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 25, 1991

Mr. Page L. Bellinger
Product Safety Engineering Standards
Deere & Company
John Deere Road
Moline, Illinois 61265-8098

Dear Mr. Bellinger:

Thank you for your letters and technical information concerning the need for the Occupational Safety and Health Administration (OSHA) to evaluate the technical differences between the various standards for Rollover Protective Structures (ROPS) used on agricultural wheeled tractors.

Your primary concern is directed towards OSHA acceptance of the present industry standards published by the Society of Automotive Engineers (SAE) standard, SAE J2194, and the American Society of Agricultural Engineers (ASAE) standard, ASAE S519. You indicate that these standards, when compared to the OSHA requirements, provide for equivalent or superior operator protection. Further, you expressed this concern due to the present compatibility between the International Standards Organization (ISO) standards, ISO 3463 and 5700 and these new industry standards.

The OSHA standard at 29 CFR 1928.51(b)(1), of Subpart C, specifies that ROPS for agricultural wheeled tractors comply with the requirements of 1928.52 or 1928.53. (This standard was adopted from SAE J168-1970.) Alternatively, compliance with the requirements of the OSHA construction standard, 29 CFR 1926.1002, is permitted.

The standard at 29 CFR 1926.1002(a)(5) specifies that ROPS shall comply with SAE J168 (July 1970). The standard, 29 CFR 1926.1002(j)(1), defines agricultural tractor as, "a wheel-type vehicle of more than 20 engine horsepower designed to furnish the power to pull, carry, propel, or drive implements that are designed for agricultural usage." That definition was adopted from SAE J333a. In 1977, SAE J168a, SAE J333b and SAE J334b were replaced by SAE J1194 which incorporated the information contained formerly in those separate standards.

Since the promulgation of SAE J1194 in mid-1977, OSHA has accepted compliance with the SAE J1194 standard as equivalent to the requirements specified at 29 CFR 1928.51(b)(1) and 29 CFR 1926.1002(a)(5).

The advent of the current SAE J2194 and ASAE S519, has required an evaluation of the new standards by OSHA to assure that the requirements for agricultural wheeled tractor ROPS continue to be acceptable. Through the outstanding cooperation of the SAE committee and its member companies, OSHA has been able to assess the impact of the current standard on the workplace safety and health of farm workers. The assessment has shown that the current ROPS structures specified by SAE J2194 and ASAE S519 provide superior safeguarding of exposed workers compared to the previous requirements of the SAE or the OSHA standards.

The test results and supporting data reflecting the required ROPS modifications, provided by three principal manufacturers of tractors in the United States, were most convincing. In every case, the tractor ROPS which could withstand the qualifying tests for OSHA/SAE J1194 approval failed when tested against the new requirements. Also, in every case, the solution for acceptance under the new standards required that the rear-most structural portion of the ROPS be strengthened significantly.

It has been determined that ROPS which meet the requirements of ANSI/SAE J2194 or ASAE S519 are superior to the existing OSHA requirements for this type of equipment and therefore are functionally equivalent to the OSHA requirements. This interpretation will provide for uniform and effective enforcement of the OSHA requirements until such time when the related OSHA standards can be modified to recognize these new consensus standards.


Gerard F. Scannell
Assistant Secretary

[Corrected 05/28/2004]