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Backhoe swing-radius barricades

Summary A contractors' association asked whether crane swing-radius barricade requirements applied to backhoes. A regional OSHA office said the same hazard existed where an excavating machine could also be used for lifting and applied the crane rule in that situation. A later OSHA letter noted a Review Commission limitation for some backhoes.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1977-06-13
Date issued
June 13, 1977
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. A September 9, 1977 OSHA letter later noted a Review Commission decision limiting use of the crane rule for a type of backhoe and discussed possible general-duty citations.
Status last verified October 10, 2026

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The current status of this document is unclear
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. A September 9, 1977 OSHA letter later noted a Review Commission decision limiting use of the crane rule for a type of backhoe and discussed possible general-duty citations. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

June 13, 1977

William G. Wadman
Assistant Executive Director
Associated General Contractors
of Maine, Inc.
[Recipient address omitted]
Dear Mr. Wadman:

Subject: Barricading Swing Radius of Backhoes

We offer the following comments in response to your letter of May 19, 1977, requesting interpretation of 1926.550(a)(9) of the OSHA Construction Standards as it applies to backhoes.

As 1926.550(a)(9) indicates, the purpose of a barricade around the rotating superstructure of a crane is to prevent an employee from being struck by the superstructure or crushed between the superstructure and other objects or another part of the crane. The hazard is the same when the superstructure of excavating equipment is rotated.

Granted, 1926.550(a)(9) covers only cranes. There is no similar specific standard in Section 1926.602(b). However, 1926.602(b)(2) does require that the excavating equipment conform to the nomenclature and dimensions for cranes and shovel and hoe attachments described in Society of Automotive Engineers' Standard SAE J-958. Also, 1926.602(b)(3) requires that the safety requirements contained in Power Crane and Shovel Association Standards Nos. 1, 2 and 3 shall be applied to excavating equipment.

Appendix A of PCSA Standard No. 1 contains Society of Automotive Engineers' Standard SAE J-958. Moreover, Section 3 of each of these three PCSA Standards contains the same descriptions of the basic components of the machines, including the mountings, the superstructure, and the various types of front end attachments, which may be applied to the basic machines for different purposes, including lifting and excavating.

When the same basic machines can be used for either lifting or excavating, the same safety precautions required for cranes should logically be applied to excavating equipment. Since it is common practice to provide barricades around the swing radius of the superstructure of the machine when it is used as a crane, it should be common practice to provide such a barricade when the machine is used as a shovel or backhoe. For this reason, it is OSHA policy to apply 1926.550(a)(9) to excavating equipment when the same basic machine can be used for either lifting or excavating.

Sincerely,

Gilbert J. Saulter
Regional Administrator
for Occupational Safety and Health

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