Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

July 16, 1975

Mr. Leonard A. Frescoln
Secretary, Local 14700
United Steel Workers of American
Apt. E-2, Driftwood Club Apts.
125 Greenbank Road
Wilmington, Delaware

Dear Mr. Frescoln:

This is in response to your letter dated July 9, 1975 to our Wilmington Office concerning training requirements.

A front end loader is a vehicle intended primarily for earth moving and therefore is not within the scope of section 1910.178 "Powered Industrial Trucks" of the OSHA standards. The fact that it is not being used for earth moving does not make it a powered industrial truck. However, section 5(a)(1) of the Occupational Safety and Health Act of 1970 could apply if employer use of such equipment creates a recognized hazard that is causing or is likely to cause death or serious physical harm to his employees.

Your interest in occupational safety and health is appreciated.

Sincerely yours,




Assistant Regional Director for
Occupational Safety and Health