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Roll-over protection for trenchers and snow vehicles

Summary A trade group asked whether trenchers and snow vehicles needed roll-over protective structures. OSHA said its standards did not require them on snow vehicles, but did require them on wheeled trenchers. For track-laying trenchers, OSHA said the answer depended on where the operator sat relative to the tracks and digging mechanism.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1974-01-21
Date issued
January 21, 1974
Status
Active
OSHA marks its online letter corrected on March 20, 2009.
Status last verified October 10, 2026

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January 21, 1974
Mr. John P. Markey
Coordinator of OSHA Activities
Industrial Relations Division
Edison Electric Institute
[Recipient address omitted]
Dear Mr. Markey:
This response is to your letter of November 26, 1973, in which you inquired whether it is necessary to install Roll-over Protective Systems (ROPS) on trenchers and snow vehicles. Please accept my apology for a delayed response.
It is not necessary to install ROPS on snow vehicles. There presently are no OSHA standards requiring such installation. However, research work is presently underway by some testing and research institutes regarding the merits of installing ROPS on snow vehicles.
If a trencher is of the wheeled variety, ROPS are required, irrespective of the fact that the trencher is equipped with an attachment (e.g., dozer blade, backhoe) or is used only to dig a trench.
If the trencher is of the track-laying variety and the operator sits between or in the middle of the tracks or frame, ROPS are required by applicable OSHA standards. If the track-laying trencher is of the variety on which the operator does not sit in the middle of the tracks or frame, but sits off to one side of the machine and the mechanism for digging the trench is located between the tracks or frame, ROPS are not required.
For your additional information, the Construction Advisory Committee is scheduled to meet on January 24, 1974, to discuss the proposed incorporation into OSHA standards of the updated portions of several standards of the Society of Automotive Engineers. This meeting will be concerned with the following:

Standard Date Title
SAE J-237a 11/79 Minimum Performance Criteria for Brake Systems for Off-Highway, Rubber Tired, Front End Loaders and Dozer
SAE J-320b 9/72 Minimum Performance Criteria for Roll Over Protective Structures for Prime Movers
SAE J-386a 3/68 Seat Belts for Construction Equipment
SAE J-1026 7/73 Crawler Tractor Brakes

It is suggested that you contact [the Directorate of Construction], for any future updating regarding this or any other area of interest within the OSHA construction standards.
I sincerely hope that I have effectively answered your questions. If I may be of further assistance to you and the Institute, please feel free to contact this office.
Sincerely,
Donald A. Shay, Director
Office of Programs Development
[Corrected 3/20/2009]

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