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Skid-steer loaders without rollover protection

Summary An OSHA memorandum addressed rubber-tired skid-steer loaders without rollover protective structures. It directed staff to cite the general duty clause for specified heavier four-wheel-drive machines when protection was needed, using an SAE criterion as evidence. OSHA archives the memorandum and warns it may no longer state current policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1979-04-19
Date issued
April 23, 1979
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1926 Construction Equipment Rollover Protection
Source
View the official document

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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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. 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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 23, 1979

MEMORANDUM FOR: RONALD MCCANN
Acting Regional Administrator

ATTENTION: KENNETH BOWMAN Area Director - Aurora

THRU: DONALD E. MACKENZIE Field Coordinator

FROM: GROVER C. WRENN Director
Federal Compliance and State Programs

SUBJECT: Proper Citing of Rubber-Tired Skid-Steer Machines Not Equipped with Rollover Protective Structures (ROPS)

The promulgation of specific OSHA standards for rollover protective structures for rubber-tired skid-steer equipment was reserved in 1972 pending consideration of standards being developed by the Society of Automotive Engineers, Inc. However, since that time the requirement of rollover protective structures for rubber-tired skid-steer machines is recommended in the Performance Criteria for Rollover Protective Structures (ROPS) for Construction, Earthmoving, Forestry and Mining Machines, (SAE) J1040b, published as a preprint in 1977 by SAE.
The use of skid-steer machines without ROPS where ROPS are necessary for the protection of operators is a recognized hazard that is causing and is likely to cause death or serious physical harm to employees operating the equipment. Therefore, utilizing four-wheel drive, skid-steer front-end loaders of mass greater than 1540 lbs., under the above conditions, shall be cited under Section 5(a)(1) of the Act using SAE J1040b to support the recognized hazard.
Enclosure

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