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 http://www.osha.gov.
July 22, 1991
Mr. James Arndt
Products Safety Engineer
Deere & Company
Moline, Illinois 61265
Dear Mr. Arndt:
This is in regard to information compiled in the State of Alaska concerning an employee who was injured while operating a John Deere bulldozer. This also confirms telephone conversations between you and Mr. Simms, a member of my staff.
It has recently been brought to our attention by the State of Alaska that a number of employees were either involved in or witnesses to incidents of employee injury caused by John Deere bulldozers. It appears the injuries occur when the operator is driving the bulldozer. The backhoe seat shears its safety pin, causing the seat to fall backwards onto the operator's neck and shoulders.
We are concerned of a possible design defect of the John Deere Model 350 and 450 bulldozers, because of the many similar incidents that have occurred just within the State of Alaska. Any information you can provide to this office concerning this matter will be appreciated.
John K. Barto
Chief, Division of Occupational Safety Programming