of PPE include such items as gloves, foot and eye 

protection, protective hearing devices (earplugs, muffs) hard hats, respirators and full 

body suits

Railcar – for the purposes of this directive, a railcar will refer to a hopper-bottom 

type railroad car generally used for the purposes of carrying bulk grain or similar 

commodities. This directive will assume these types of cars have a suitable metal 

walkway on the top of the car to access the compartments from above.

Rolling Stock – a general term used to describe a railroad car (such as a hopper-bottom 

railcar typically used to carry grain) or a truck trailer used to carry grain (flat bottom or 

hopper bottom)

Truck – for the purposes of this directive, a truck will be defined as a flat- or hopperbottom truck typically used for the transportation of bulk grain or similar commodities

3. BACKGROUND

In 2013, FGIS and AMS’s Safety and Health Manager met with OSHA officials to 

discuss the 1996 “Miles Memo” and how it applies to the use of fall protection today. 

These discussions led FGIS to the interpretation outlined in this policy. For the safety o

our employees and to comply with OSHA standards, FGIS must take the following steps

to identify fall hazards and formulate a plan to best mitigate those hazards
FGIS Directive 9170.14 August 4, 2014

Page 3

4. POLICY

FGIS is committed to providing a safe working environment for our employees.

Working on top of railcars and trucks presents several inherent hazardous conditions 

that employees must be made aware of and protected from. FGIS will utilize a hierarchy 

of controls, such as employee training and personal protective equipment, to mitigate 

these hazards. FGIS must also conduct an assessment to determine the potential

hazards of each worksite and to determine the availability of fall protection.

The results of a fall protection assessment at each location will determine if fall 

protection is required. If fall protection is available, FGIS employees must use fall 

protection while working on top of rolling stock. If fall protection is not available, FGIS 

employees may provide service on top of rolling stock without fall protection.

5. RESPONSIBILITIES

a. FGIS Responsibilitie

(1) All employees who work on or around rolling stock must complete Fall Hazard 

Awareness Training. The material for this training will be provided by the AMS 

Training Office, and the field office will be responsible for documenting the 

training and maintaining the records for each employee

(2) FGIS will direct employees what PPE will be required for a specific task when 

working on or around rolling stock. FGIS will provide this equipment in most 

cases; however, if FGIS does not provide the equipment FGIS will instruct the 

employee what PPE will be required (for example, safety shoes). FGIS will 

provide a harness for employee use while working under fall protection.

Field Offices are required to train each employee who must use PPE.

Employees must be trained to know at least the following:

• When PPE is necessary;

• What PPE is necessary;

• How to properly put on, take off, adjust and wear the PPE;

• The limitations of the PPE;

• Proper care, maintenance, useful life and disposal of PPE.

(3) Designate personnel within a Field Office to conduct Fall Protection 

Assessments and complete Fall Protection Assessment training

(4) Conduct a Fall Protection Assessment at any worksite where FGIS personnel

are requested to perform service on top of rolling stock. This assessment

includes an evaluation of any available fall protection equipment that FGIS 

personnel will be using.

(5) When using fall protection at an applicant’s facility, complete any training 

offered or required by the facility where work is performed (e.g., training on 

how to use a fall protection system installed at that facility).
FGIS Directive 9170.14 August 4, 2014

Page 4

b. Applicant Responsibilitie

(1) Provide safe means for FGIS to access railcars and trucks

(2) Provide, when necessary, additional personnel to witness FGIS personnel 

while working on top of railcars and trucks so they may render aid in case of 

an emergency

(3) Train FGIS employees on the use of any available fall protection equipment at

the facility

(4) When using a fall protection system, provide any lanyards, self-retracting 

lanyards (SRL), or any other equipment necessary to connect to the fall 

protection equipment. The connection must be accessible at ground level, 

or another platform where fall protection is not needed (i.e., FGIS personnel 

should be able to fully connect to the system before stepping on the rolling 

stock). FGIS will provide employees a harness to use while working under fall 

protection

(5) Work with FGIS to mitigate any potential hazards found in a Fall Protection

Assessment

(6) Inform FGIS personnel of the facility rescue plan. If a fall protection system is

used and foot suspension relief straps are part of the rescue plan, provide 

straps for FGIS personnel use in the event of an emergency

6. DOCUMENTATION

Perform a Fall Protection Assessment at least once per year at each active facility 

where FGIS employees perform work on top of rolling stock. Conduct another 

assessment any time when the facility or conditions change (including weather 

conditions). For facilities with varying weather conditions or multiple scenarios for 

requesting service on top of rolling stock, this may mean conducting an assessment 

each time a service is requested

For example, an assessment conducted on a snowy or windy day might be done 

differently than one conducted on a sunny day with no wind, even at the same facility.

NOTE: If inclement weather (e.g., icy conditions or heavy rain and wind) or other 

hazardous conditions make working on top of the railcars unsafe, decline the 

request for service.
FGIS Directive 9170.14 August 4, 2014

Page 5

7. EXAMPLES

See the attached “Appendix A” for examples of a Fall Protection Assessment.

8. QUESTIONS

Direct any questions regarding this directive to AMS Safety and Health

Manager, at (202) 720-0061, or FGIS Field Management Division, at (202) 720-0228.
FGIS Directive 9170.14 August 4, 2014

Page 6

APPENDIX A

LOCATION: ____________________________________

NAME/TITLE: ____________________________________

SIGNATURE: ____________________________________

DATE: ____________________________________

Rolling Stock Fall Protection Assessment:

1. Is a suitable fall arrest system installed in location where AMS employees are 

sampling or performing stowage exams?

 

a. Is the system free of hazards? (e.g., overhead clearance)-

______________________________________________________________

b. Are there any other hazardous conditions which make working on top of the 

railcars unsafe?

______________________________________________________________

2. Is the area where sampling/stowage exam is to take place contiguous to a building 

or permanent structure?

__________________________________________________________________

If yes, why isn’t fall protection provided?

__________________________________________________________________

3. How far is the nearest building or permanent structure from the area AMS 

employees are to sample/perform stowage exam?

__________________________________________________________________

4. What type of surface is contiguous to the area where sampling/stowage exam is to

 take place?

__________________________________________________________________

5. Is this a multiple track yard?

__________________________________________________________________

If yes, how many tracks are used for sampling?

__________________________________________________________________

6. Can railcars be positioned next to a building, structure, or other area where fall 

arrest system may be used?

__________________________________________________________________
FGIS Directive 9170.14 August 4, 2014

Page 7

7. Can a freestanding mobile system be used?

__________________________________________________________________

8. Does the facility have a rescue plan in place to assist someone in an emergency? 

This may also include providing suspension/relief foot straps for fall protection 

harnesses

__________________________________________________________________

FINAL ASSESSMENT – IS FALL PROTECTION FEASIBLE?

______________________________________________________________________
FGIS Directive 9170.14 August 4, 2014

Page 8

Example #1

Situation: Railcar on Track 2 needs to be probed. Fall protection is positioned near the 

elevator approximately 1⁄2 mile away.

Result: Is fall protection feasible?
FGIS Directive 9170.14 August 4, 2014

Page 9

EXAMPLE #1 - Rolling Stock Fall Protection Assessment:

1. Is a suitable fall arrest system installed in location where AMS employees are 

sampling or performing stowage exams? No. Car is being sampled approximately 

1⁄2 mile away from existing fall protection.

a. Is the system free of hazards? (e.g., overhead clearance) N/A

b. Are there any other hazardous conditions which make working on top of the 

railcars unsafe? No.

2. Is the area where sampling/stowage exam is to take place contiguous to a building 

or permanent structure? No.

a. If yes, why isn’t fall protection provided? N/A

3. How far is the nearest building or permanent structure from the area AMS

employees are to sample/perform stowage exam? Approximately 1⁄2 mile.

4. What type of surface is contiguous to the area where sampling/stowage exam is to 

take place? Gravel

5. Is this a multiple track yard? Yes

a. If yes, how many tracks are used for sampling? As many as 4

6. Can railcars be positioned next to a building, structure, or other area where fall 

arrest system may be used? No, the railcar cannot be moved. There is no 

locomotive available.

7. Can a freestanding mobile system be used? No.

8. Does the facility have a rescue plan in place to assist someone in an emergency? 

This may also include providing suspension/relief foot straps for fall protection 

harnesses. Yes. FGIS has been provided a copy of the facility rescue plan. Fall

protection is not being used therefore suspension straps are not necessary.

FINAL ASSESSMENT – IS FALL PROTECTION FEASIBLE?

No. There is no fall protection available contiguous to where the work is being

performed. If the applicant was able to position the railcar under the fall protection,

then fall protection would be feasible. Under the current circumstances, it is not feasible.
FGIS Directive 9170.14 August 4, 2014

Page 10

Example #2

Situation: Every car in the rail yard needs a stowage exam prior to loading. The grain 

elevator sends a crew out in the morning to prepare the cars for loading. The grain 

elevator requests official personnel to perform the stowage exams at the same time. Fall 

protection is not contiguous to where the work is being performed.

Is fall protection feasible?
FGIS Directive 9170.14 August 4, 2014

Page 11

EXAMPLE #2 - Rolling Stock Fall Protection Assessment:

1. Is a suitable fall arrest system installed in location where AMS employees are 

sampling or performing stowage exams? No. Cars are being examined approximately

1⁄2 mile away from existing fall protection.

a. Is the system free of hazards? (e.g., overhead clearance) N/A

b. Are there any other hazardous conditions which make working on top of the 

railcars unsafe? No

2. Is the area where sampling/stowage exam is to take place contiguous to a building 

or permanent structure? No

a. If yes, why isn’t fall protection provided? N/A

3. How far is the nearest building or permanent structure from the area AMS 

employees are to sample/perform stowage exam? Approximately 1⁄2 mile.

4. What type of surface is contiguous to the area where sampling/stowage exam is to 

take place? Gravel

5. Is this a multiple track yard? Yes.

a. If yes, how many tracks are used for sampling? As many as 4.

6. Can railcars be positioned next to a building, structure, or other area where fall 

arrest system may be used? No, the railcars cannot be moved.

7. Can a freestanding mobile system be used? No.

8. Does the facility have a rescue plan in place to assist someone in an emergency? 

This may also include providing suspension/relief foot straps for fall protection 

harnesses. Yes. FGIS has been provided a copy of the facility rescue plan. Fall

protection is not being used therefore suspension straps are not necessary.

FINAL ASSESSMENT – IS FALL PROTECTION FEASIBLE?

No. There is no fall protection available contiguous to where the work is being

performed. If the applicant was able to position the railcars under the fall protection,

then fall protection would be feasible. Under the current circumstances, it is not feasible.
FGIS Directive 9170.14 August 4, 2014

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Example #3

Situation: All 16 cars on track need probed. Fall protection at this facility is only 5-cars 

long. There is no locomotive available to move the cars under fall protectio

Is fall protection feasible?
FGIS Directive 9170.14 August 4, 2014

Page 13

EXAMPLE #3 - Rolling Stock Fall Protection Assessment:

1. Is a suitable fall arrest system installed in location where AMS employees are 

sampling or performing stowage exams? Yes, but only approx 5 car lengths long.

a. Is the system free of hazards? (e.g., overhead clearance) Yes.

b. Are there any other hazardous conditions which make working on top of the 

railcars unsafe? No.

2. Is the area where sampling/stowage exam is to take place contiguous to a building

or permanent structure? No

a. If yes, why isn’t fall protection provided? N/A

3. How far is the nearest building or permanent structure from the area AMS 

employees are to sample/perform stowage exam? N/A

4. What type of surface is contiguous to the area where sampling/stowage exam is to 

take place? Gravel

5. Is this a multiple track yard? No.

a. If yes, how many tracks are used for sampling? N/A

6. Can railcars be positioned next to a building, structure, or other area where fall 

arrest system may be used? No, the railcar cannot be moved. There is no 

locomotive available.

7. Can a freestanding mobile system be used? No

8. Does the facility have a rescue plan in place to assist someone in an emergency? 

This may also include providing suspension/relief foot straps for fall protection 

harnesses. Yes. FGIS has been provided a copy of the facility rescue plan. The

facility has suspension relief straps available for FGIS personnel working under fall

protection.

FINAL ASSESSMENT – IS FALL PROTECTION FEASIBLE?

Yes for the first 5 cars, but no for the remaining 11 cars. Use FP for the cars positioned

under fall protection, however FP is not feasible for the remaining 11 cars.
FGIS Directive 9170.14 August 4, 2014

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Example #4

Situation: FGIS is called out to a feed mill in a remote area. All 7 railcars pictured need 

probed. They are contiguous to a building. There is no fall protection equipment on-site 

or readily available

Is fall protection feasible?
FGIS Directive 9170.14 August 4, 2014

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EXAMPLE #4 - Rolling Stock Fall Protection Assessment:

1. Is a suitable fall arrest system installed in location where AMS employees are 

sampling or performing stowage exams? No.

a. Is the system free of hazards? (e.g., overhead clearance) N/A

b. Are there any other hazardous conditions which make working on top of the 

railcars unsafe? No.

2. Is the area where sampling/stowage exam is to take place contiguous to a building

or permanent structure? Yes, the cars are positioned next to a warehouse.

a. If yes, why isn’t fall protection provided? The warehouse was not designed to 

 support a fall protection system, and no system is installed.

3. How far is the nearest building or permanent structure from the area AMS 

employees are to sample/perform stowage exam? Next to the railcars.

4. What type of surface is contiguous to the area where sampling/stowage exam is to 

take place? Gravel

5. Is this a multiple track yard? Yes.

a. If yes, how many tracks are used for sampling? 2.

6. Can railcars be positioned next to a building, structure, or other area where fall 

arrest system may be used? The railcars are positioned next to a building, but it is 

not suitable to sustain fall protection.

7. Can a freestanding mobile system be used? No. The applicant does not have a 

mobile system.

8. Does the facility have a rescue plan in place to assist someone in an emergency? 

This may also include providing suspension/relief foot straps for fall protection 

harnesses. Yes. FGIS has been provided a copy of the facility rescue plan

FINAL ASSESSMENT – IS FALL PROTECTION FEASIBLE?

No. Although there is a building located adjacent to where the work is being performed,

it does not have a fall protection system, nor was it designed to accommodate one. Fall

protection is not feasible.
FGIS Directive 9170.14 August 4, 2014

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Example #5

Situation: FGIS must perform a stowage exam on each car before they are loaded. At 

this location, elevator personnel bring up 5 cars at a time. Elevator personnel then hook 

up to fall protection and open the lids to prepare the cars for loading (this is done in the 

“Stowage Exam Area”). Once the cars are prepared and pass stowage inspection, the 

cars are moved to the “Loading Area” for loading. Elevator personnel request FGIS to

come out to the “Stowage Exam Area” to perform a stowage exam while the elevator 

crew preps the cars for loading.

If FGIS personnel perform a stowage exam in the “Stowage Exam Area,” is fall 

protection feasible?
FGIS Directive 9170.14 August 4, 2014

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EXAMPLE #5 - Rolling Stock Fall Protection Assessment:

1. Is a suitable fall arrest system installed in location where AMS employees are 

sampling or performing stowage exams? YES

a. Is the system free of hazards? (e.g., overhead clearance) Yes.

b. Are there any other hazardous conditions which make working on top of the 

railcars unsafe? No.

2. Is the area where sampling/stowage exam is to take place contiguous to a building 

or permanent structure? No.

a. If yes, why isn’t fall protection provided? N/A

3. How far is the nearest building or permanent structure from the area AMS 

employees are to sample/perform stowage exam? Approx 50 feet.

4. What type of surface is contiguous to the area where sampling/stowage exam is to 

take place? Asphalt

5. Is this a multiple track yard? Yes.

a. If yes, how many tracks are used for sampling? 2.

6. Can railcars be positioned next to a building, structure, or other area where fall 

arrest system may be used? Yes. The railcars are positioned under fall protection.

7. Can a freestanding mobile system be used? No (the applicant has a permanent fall

protection system in place).

8. Does the facility have a rescue plan in place to assist someone in an emergency? 

This may also include providing suspension/relief foot straps for fall protection 

harnesses. Yes. FGIS has been provided a copy of the facility rescue plan. The

facility rescue plan calls for the applicant to provide suspension straps to FGIS 

personnel working on fall protection in the event of an emergency.

FINAL ASSESSMENT – IS FALL PROTECTION FEASIBLE?

YES. In this scenario, FGIS employees must use fall protection.

The important thing to consider is where the work is being performed. Elevator

personnel move the cars under fall protection into the “Stowage Exam Area” and 

request service at that location. Therefore, FGIS personnel must use fall protection. If 

the service was requested out in the railyard on “Track 1,” and the cars could not be 

moved into the “Stowage Exam Area,” fall protection would not be feasible.
FGIS Directive 9170.14 August 4, 2014

Page 18

Example #6

Situation: FGIS is called out to a feed mill in a remote area. All 7 railcars pictured need 

probed. They are contiguous to a building. There is no fall protection equipment onsite or readily available. There are also several overhead power lines above where the 

railcars will be sampled.

Is fall protection feasible?
FGIS Directive 9170.14 August 4, 2014

Page 19

EXAMPLE #6 - Rolling Stock Fall Protection Assessment:

1. Is a suitable fall arrest system installed in location where AMS employees are 

sampling or performing stowage exams? No.

a. Is the system free of hazards? (e.g., overhead clearance) N/A.

b. Are there any other hazardous conditions which make working on top of the 

railcars unsafe? YES – overhead power lines above the railcars. Dismiss the 

request for service.

2. Is the area where sampling/stowage exam is to take place contiguous to a building 

or permanent structure? N/A.

a. If yes, why isn’t fall protection provided? N/A

3. How far is the nearest building or permanent structure from the area AMS 

employees are to sample/perform stowage exam? N/A

4. What type of surface is contiguous to the area where sampling/stowage exam is to 

take place? N/A

5. Is this a multiple track yard? N/A

a. If yes, how many tracks are used for sampling? N/A

6. Can railcars be positioned next to a building, structure, or other area where fall 

arrest system may be used? N/A

7. Can a freestanding mobile system be used? N/A

8. Does the facility have a rescue plan in place to assist someone in an emergency? 

This may also include providing suspension/relief foot straps for fall protection 

harnesses. N/

FINAL ASSESSMENT – IS FALL PROTECTION FEASIBLE?

Not applicable. The overhead power lines present a hazard and FGIS personnel may 

not provide service, regardless of fall protection.
FGIS Directive 9170.14 August 4, 2014

Page 20

Example #7

Situation: FGIS is called out to a feed mill in a remote area. All 7 railcars pictured need 

probed. They are contiguous to a building, however there is heavy rain and a 45 mph 

wind. There is no fall protection equipment on-site or readily available. 

Is fall protection feasible?
FGIS Directive 9170.14 August 4, 2014

Page 21

EXAMPLE #7 - Rolling Stock Fall Protection Assessment:

1. Is a suitable fall arrest system installed in location where AMS employees are 

sampling or performing stowage exams? No.

a. Is the system free of hazards? (e.g., overhead clearance) N/A.

b. Are there any other hazardous conditions which make working on top of the

railcars unsafe? YES. There is strong wind and rain, which could make 

working on top of rolling stock hazardous. Dismiss the request for service.

2. Is the area where sampling/stowage exam is to take place contiguous to a building 

or permanent structure? N/A

a. If yes, why isn’t fall protection provided? N/A

3. How far is the nearest building or permanent structure from the area AMS

employees are to sample/perform stowage exam? N/A

4. What type of surface is contiguous to the area where sampling/stowage exam is to 

take place? N/A

5. Is this a multiple track yard? N/A.

a. If yes, how many tracks are used for sampling? N/A.

6. Can railcars be positioned next to a building, structure, or other area where fall 

arrest system may be used? N/A

7. Can a freestanding mobile system be used? N/A

8. Does the facility have a rescue plan in place to assist someone in an emergency? 

This may also include providing suspension/relief foot straps for fall protection 

harnesses. N/

FINAL ASSESSMENT – IS FALL PROTECTION FEASIBLE?

Not applicable. The severe weather presents a hazard and FGIS personnel may not

provide service.