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.

October 22, 1981

Mr. William E. Lawler
Specifications Manager
Indian Mills & Manufacturing, Inc.
120 West Main Street
Carmel, Indiana 46032

Dear Mr. Lawler:

Thank you for your letter of October 5, 1981, requesting a clarification of 29 CFR 1928.51, Roll-over Protective Structures (ROPS) for tractors used in agricultural operations.

It was not the intent of 29 CFR 1928.51(b)(2)(ii)(B) to make the seat belt load requirement equal to the seat belt anchorage load requirement as mentioned in your letter. 29 CFR 1928.51(b)(2)(ii) requires each seat belt to meet the requirements set forth in Society of Automotive Engineers Standard SAE J4C, 1965 Motor Vehicle Seat Belt Assemblies, except as noted in Subparagraphs A, B and C.

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


Bruce Hillenbrand
Deputy Director,
Federal Compliance and State Programs