I also don’t have a generator, and find that shelf to be highly useful storage space. My use of it varies a lot, based on what kind of boating I’m doing.
On longer cruises, I have used the shelf to store watertight boxes with spare parts and odd-ball tools, plus containers with extra rope and lines, an extra fender, etc. The containers were packed in reasonably well and I did not secure them. None of them moved around much if at all, even after some choppy cruising.
For day trips and shorter weekend excursions, I sometimes leave an extra fender down there, and maybe a small container of spare parts. At those times, things are not packed in tightly and there is room for them to move about. But they have always seemed to stay put.
For short day trips, often the shelf is mostly empty. All that is on it is what I always keep there — the things I use to check fluids before every outing. That amounts to nothing other than some quartered blue paper towels for checking engine and transmission oil, an oil absorbent pad or two, and a small wastebasket to throw the blue paper towels into after checking fluids. Those things are all super light, but they never move much. Now that I think about it, I’m not sure they ever move at all. The ultra-light waste basket is always to the far port side of the shelf when I leave as well as when I return.
All of that is to say that, in my experience, that area does not seem subject to much tossing and movement. Maybe that’s because it is the most heavily ballasted part of the boat. Everything rides well without much effort on my part to make that happen, So in my experience, putting things there hasn’t proven risky. But I do think through what I put there because it is a distinct “environment” (the air there is a mix of damp from the bilge but warm from the engine). So parts, etc, go into watertight containers. But other than that, using it for storage hasn’t required a lot of extra precautions.
Gini