OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.


January 21, 1974

Mr. John P. Markey
Coordinator of OSHA Activities
Industrial Relations Division
Edison Electric Institute
98 Park Avenue
New York, New York 10016

Dear Mr. Markey:

This response is to your letter of November 26, 1973, in which you inquired whether it is necessary to install Roll-over Protective Systems (ROPS) on trenchers and snow vehicles. Please accept my apology for a delayed response.

It is not necessary to install ROPS on snow vehicles. There presently are no OSHA standards requiring such installation. However, research work is presently underway by some testing and research institutes regarding the merits of installing ROPS on snow vehicles.

If a trencher is of the wheeled variety, ROPS are required, irrespective of the fact that the trencher is equipped with an attachment (e.g., dozer blade, backhoe) or is used only to dig a trench.

If the trencher is of the track-laying variety and the operator sits between or in the middle of the tracks or frame, ROPS are required by applicable OSHA standards. If the track-laying trencher is of the variety on which the operator does not sit in the middle of the tracks or frame, but sits off to one side of the machine and the mechanism for digging the trench is located between the tracks or frame, ROPS are not required.

For your additional information, the Construction Advisory Committee is scheduled to meet on January 24, 1974, to discuss the proposed incorporation into OSHA standards of the updated portions of several standards of the Society of Automotive Engineers. This meeting will be concerned with the following:




Standard Date Title
SAE J-237a 11/79 Minimum Performance Criteria for Brake Systems for Off-Highway, Rubber Tired, Front End Loaders and Dozer
SAE J-320b 9/72 Minimum Performance Criteria for Roll Over Protective Structures for Prime Movers
SAE J-386a 3/68 Seat Belts for Construction Equipment
SAE J-1026 7/73 Crawler Tractor Brakes


It is suggested that you contact [the Directorate of Construction], for any future updating regarding this or any other area of interest within the OSHA construction standards.

I sincerely hope that I have effectively answered your questions. If I may be of further assistance to you and the Institute, please feel free to contact this office.


Donald A. Shay, Director
Office of Programs Development

[Corrected 3/20/2009]