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.

September 12, 1980

Mr. Larry D. Schmitt
Lead Engineer
ATI--Advance Technology, Inc.
1762 North St. Francis
P. O. Box 8177
Wichita, Kansas 67208

Dear Mr. Schmitt:

This is in response to your letter requesting information concerning protective structures.

Falling object protective structures do not need to be supported by a 4-post structure. The requirement for falling object protective structures depends on the application of tractors. 29 CFR 1926.604 requires rider-operated equipment to be equipped with an overhead and rear canopy guards for site clearing. 29 CFR 1910.266 requires a protective canopy to be provided for the operator of mobile equipment in pulpwood logging operations. The horsepower of equipment is not considered for falling object protective structure standards.

If the operator of an attachment, such as a back-hoe, is located in a position of operation other than the tractor operation seat, there is no criteria for protective structure placement. However, if a falling object hazard exists, an employer is required to eliminate the hazard.

SAE J 1043 may be used, in lieu of 29 CFR 1926.1003, if the protection provided is superior to the requirements for tractors covered by that section. SAE J 231 can be used as criteria for falling object protection attached to ROPS equipment covered by 29 CFR 1926.604, and 1926.1000 and 1001, which apply to all dozer and loader machines. Currently, the ROPS criteria is recognized as the criteria for the support structures when falling object protection is also required.

If we may be of further assistance, please feel free to call or write.


John K. Barto Chief,
Division of Occupational Safety Programming