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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

December 6, 1988

Mr. Richard B. Jacobsen
Assistant Manager of Safety
UE&C Catalytic, Inc.
30 South 17th Street
Philadelphia, Pennsylvania 19101

Dear Mr. Jacobsen:

This is in response to your letter of October 7, 1988, concerning interpretation of 29 CFR 1926.601(b)(8) and (9).

Construction Standards 1926.600 thru 604 address motor vehicles, motorized equipment and marine operations. Section 601 specifically covers vehicles that operate within an off-highway jobsite, not open to public traffic, and provides a list of general requirements (601(b)(1-14)).

This list of requirements is not in any priority sequence and are independent of each other. Therefore, the anchorage requirement for seat belts is not dependent on the requirement to provide an adequate number of firmly attached seats for occupants being transported.

After extensive research and several discussions with DOT representatives, the meaning of 601(b)(9) was to provide a reference for factory installed seat belts and or those provided during vehicles modification. Furthermore, DOT requirements and test data were developed for forward facing seats within the confines of a vehicle housing. Side facing seats, as described in your letter were not included in this requirement. Therefore, beat belts for occupants of side facing seats in the rear of an open bodied vehicle are not required.

If you have any additional questions or need further information, please contact Gerald Reidy at 523-8136.


Thomas J. Shepich, Director
Directorate of Compliance Programs