Comprehensive SWMS for Shipping Container Devanning and Unpacking Operations

Shipping Container Unloading Safe Work Method Statement

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Shipping container unloading and devanning operations involve removing goods, materials, and equipment from enclosed international or domestic shipping containers. This SWMS addresses critical safety requirements for confined space assessment and entry procedures, unstable load identification and stabilization, manual handling of heavy or awkward materials, fumigation and hazardous atmosphere detection, coordination with lifting equipment operators, and safe work practices for container unpacking in construction and warehousing environments.

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Overview

What this SWMS covers

Shipping container unloading, commonly termed devanning or unpacking, involves the manual or mechanical extraction of goods and materials from enclosed steel containers used for international and domestic freight transport. Standard shipping containers measure 20 feet (6.1 metres) or 40 feet (12.2 metres) in length, 8 feet (2.4 metres) wide, and 8.5 feet (2.6 metres) high, creating enclosed spaces with volumes up to 67 cubic metres that must be entered to access cargo packed at the front of containers. High cube containers add approximately 300mm additional height. Construction materials commonly shipped in containers include ceramic tiles, sanitary fixtures, hardware and fixings, prefabricated components, architectural finishes, imported equipment, and specialized building products sourced internationally. Containers are typically packed to maximize cubic capacity and minimize freight costs, resulting in floor-to-ceiling stacking of goods often weighing 20-25 tonnes total. Items may be palletized for forklift handling, individually wrapped and hand-stacked, or secured with timber blocking and lashing. During international sea freight lasting weeks or months, cargo may shift due to vessel movement despite initial proper packing, creating unstable configurations that present collapse hazards when restraints are removed. Containers that have been in transit or storage may develop hazardous atmospheres from cargo off-gassing, chemical spills, fumigation treatments, or oxygen depletion from organic materials, rust formation, or bacterial activity. Temperature extremes during transport can cause condensation leading to mold growth, corrosion of metal goods, or degradation of packaging materials. Unloading operations require coordination between multiple personnel including truck drivers delivering containers to sites, forklift or crane operators positioning containers for access, workers entering containers to unpack goods, checkers verifying quantities against shipping manifests, and quality inspectors examining goods for transit damage. Mechanical handling using forklifts or hand pallet jacks may extract palletized goods, while manually packed items require workers to enter containers to carry or pass items to personnel outside. The enclosed nature of containers, limited entry/exit access through single end doors, poor natural lighting, and potential for oxygen-deficient or contaminated atmospheres creates confined space hazards requiring specific risk assessment and controls. Shipping containers arriving from international origins may have been fumigated with toxic gases including methyl bromide, phosphine, or formaldehyde to prevent pest transfer. Fumigants are neurotoxic chemicals that can remain trapped in cargo or container cavities for extended periods after treatment, presenting acute poisoning risk to workers entering containers without appropriate atmospheric testing. Some cargo types including certain timber products, chemicals, or agricultural materials naturally off-gas hazardous substances. Containers used for previous hazardous cargo may have residual contamination even after cleaning. Australian biosecurity regulations require specific pest and disease controls for imported goods, sometimes involving ongoing fumigation processes that must be completed before container access is permitted. Documentation including Material Safety Data Sheets, fumigation certificates, and cargo manifests provides critical information about potential chemical exposures, but may not always be available or accurate at receiving sites. Australian workplace health and safety regulations classify shipping container entry for unloading as confined space work when atmospheric hazards exist, entry is required for work purpose, and space is enclosed or partially enclosed. Confined space entry requires specific risk assessment, atmospheric testing, permits to work, emergency rescue arrangements, and trained personnel. The confined space determination depends on specific container conditions and cargo type rather than container size alone. Manual handling of heavy building materials, working in awkward postures when extracting items from tight stacking configurations, repetitive lifting during extended unpacking operations, and potential struck-by hazards from unstable loads all contribute to injury risks requiring documented procedures and appropriate training for workers performing container unloading operations.

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Why this SWMS matters

Shipping container unloading operations have resulted in multiple worker fatalities and serious injuries in Australian workplaces, with primary causes including oxygen-deficient atmospheres causing asphyxiation, fumigant poisoning from trapped toxic gases, crushing from collapsed loads, and manual handling injuries from repetitive heavy lifting. Safe Work Australia incident investigations have documented deaths from workers entering containers with oxygen levels below 16% causing unconsciousness and death within minutes, phosphine gas poisoning from fumigated cargo, and workers buried under collapsed stacks of bagged or boxed materials. The enclosed nature of containers means that unconscious workers cannot be easily observed or rescued, while would-be rescuers entering containers to help collapsed co-workers often become additional victims of the same atmospheric hazard that caused the initial incident. Under Work Health and Safety Act 2011, persons conducting a business or undertaking have duties to ensure worker health and safety when conducting confined space entry, managing manual handling risks, and preventing exposure to hazardous chemicals. For shipping container unloading, this requires atmospheric testing before entry where contamination risk exists, provision of mechanical aids to reduce manual handling, implementation of load restraint and stabilization procedures preventing collapses, training of personnel in safe unloading techniques, and emergency response procedures for medical emergencies in containers. WHS regulations establish specific confined space requirements including risk assessment, elimination of entry where possible, atmospheric testing and monitoring, provision of respiratory protection where required, permits to work, trained standby personnel, and rescue procedures that do not require rescuers to enter hazardous atmospheres. The Biosecurity Act 2015 and associated import conditions administered by Department of Agriculture, Fisheries and Forestry impose fumigation and treatment requirements for many imported goods including timber, plant materials, and products from certain countries. Containers may arrive bearing fumigation warnings or with fumigant sachets still active inside cargo. Fumigants including phosphine (aluminum or magnesium phosphide) and methyl bromide are highly toxic, with exposure limits measured in parts per million requiring atmospheric monitoring to detect. Phosphine in particular can accumulate in container dead spaces and in porous cargo materials, releasing slowly over days or weeks. Workers entering fumigated containers without appropriate controls have died from acute poisoning or asphyxiation. Liability for fumigant exposures can extend to importers, freight forwarders, and site controllers who should have knowledge of fumigation status through documentation. Manual handling injuries represent the most frequent workers' compensation claims in warehousing and transport sectors, with container unloading operations presenting particular risk due to heavy building materials, awkward reaching and lifting postures when extracting items from deep in containers, confined working space limiting proper manual handling technique, and sustained repetitive lifting during extended unloading operations. Ceramic tiles, sanitary ware, stone products, and metal fittings commonly imported for construction projects are dense heavy materials often packed in awkward sizes. Workers develop cumulative musculoskeletal disorders from repeated exposure over months or years, as well as acute strains from single lifts of excessive loads or in poor postures. The economic cost to businesses includes workers' compensation premiums, lost productivity during worker absence, light duty limitations, and potentially permanent disability for severe injuries. Implementing comprehensive SWMS for shipping container unloading establishes systematic hazard identification and control procedures addressing atmospheric testing requirements, confined space entry protocols, mechanical handling provisions, load stability assessment, and manual handling techniques. Documentation ensures workers understand container-specific hazards that may not be evident from external inspection, provides clear entry procedures preventing access to hazardous atmospheres, and demonstrates due diligence in the event of incidents. Given the fatality potential from atmospheric hazards, crush hazards from unstable loads, and chronic injury risk from manual handling, proper SWMS implementation is fundamental to worker protection and regulatory compliance in container unloading operations.

Reinforce licensing, insurance, and regulator expectations for Shipping Container Unloading Safe Work Method Statement crews before they mobilise.

Hazard identification

Surface the critical risks tied to this work scope and communicate them to every worker.

Risk register

Oxygen-Deficient and Hazardous Atmospheres in Sealed Containers

High

Shipping containers that have been sealed during extended transit or storage can develop oxygen-deficient atmospheres below safe 19.5% oxygen levels, or accumulate toxic gases creating immediate life-threatening hazards to workers entering containers. Oxygen depletion occurs through rust formation consuming oxygen, decomposition of organic materials including timber dunnage or cargo, bacterial activity in moisture-contaminated cargo, and absorption by certain chemical products. Workers entering containers with oxygen below 16% will lose consciousness within seconds, suffering brain damage or death within minutes. The lack of warning odor or visible indicators means workers may be unaware of oxygen deficiency until collapse occurs. Hazardous atmospheres also result from fumigant gases including phosphine, methyl bromide, or formaldehyde remaining trapped in containers after pest treatment, cargo off-gassing from chemicals, solvents, or treated timber products, and carbon monoxide from organic material decomposition. Container geometry with dead air spaces in corners and ceiling areas allows stratification where hazardous gases accumulate in pockets even when bulk atmosphere tests normal.

Consequence: Fatal asphyxiation from oxygen deficiency causing unconsciousness and death within minutes, acute poisoning from fumigant exposure causing neurological damage or fatality, multiple casualties when rescuers enter containers to assist collapsed workers becoming secondary victims, and permanent neurological impairment from oxygen deprivation in surviving workers.

Unstable Load Collapse and Avalanche During Unloading

High

Cargo packed tightly in containers to maximize freight efficiency can shift during transport creating unstable configurations that avalanche when container doors open or when restraints are removed during unloading. Load instability results from inadequate packing and blocking during container loading at origin, timber dunnage deterioration or shifting during transit, securing straps or lashing breaking under load movement, moisture ingress causing packaging failure or pallets to collapse, and container handling including lifting and transport causing cargo to lean or separate from original configuration. Heavy materials including ceramic tiles, bagged cement or chemicals, steel products, and stone items can weigh hundreds of kilograms per unit, creating crush hazard when multiple units collapse simultaneously. Workers opening container doors while standing in line with cargo can be struck by material avalanching out of containers. Personnel working inside containers extracting cargo can be buried under collapsing stacks when supporting materials are removed. Poor visibility due to limited lighting prevents workers from recognizing unstable configurations before triggering collapse.

Consequence: Fatal crushing injuries when workers are buried under collapsed cargo, severe traumatic injuries including fractures and internal trauma requiring emergency response, entrapment requiring complex rescue operations, and delayed rescue due to cargo weight making victim extraction difficult.

Manual Handling Injuries from Heavy and Awkward Materials

Medium

Container unloading involves sustained manual handling of construction materials often weighing 15-30 kg per unit, with awkward sizes, poor handholds, and requirement to lift from floor level to waist height repeatedly during extended unloading operations. Manual handling risks are compounded by constrained working space inside containers limiting proper lifting posture, reaching deep into containers to access cargo packed at front reducing mechanical advantage, repetitive lifting of hundreds of units during single container unpacking, twisting and lateral movement when passing items to co-workers, sustained static postures when working in confined container space, and inadequate recovery time between containers when continuous unloading is required. Materials including boxed tiles, sanitary fixtures in packaging, bagged products, and individually wrapped items may lack proper handholds forcing workers to use pinch grips increasing forearm strain. Container floor height approximately 1.2 metres above ground requires workers to lift materials above shoulder height for passing to personnel outside. Ambient temperatures inside sealed containers in summer can exceed 50°C causing rapid fatigue and heat stress affecting safe handling capacity.

Consequence: Acute back and shoulder strains from excessive loads or poor postures, cumulative musculoskeletal disorders developing over months or years of repetitive exposure, chronic pain and disability requiring ongoing medical treatment, reduced work capacity and light duty restrictions, and workers' compensation claims with significant economic costs.

Fumigant Chemical Exposure from Treated Cargo

High

Shipping containers arriving from international origins may contain cargo fumigated with highly toxic chemicals to comply with biosecurity requirements, with fumigants remaining trapped in cargo, packaging materials, or container cavities for extended periods after treatment. Common fumigants include phosphine gas generated from aluminum or magnesium phosphide pellets, methyl bromide injected as pressurized gas, and formaldehyde used for wood packaging treatment. Phosphine exposure above 0.3 ppm causes pulmonary edema, neurological damage, and can be fatal, while methyl bromide is neurotoxic affecting central nervous system. Fumigants are often odorless at dangerous concentrations or have odors that fade with continued exposure, preventing workers from detecting hazardous levels. Porous materials including timber, fabrics, and cardboard absorb fumigants during treatment then release them slowly over days or weeks. Fumigation placards may be removed or damaged during transport, and documentation may not reach receiving sites before containers arrive. Workers unaware of fumigation status enter containers without atmospheric testing or respiratory protection. Some fumigation protocols require specified aeration periods before container entry, but compliance may be inadequate particularly when commercial pressure exists for rapid unloading.

Consequence: Acute chemical poisoning causing respiratory distress, neurological symptoms, and potential fatality from high-level exposure, chronic health effects from repeated low-level exposure including neurological impairment, chemical burns to respiratory system requiring medical treatment, and potential reproductive or developmental effects from certain fumigants.

Insufficient Lighting and Poor Visibility Inside Containers

Medium

Shipping containers have no internal lighting and limited natural light penetration through single end door opening, creating poor visibility particularly when working deep inside containers or with cargo blocking door light. Insufficient lighting prevents workers from identifying trip hazards, recognizing unstable loads, reading product labels, detecting packaging damage, and safely navigating around obstacles. Shadows from partial lighting at door create dark zones where hazards are invisible. Workers' eyes require time to adapt between bright outdoor conditions and dark container interiors reducing visual acuity. Portable lighting may be inadequate for container size or may create glare and shadow effects reducing rather than improving visibility. Extension cords for lighting create trip hazards in confined container space. Battery-powered lights have limited duration potentially leaving workers in darkness if batteries deplete during unloading. Poor visibility increases risk of all other hazards including striking obstacles, tripping over cargo, failing to recognize unstable loads, and inability to read safety warnings on hazardous cargo.

Consequence: Increased risk of trips, slips, and falls causing injuries, inability to recognize unstable loads or hazards before incidents occur, contact with hazardous materials not visible in poor light, eye strain and fatigue affecting work quality, and reduced situational awareness creating general safety degradation.

Struck-By Hazards from Forklift and Materials Handling Equipment

High

Container unloading operations involve close coordination between workers inside containers manually unpacking goods and forklift or machinery operators extracting pallets or heavy items, creating collision hazards in confined areas with limited visibility and escape routes. Struck-by incidents occur when forklift operators do not detect workers inside or behind containers before inserting forks or moving extracted loads, workers step into forklift paths when exiting containers, inadequate communication between manual workers and equipment operators, load swings or shifts striking workers positioned nearby, and containers on trailers moving if truck is not properly secured. The confined nature of container access areas limits space for workers to remain clear of forklift operating zones. Reversing forklifts may not detect workers in blind spots. Workers focused on unpacking tasks may not maintain awareness of forklift movements. Noise from forklifts and other site activities masks warning alarms and verbal communication. Time pressure creates incentive for simultaneous operations rather than sequential work maintaining separation between manual workers and equipment.

Consequence: Fatal injuries from being struck or crushed by forklifts or heavy loads, serious trauma including fractures and internal injuries requiring emergency medical response, amputations from being caught between equipment and container structures, and potential multiple casualties if forklift impacts cause load collapse affecting several workers.

Control measures

Deploy layered controls aligned to the hierarchy of hazard management.

Implementation guide

Mandatory Atmospheric Testing and Confined Space Entry Procedures

Elimination

Preventing atmospheric hazard exposures requires elimination of entry to containers with hazardous atmospheres through atmospheric testing before any personnel access, mechanical unloading methods avoiding entry where possible, and aeration procedures reducing contamination to safe levels before entry is permitted. This control includes using calibrated gas detection equipment testing for oxygen percentage, flammable gases, toxic gases including phosphine and carbon monoxide, and other contaminants identified through cargo documentation. Testing must sample multiple locations including floor level and ceiling areas where stratified gases accumulate. Where hazardous atmospheres are detected, containers must be ventilated using forced air circulation before retesting and entry. If mechanical extraction using reach forklifts or crane lifting can remove cargo without personnel entering containers, this eliminates confined space hazards entirely. Documentation including fumigation certificates, dangerous goods declarations, and material safety data sheets identifies cargo requiring particular atmospheric monitoring.

Implementation

1. Establish policy requiring atmospheric testing before any personnel enter shipping containers, regardless of cargo type or apparent absence of hazards. 2. Procure calibrated multi-gas detectors measuring oxygen percentage, lower explosive limit, carbon monoxide, phosphine, and other gases relevant to common cargo types. 3. Conduct calibration and bump testing of gas detection equipment before each use verifying accurate readings and alarm function at specified setpoints. 4. Train competent personnel in gas detector operation, interpretation of readings, sampling procedures for stratified atmospheres, and response to hazardous readings. 5. Test containers by inserting probe through gap between doors before fully opening, sampling at floor, mid-height, and ceiling levels to detect stratification. 6. Establish minimum acceptable atmosphere standards: oxygen 19.5-23.5%, carbon monoxide below 30 ppm, phosphine below 0.3 ppm, flammable gases below 10% LEL. 7. Where hazardous atmospheres are detected, implement forced ventilation using blowers or fans circulating air for minimum 30 minutes before retesting. 8. Prohibit entry to containers with hazardous atmospheres until testing confirms atmosphere has reached safe parameters and remains stable. 9. Use mechanical extraction methods including long-reach forklifts, vacuum lifting equipment, or crane lifting to unload cargo without personnel entry where practical. 10. Document all atmospheric testing including date, time, equipment used, readings obtained, actions taken for hazardous atmospheres, and authorization for entry where testing confirms safe conditions.

Load Stability Assessment and Controlled Door Opening Procedures

Engineering

Preventing load collapse incidents requires engineering controls including visual assessment before doors open, controlled door opening from safe position, installation of cargo netting or barriers if instability is detected, and systematic unloading procedures working top-to-bottom and front-to-back maintaining load stability. External inspection before doors open looks for container lean indicating shifted cargo, damage to container walls from internal pressure, and bulging doors suggesting material pressing against them. Door opening procedures require personnel to stand beside rather than in line with door opening, releasing one door fully before opening second door, and opening doors slowly ready to close if cargo begins shifting. If cargo appears unstable, netting or rope barriers can be installed across door opening before unloading begins. Internal unloading works from top of stacks downward and from door toward front maintaining stable configuration. Mechanical restraints including strapping or blocking prevent sudden collapse. This systematic approach prevents sudden avalanche incidents and provides controlled unloading even of shifted cargo.

Implementation

1. Conduct external container inspection before opening doors checking for lean, wall damage, floor distortion, or other indicators of internal cargo movement or damage. 2. Listen for sounds of moving or settling cargo when container is positioned, waiting for movement to cease before opening doors. 3. Require personnel opening doors to stand beside hinge side rather than in line with door opening, preventing being struck if cargo avalanches outward. 4. Open locking bars and release one door only initially, observing for cargo pressing against doors or beginning to shift before opening second door. 5. If cargo appears unstable or is pressing on doors, install cargo netting or rope barrier across opening before fully releasing doors, containing cargo movement. 6. Enter container initially only for visual assessment of load stability, identifying lean, separated stacks, damaged packaging, or configurations requiring stabilization. 7. Install additional internal restraints including strapping or timber blocking if unstable configurations are identified before commencing removal of cargo. 8. Implement unloading sequence working from top of stacks to bottom, removing upper layers before lower support materials, preventing collapse from removing base support. 9. Work from door progressing toward container front, maintaining access to exit and preventing workers from being trapped behind unstable material. 10. Remove cargo symmetrically from both sides of container maintaining balanced loading rather than creating one-sided loads that could cause tipping or further instability.

Mechanical Handling Equipment and Manual Handling Aid Provision

Engineering

Reducing manual handling injuries requires engineering controls providing mechanical aids eliminating or reducing need for manual lifting. This includes forklift access for palletized cargo, hand pallet jacks or trolleys for moving units without carrying, conveyor systems allowing items to be slid or rolled rather than lifted, height-adjustable work platforms positioning workers at ergonomic height for container floor, and team lifting protocols for items exceeding individual safe lifting limits. Cargo can be transferred to wheeled carts inside containers then rolled out rather than carried. Scissor lifts or elevated work platforms position personnel at container floor level eliminating lifting above shoulder height. Gravity conveyors or roller ramps allow items to slide down from container floor to ground level. Where manual lifting is unavoidable, training in proper lifting technique, job rotation reducing sustained exposure, and scheduled rest breaks preventing fatigue accumulation all reduce injury risk. Design of unloading workspace provides adequate space for proper technique rather than forcing awkward postures.

Implementation

1. Provide forklift access for containers with palletized cargo, using appropriate capacity forklifts with reach adequate for container depth. 2. Supply hand pallet jacks rated for heavy loads allowing workers to move pallets and heavy items without manual carrying. 3. Provide robust wheeled carts or dollies that fit inside container aisles, allowing workers to load items onto carts then roll out rather than carrying. 4. Install temporary roller conveyor or skate wheel conveyor spanning from container floor to ground level, allowing items to be slid rather than lifted. 5. Position hydraulic scissor lift or elevated work platform adjacent to container bringing workers to container floor level, eliminating lifting above shoulder height. 6. Implement team lifting protocols for items exceeding 15 kg individual safe lifting limits, requiring two or more workers to coordinate lifts of heavy materials. 7. Organize container workspace providing adequate clear floor area inside for workers to use proper lifting posture without working in cramped positions. 8. Provide anti-fatigue matting for workers standing on container metal floors for extended periods, reducing lower limb fatigue and improving comfort. 9. Schedule regular rest breaks every 45-60 minutes during sustained manual unloading operations, allowing physical recovery and preventing fatigue accumulation. 10. Rotate workers between different tasks including manual handling, forklift operation, checking, and other duties reducing continuous manual handling exposure.

Fumigation Documentation Review and Hazard Communication

Administrative

Identifying fumigation hazards requires administrative controls reviewing cargo documentation before container arrival, communicating fumigation status to all personnel, implementing mandatory aeration periods for treated cargo, and prohibiting container access until fumigant testing confirms safe atmosphere. Documentation including bills of lading, fumigation certificates, dangerous goods declarations, and biosecurity treatment records identifies containers that have undergone chemical treatment. Some containers bear fumigation placards with treatment dates and gases used. Administrative controls establish minimum aeration periods based on fumigant type before testing and entry is permitted, ranging from 24 hours to several days depending on chemical and cargo porosity. Clear communication ensures all workers understand fumigation hazards and that containers are not accessed without authorization. This systematic approach prevents exposure to toxic fumigants through proactive identification and control rather than reactive response to incidents.

Implementation

1. Establish procedures requiring review of shipping documentation before container delivery, identifying any fumigation certificates, dangerous goods declarations, or treatment notifications. 2. Implement container manifest system tracking fumigation status, treatment dates, chemicals used, and minimum aeration periods before access is permitted. 3. Mark fumigated containers with highly visible warning placards stating fumigation status, chemical type, treatment date, and no entry restrictions. 4. Implement minimum aeration periods based on fumigant type: phosphine minimum 48 hours, methyl bromide 24 hours, in well-ventilated areas before testing. 5. Require mandatory atmospheric testing for all fumigated containers regardless of elapsed aeration time, using appropriate gas-specific detection equipment. 6. Prohibit container access until testing confirms fumigant concentrations below safe exposure limits with margin for continued off-gassing. 7. Brief all personnel working with containers on fumigation hazards, symptoms of exposure, and requirement never to enter containers without atmospheric test clearance. 8. Provide fumigant-specific safety data sheets accessible to all workers, detailing toxicity, exposure symptoms, first aid, and emergency response procedures. 9. Establish incident reporting requirements for workers experiencing symptoms after container entry, even if atmospheric testing indicated safe levels. 10. Coordinate with importers and freight forwarders requesting advance notice of fumigated shipments allowing proper planning of testing and aeration before delivery schedules.

Adequate Lighting Systems for Container Interior Work

Engineering

Ensuring adequate visibility inside containers requires engineering controls providing artificial lighting achieving minimum 50 lux at floor level throughout working areas. Portable LED work lights on stands positioned inside containers provide general illumination without heat generation or fire hazard. Multiple lights eliminate shadow zones, with lights positioned to provide cross-illumination rather than single-source directional light. Rechargeable battery-powered lights avoid extension cord trip hazards and electrical risks in potentially wet containers. Intrinsically safe lights may be required if flammable atmospheres are possible. Head-mounted LED lights provide task illumination following worker line of sight. External lights positioned at container door provide supplementary illumination without occupying interior space. Adequate lighting allows workers to identify all hazards, read product labels, recognize packaging damage, and safely navigate container interior reducing all injury risks.

Implementation

1. Provide minimum two LED work lights rated for commercial/industrial use with stable bases or mounting systems preventing tip-over in confined container space. 2. Position lights inside container to provide cross-illumination from different angles, eliminating shadow zones where hazards could be concealed. 3. Use LED technology providing high-output illumination without heat generation that could create additional heat stress in containers. 4. Provide rechargeable battery-powered lights for containers where extension cords would create trip hazards or electrical risks from moisture. 5. Ensure light intensity achieves minimum 50 lux measured at floor level throughout working areas, with higher levels for detailed inspection tasks. 6. Supply workers with head-mounted LED lights providing supplementary task lighting following their line of sight when working in tight spaces. 7. Position external flood lights near container door providing supplementary illumination and maintaining visibility of exit path. 8. Maintain lighting equipment in functional condition with regular inspection, cleaning of lenses, and battery replacement ensuring reliable performance. 9. Use intrinsically safe or explosion-proof lighting if atmospheric testing indicates flammable vapors may be present in containers. 10. Test lighting adequacy before commencing unloading operations, adding supplementary lights if initial setup provides insufficient illumination.

Traffic Management and Equipment Coordination Protocols

Administrative

Preventing struck-by incidents requires administrative controls separating workers from operating equipment through traffic management, exclusion zones during equipment operation, communication protocols between workers and operators, and sequential work procedures rather than simultaneous operations. Traffic management establishes designated forklift operating zones separated from manual work areas using barriers or line marking. Exclusion zones require manual workers to exit containers and remain at safe distances while forklifts extract pallets. Communication using two-way radios or hand signals coordinates work between workers inside containers and equipment operators outside. Permit to work systems control container access ensuring only authorized personnel are in containers and equipment operators are aware. Spotter personnel maintain situational awareness of worker locations and equipment movements providing additional safety oversight. This systematic separation prevents workers and equipment from occupying same space simultaneously.

Implementation

1. Develop site traffic management plan for unloading areas showing forklift approach paths, manual work zones, and clear separation between equipment and pedestrian areas. 2. Establish exclusion zones requiring manual workers to exit containers and remain behind barriers while forklifts insert forks or extract pallets. 3. Implement communication protocols using two-way radios or standardized hand signals allowing workers and forklift operators to coordinate operations safely. 4. Require forklift operators to sound horn and wait for acknowledgment before approaching containers, ensuring manual workers are aware of equipment movement. 5. Install high-visibility bollards, barriers, or line marking clearly showing forklift operating zones that must remain clear of pedestrian workers. 6. Implement permit to work system for container entry, logging workers in and out and ensuring forklift operators know when personnel are inside containers. 7. Provide high-visibility vests for all manual workers making them easily visible to equipment operators in busy unloading areas. 8. Assign dedicated spotter personnel for high-volume unloading operations, maintaining awareness of worker and equipment locations and stopping operations if conflicts develop. 9. Establish sequential work procedures where manual unpacking and forklift operations alternate rather than occurring simultaneously in same area. 10. Conduct pre-shift briefings with all unloading personnel including equipment operators reviewing traffic management, communication protocols, and individual responsibilities.

Download complete control procedures

Personal protective equipment

Respiratory Protection for Fumigated Containers

Requirement: P2 or P3 particulate respirator for low-level fumigants, full-face supplied-air for high concentrations per AS/NZS 1715/1716

When: Required when atmospheric testing shows fumigant presence above safe exposure limits, during initial aeration of recently fumigated containers, or when documentation indicates fumigation but testing is unavailable. Must be fit-tested to wearer.

Steel Toe Cap Safety Boots

Requirement: Certified to AS/NZS 2210.3 with steel toe protection and slip-resistant soles

When: Mandatory during all container unloading operations to protect feet from crushing injuries from dropped materials, struck-by hazards from rolled items, and penetration from nails or packaging components.

Cut-Resistant Gloves for Materials Handling

Requirement: Rated to Level C or D per AS/NZS 2161.2 with grip enhancement

When: Required during manual handling of materials with sharp edges including steel banding, timber packaging with splinters, and ceramic products with cut hazards. Must maintain dexterity for safe handling.

Hard Hat for Overhead Hazards

Requirement: Type 1 helmet compliant with AS/NZS 1801

When: Required when working inside containers with overhead crane or hoist operations, in areas where forklifts are lifting loads overhead, or where falling object hazards exist from stacked materials.

High-Visibility Vest

Requirement: Class D Day/Night compliant with AS/NZS 4602.1

When: Mandatory for all workers in unloading areas to ensure visibility to forklift operators, truck drivers, and other equipment operators. Essential when working in or around containers on busy sites.

Safety Glasses with Side Protection

Requirement: Impact-rated to AS/NZS 1337

When: Required during all container unloading to protect eyes from dust, debris, splinters from timber packaging, steel banding under tension, and particles from damaged goods.

Hearing Protection

Requirement: Class 4 or 5 earplugs or earmuffs per AS/NZS 1270 providing 25dB attenuation

When: Required in warehouse or site areas where ambient noise exceeds 85dB(A), when working near operating forklifts or other equipment producing sustained noise exposure.

Inspections & checks

Before work starts

  • ✓Review shipping documentation checking for fumigation certificates, dangerous goods declarations, and cargo manifests identifying hazardous materials requiring special handling
  • ✓Inspect container exterior for damage, leaning, bulging walls, or other indicators of internal cargo shifting or structural compromise
  • ✓Verify atmospheric testing equipment is calibrated and functional, conducting bump test confirming gas detector alarm operation at specified setpoints
  • ✓Check manual handling equipment including pallet jacks, trolleys, and carts are in working condition with wheels operating freely and no structural damage
  • ✓Ensure adequate lighting equipment is available with fully charged batteries or functional electrical connections for interior container illumination
  • ✓Verify first aid equipment including eyewash, emergency shower, and chemical spill kit are accessible in unloading area
  • ✓Confirm communication systems including two-way radios are operational allowing coordination between workers and equipment operators
  • ✓Brief all personnel on cargo type, identified hazards, atmospheric testing requirements, and emergency procedures before unloading commences

During work

  • ✓Monitor workers for signs of heat stress when working in sealed containers in hot weather including excessive sweating, fatigue, or disorientation
  • ✓Maintain situational awareness of equipment movements ensuring clear separation between manual workers and operating forklifts or other machinery
  • ✓Check load stability continuously as cargo is removed, identifying configurations requiring stabilization before workers continue accessing stacks
  • ✓Monitor atmospheric conditions if gas detection equipment is left operating, watching for any changes indicating continued off-gassing or oxygen depletion
  • ✓Observe workers for signs of chemical exposure including respiratory irritation, headaches, or nausea requiring immediate removal from container
  • ✓Verify lighting remains adequate throughout unloading as cargo is removed and shadows change, repositioning lights as needed
  • ✓Ensure exclusion zones remain enforced with manual workers exiting containers before forklift operations and equipment stopping before workers re-enter

After work

  • ✓Conduct final inspection of emptied container interior checking for any spilled materials, damaged packaging, or items requiring disposal
  • ✓Remove all lighting equipment, manual handling aids, and tools from container verifying nothing is left inside that could create hazard for subsequent handling
  • ✓Document any cargo damage discovered during unloading with photographs and descriptions for insurance and supplier quality claims
  • ✓Report any atmospheric hazards encountered, fumigation issues, or safety concerns for continuous improvement and communication to freight forwarders
  • ✓Clean and return all manual handling equipment to storage ensuring it is ready for next use and any damage is reported for repair
  • ✓Conduct worker debrief addressing any incidents, near-misses, or improvement opportunities identified during unloading operation
  • ✓Complete documentation including quantity received, quality issues, atmospheric testing records, and worker hours for compliance and payroll purposes

Step-by-step work procedure

Give supervisors and crews a clear, auditable sequence for the task.

Field ready
1

Review Documentation and Conduct Hazard Identification

Before container arrival, review shipping documentation including bill of lading, packing list, fumigation certificates, dangerous goods declarations, and material safety data sheets identifying cargo hazards. Check for fumigation status noting treatment dates, chemicals used, and aeration requirements. Identify any dangerous goods requiring special handling or storage. Review cargo weight and configuration planning adequate labor and equipment resources. Contact freight forwarder or importer if documentation is incomplete or unclear regarding hazards. Brief unloading team on cargo type, identified hazards including fumigation status, manual handling considerations based on materials and weights, and atmospheric testing requirements before container access. Prepare atmospheric testing equipment ensuring calibration is current and equipment is functional. Arrange manual handling aids including trolleys, pallet jacks, or forklifts appropriate for cargo type. Ensure lighting equipment, PPE, first aid supplies, and communication equipment are ready. Establish emergency contacts including poison information center for chemical exposure advice.

Safety considerations

Incomplete or missing documentation does not mean container is safe - fumigation hazards may exist without documentation. If fumigation status cannot be confirmed, treat container as potentially fumigated requiring atmospheric testing before access. Inadequate hazard identification leads to exposure to unsuspected hazards including toxic atmospheres and unstable loads. Never commence unloading without understanding cargo type and basic hazards.

2

Conduct Atmospheric Testing Before Container Access

Position container in well-ventilated outdoor area or warehouse loading dock with adequate air circulation. Before opening doors, conduct atmospheric testing by inserting gas detector probe through gap between door seals, sampling air from container interior. Test for oxygen percentage, carbon monoxide, flammable gases, and if fumigation is suspected, fumigant-specific gases including phosphine. Sample at floor, mid-height, and ceiling levels to detect stratified atmospheres. Acceptable atmosphere requires oxygen 19.5-23.5%, carbon monoxide below 30 ppm, flammable gases below 10% LEL, and fumigants below specific exposure limits. If hazardous atmosphere is detected, do not open doors fully. Implement forced ventilation using fans or blowers creating air circulation through container for minimum 30 minutes. Retest atmosphere after ventilation period confirming readings have reached safe parameters and remain stable. Document all testing results, ventilation actions, and clearance for entry. Only after safe atmosphere is confirmed and documented, authorize container door opening and personnel access.

Safety considerations

Entering containers with oxygen below 19.5% causes unconsciousness within seconds and death within minutes. Workers have died entering containers without atmospheric testing. Always test before entry regardless of cargo type or apparent absence of fumigation. Never enter container if any atmospheric reading is outside safe parameters. Forced ventilation must fully exchange container atmosphere - minimum 30 minutes ventilation is generally required.

3

Open Container Doors Using Controlled Procedure from Safe Position

Position personnel beside container on hinge side of doors rather than in line with door opening where cargo avalanche could strike workers. Release locking bars or twist-locks securing doors. Open one door only initially, watching and listening for any cargo movement or signs of instability. If cargo is pressed against door or appears unstable, stop and install cargo netting or rope barrier before fully opening. Once one door is safely opened, open second door while maintaining position beside rather than in front of opening. Conduct visual assessment from door entrance observing cargo configuration, evidence of shifting, damaged packaging, leaning stacks, or separated loads requiring stabilization. Do not enter container immediately - allow any residual off-gassing to dissipate with air circulation through opened doors. Install lighting equipment positioning work lights inside container to provide adequate illumination throughout interior. Set up manual handling equipment including trolleys or roller conveyors at door opening. Establish traffic management barriers or exclusion zones if forklifts will be used. Brief workers on specific unloading sequence based on observed cargo configuration.

Safety considerations

Workers have been killed by cargo avalanching when container doors opened. Always stand beside doors during opening, never in line with potential cargo movement path. If cargo appears unstable, install restraints before removing cargo. Adequate lighting before entry allows identification of hazards that would be invisible in darkness. Allow time for air exchange before entry reduces exposure to any residual contamination.

4

Establish Safe Work Zone and Implement Traffic Management

Before manual workers enter container, establish clear traffic management separating pedestrian workers from equipment operating areas. Mark forklift approach paths using cones, barriers, or line marking. Designate exclusion zones where manual workers must remain while forklifts operate. Position barriers preventing workers from walking into forklift paths. If mechanical equipment is not required for initial unloading, establish clear working area around container entrance with adequate space for manual handling. Brief forklift operators on communication protocols, requirements to wait for worker clearance before approaching container, and procedures if workers are observed inside containers. Provide two-way radios to workers and operators or establish hand signal protocols for communication. Assign spotter personnel if available to maintain oversight of worker and equipment locations. Test communication systems confirming all parties can clearly exchange information. Document worker access to containers using sign-in procedures ensuring accountability and awareness of who is in confined spaces. Display emergency contact numbers and first aid station locations clearly visible to all personnel.

Safety considerations

Workers struck by forklifts or heavy loads suffer fatal or serious injuries. Clear separation between manual workers and operating equipment prevents these incidents. Communication systems must function reliably - test before operations commence. Never allow simultaneous forklift operation and manual work in same area without clear coordination and awareness. Spotter personnel provide additional safety oversight particularly in busy unloading operations with multiple workers and equipment.

5

Unload Cargo Using Systematic Sequence and Manual Handling Controls

Enter container wearing appropriate PPE and using proper manual handling techniques. Work systematically from top of cargo stacks to bottom, removing upper layers before lower supporting materials preventing collapse. Progress from door toward front of container maintaining clear exit path and preventing workers from being trapped behind cargo. For palletized cargo, signal for forklift access after workers exit container, maintaining exclusion zones while forklifts operate. For manually packed cargo, use team lifting for items exceeding 15 kg individual safe limits. Utilize trolleys, carts, or conveyors to move items without carrying where possible. Pass items to co-workers positioned outside container when practical reducing distance materials must be carried. Take regular rest breaks every 45-60 minutes preventing fatigue accumulation. Maintain awareness of load stability as cargo is removed, stabilizing configurations that develop lean or instability. Work in adequate lighting repositioning lights as cargo removal changes shadow patterns. Communicate continuously with team members coordinating work sequences and alerting to hazards. Rotate workers between different tasks including manual handling, checking, and equipment operation reducing continuous physical demands.

Safety considerations

Manual handling injuries from repetitive heavy lifting are most common container unloading injuries. Use mechanical aids whenever possible, team lifting for heavy items, and proper technique maintaining neutral spine position. Working top-to-bottom prevents removing support causing upper loads to collapse. Maintain clear exit path allowing rapid evacuation if load collapse or atmospheric hazard develops. Fatigue dramatically increases injury risk - mandatory rest breaks prevent exhaustion.

6

Complete Post-Unloading Inspection and Documentation

After cargo is fully removed, conduct final inspection of empty container interior checking for any spilled materials, damaged goods requiring documentation, residual cargo, or packaging debris requiring cleanup. Look for any signs of container damage, moisture ingress, or contamination that should be reported to shipping line or freight forwarder. Remove all lighting equipment, manual handling tools, and worker belongings from container ensuring nothing is left that could create hazard during container handling or return. Document cargo received including quantities, quality assessment, any damage requiring insurance claims, and completion time. Record atmospheric testing results, any hazards encountered, incidents or near-misses, and worker feedback on process improvements. Brief logistics office on completion allowing scheduling of container return. Conduct worker debrief discussing any safety concerns, improvement opportunities, or issues requiring management attention. Clean and store manual handling equipment ensuring readiness for next unloading operation. Report any equipment damage or defects requiring repair. Complete all required documentation including receiving records, quality reports, and workplace safety records for compliance purposes.

Safety considerations

Leaving materials or equipment inside containers creates hazards for subsequent handlers and may violate shipping regulations. Thorough documentation of any cargo damage protects business interests and provides feedback to suppliers about packaging adequacy. Recording safety issues and near-misses enables continuous improvement preventing future incidents. Worker debrief provides opportunity to identify hazards that may not be evident to supervisors and engages workers in safety management.

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Frequently asked questions

When is shipping container entry considered confined space work requiring specific controls?

Shipping container entry becomes confined space work when atmospheric hazards exist or are suspected, including oxygen deficiency, toxic gas presence, or flammable atmosphere. Confined space classification also applies when entry is primarily through doors at one end limiting escape routes, when purpose is to work inside rather than just reaching in from door, or when workers must enter to depths where emergency exit would be restricted. Key factors include whether atmospheric testing shows or is likely to show hazardous atmosphere, whether cargo includes fumigated materials or dangerous goods, whether container has been sealed for extended period allowing oxygen depletion, and whether workers must enter fully enclosed area rather than working from door opening. If confined space determination is made, specific controls required include atmospheric testing and monitoring, permits to work, emergency retrieval equipment, standby personnel trained in rescue, and communication systems. Not all container entry requires full confined space controls - brief access to doors-open container with confirmed safe atmosphere and clear exit path may not require extensive controls, but risk assessment must guide determination rather than assumptions.

What atmospheric hazards can develop in sealed shipping containers?

Multiple atmospheric hazards can develop in containers sealed during transport or storage. Oxygen depletion below safe 19.5% minimum occurs through rust formation on steel container walls and cargo consuming oxygen, decomposition of timber dunnage or organic materials, bacterial activity in moisture-contaminated cargo, and absorption by certain chemical products. Containers with oxygen below 16% cause unconsciousness within seconds. Toxic gas accumulation includes carbon monoxide from organic decomposition or combustion, fumigants including phosphine, methyl bromide, or formaldehyde from pest treatment, off-gassing from chemical cargo including solvents or cleaning products, and gases from battery leakage or other chemical reactions. Flammable atmospheres can develop from volatile cargo, leaked fuel or solvents, or organic decomposition producing methane. Container geometry with limited air circulation allows stratification where hazardous gases accumulate in upper or lower areas while bulk atmosphere appears normal. Temperature cycling during transport causes condensation promoting mold growth and accelerating decomposition. Hazards may develop even when cargo appears benign - oxygen depletion has occurred in containers carrying seemingly non-hazardous materials. Atmospheric testing is mandatory before entry regardless of apparent cargo safety.

How do I identify if a shipping container has been fumigated?

Fumigated containers should be identified through multiple sources. Review shipping documentation including bill of lading, packing lists, and specific fumigation certificates stating treatment date, chemical used (phosphine, methyl bromide, formaldehyde), and concentration/duration. Check for fumigation placards or warning labels affixed to container doors stating fumigation status, though these may be removed or damaged during transport. Inspect cargo for fumigation sachets, typically small packets or strips containing phosphine-generating pellets, placed inside cargo or attached to packaging. Contact freight forwarder or importer requesting fumigation status if documentation is incomplete. Certain cargo types including timber, plant materials, products from specific countries, and consolidated shipments from multiple sources have high probability of fumigation under biosecurity requirements. Absence of documentation does not confirm container is not fumigated - treatment may have occurred without proper documentation or notices may have been lost. If fumigation status cannot be definitively confirmed as not treated, treat container as potentially fumigated requiring atmospheric testing for fumigants before entry. Atmospheric testing for phosphine uses specific phosphine detector, while general multi-gas detectors may not detect fumigants. Safe approach is test all containers from international origins regardless of apparent documentation status.

What manual handling techniques reduce injury risk during container unloading?

Effective manual handling techniques during container unloading include using mechanical aids to eliminate lifting where possible - trolleys, carts, pallet jacks, conveyors, or forklifts. When manual lifting is required, maintain neutral spine position keeping natural curves rather than bending from waist, position feet shoulder-width apart providing stable base, hold load close to body reducing moment arm and back stress, and lift using leg muscles rather than back by bending knees and keeping torso upright. For items on container floor 1.2 metres above ground, step into container bringing body to load level rather than lifting from ground. Pass items to co-workers positioned outside container reducing carry distance and eliminating lifting above shoulder height. Use team lifts for items exceeding 15 kg or awkward sizes, coordinating lifts with verbal count. Avoid twisting during lifts - turn feet and body together as complete unit. Maintain power zone between mid-thigh and mid-chest levels where lifting capacity is greatest and injury risk lowest. Take frequent rest breaks preventing fatigue which dramatically increases injury risk. Vary tasks rotating between manual handling and other duties. Communicate with supervisor if loads exceed safe capacity requesting mechanical aid or additional personnel. Poor manual handling technique including back-bent lifting, twisting under load, carrying at arms length, and working while fatigued causes majority of manual handling injuries.

What emergency procedures should be in place for container unloading operations?

Comprehensive emergency procedures for container unloading must address likely emergency types. For atmospheric emergencies including worker collapse from oxygen deficiency or toxic exposure, procedures include immediate evacuation of other workers from container, not entering to attempt rescue unless wearing self-contained breathing apparatus, calling emergency services immediately, implementing emergency retrieval from outside container using ropes or rescue equipment without entry, and providing first aid once victim is extracted to safe atmosphere including CPR if required. For fumigant exposure, emergency procedures include removing victim to fresh air, flushing eyes with water for chemical contact, calling Poisons Information Centre for specific antidote advice, and transporting to hospital with fumigant chemical details. For load collapse incidents, procedures include ensuring area is safe before attempting access, stabilizing any remaining unstable cargo, methodically removing material to reach trapped workers without causing further collapse, and requesting specialized rescue resources for complex extractions. For heat-related emergencies in sealed containers, procedures include moving victim to cool environment, providing cool water if conscious, and seeking medical assessment for severe heat exhaustion. General requirements include ensuring mobile phone coverage or radio communication for emergency calls, maintaining first aid kits with adequate supplies for chemical exposure including eyewash, displaying emergency contact numbers prominently, conducting emergency drills ensuring workers know evacuation routes and muster points, and maintaining rescue equipment including breathing apparatus and retrieval systems for confined space operations. Never attempt rescue entry to containers with atmospheric hazards without proper respiratory protection - would-be rescuers frequently become secondary victims.

How can forklift operations be safely coordinated during container unloading?

Safe forklift coordination during container unloading requires clear traffic management separating equipment from manual workers. Establish physical barriers or line marking showing forklift operating zones that must remain clear of pedestrians. Implement exclusion zones requiring manual workers to exit containers and retreat behind barriers before forklifts approach. Use communication systems including two-way radios or hand signals allowing workers to call for forklift access after clearing area. Forklifts must sound horn and wait for worker acknowledgment before approaching containers. Install highly visible signs at containers showing whether manual workers are inside prohibiting forklift entry until workers exit. Provide high-visibility vests for all manual workers making them easily seen by forklift operators. Assign spotter personnel for high-volume operations maintaining awareness of both worker and forklift locations and stopping operations if safe separation is compromised. Implement sequential rather than simultaneous operations where manual workers complete section of unloading, exit and signal for forklift access, forklift removes pallets while workers remain clear, then workers re-enter for next section. Install mirrors or cameras at blind corners allowing forklift operators to see workers before encountering them. Conduct joint briefings with manual workers and forklift operators reviewing communication protocols and responsibilities. Never allow workers to walk around or under forklift raised loads. Forklift operators must verify no workers are in containers before inserting forks or extracting loads. Clear communication and enforced separation prevent struck-by incidents which are frequently fatal or cause serious injuries.

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