April 23, 1979
| MEMORANDUM FOR: |
RONALD MCCANN Acting Regional Administrator
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| ATTENTION: |
KENNETH BOWMAN Area Director - Aurora
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| THRU: |
DONALD E. MACKENZIE Field Coordinator
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| FROM: |
GROVER C. WRENN Director Federal Compliance and State Programs
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| SUBJECT: |
Proper Citing of Rubber-Tired Skid-Steer Machines Not Equipped with Rollover Protective Structures (ROPS) |
The promulgation of specific OSHA standards for rollover protective
structures for rubber-tired skid-steer equipment was reserved in 1972 pending
consideration of standards being developed by the Society of Automotive
Engineers, Inc. However, since that time the requirement of rollover
protective structures for rubber-tired skid-steer machines is recommended in
the Performance Criteria for Rollover Protective Structures (ROPS) for
Construction, Earthmoving, Forestry and Mining Machines, (SAE) J1040b,
published as a preprint in 1977 by SAE.
The use of skid-steer machines without ROPS where ROPS are necessary for the
protection of operators is a recognized hazard that is causing and is likely
to cause death or serious physical harm to employees operating the equipment.
Therefore, utilizing four-wheel dirve, skid-steer front-end loaders of mass
greater than 1540 lbs., under the above conditions, shall be cited under
Section 5(a)(1) of the Act using SAE J1040b to support the recognized hazard.
Enclosure
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