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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

January 28, 2011

Olivier Bony, Technical Manager
Techni-Metal Systeme
Z.A. de Fiancey
26250 Livron France

Re: OSHA construction standards applicable to specialized vehicles for hauling concrete sections in tunnel construction.

Dear Mr. Bony:

This is in response to your e-mail message dated January 23, 2007 to Mr. Robert Carroll in the Pittsburgh area office of the Occupational Safety and Health Administration (OSHA).  You requested assistance in determining applicable U.S. regulations for tunnel construction vehicles.  Your message was forwarded to this office.  We apologize for the long delay in responding.

We have paraphrased your question as follows:

Question:  We manufacture in France a specialized vehicle used to carry concrete segments to Tunnel Boring Machines during the tunnel construction process.  These vehicles are used only for off-highway construction sites.  Are there any federal OSHA construction standards that set criteria that such vehicles have to meet, including electrical standards?

Answer: Federal OSHA construction standards applicable to the type of hauling construction vehicle you describe may be found in the Code of Federal Regulations (CFR) at 29 CFR Subpart O - Motor Vehicles, Mechanized Equipment, and Marine Operations.   Based on the pictures you sent, and your description of your particular vehicle, it appears that the vehicle has no lifting function.  Accordingly, the vehicle would be governed by 29 CFR §1926.601, Motor Vehicles.  Guidance can also be found in the standards established by the American National Standards Institute (ANSI) B56.1-1969, Safety Standards for Powered Industrial Trucks.

If you need any further clarification on this subject, please contact us by fax at:  U.S. Department of Labor, Directorate of Construction Office of Construction Standards and Guidance. (Fax number: 202-693-1689). You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.


James G. Maddux, Director
Directorate of Construction