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.

April 6, 1976

Mr. Darrell E. Wolbers,
Statutory Regulations
J I Case
700 State Street
Racine, Wisconsin 53404

Dear Mr. Wolbers:

This is in response to your letter of February 26, 1976, addressed to Mr. Fred Stockmeir, or our Chicago Regional Office, regarding Rollover Protection Structures (ROPS) on skid-steer loaders used in agricultural operations. In addition, it confirms a telephone conversation with a member of my staff.

Your specific question is: Do skid-steer loaders when used in agricultural operations have to conform to 29 CFR 1928.51(b)(1) which requires ROPS on each tractor operated by an employee?

The answer is no. The negative answer is in agreement with Construction standard 29 CFR 1926.1000(a)(2) [incorporated by reference in 29 CFR 1928.51(b)(1)]. This construction standard 29 CFR 1926.1000(a)(2) reads:

The promulgation of specific standards for rollover protective structures for compactors and rubber-tired skid-steer equipment is reserved pending consideration of standards currently being developed.

A Program Directive covering this subject will be issued in the near future.

If I may be of any further assistance, please feel free to contact me.


John K. Barto, Chief
Division of Occupational Safety Programming