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Construction vehicle rules for end dump trucks

Summary A consultant asked whether end dump trucks traveling between jobsites must comply with construction vehicle rules once they enter an off-highway site. OSHA said they do, while conflicting Department of Transportation rules take precedence on public highways. It also described acceptable manufacturer-designed devices to prevent accidental dump-hoist operation.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-10-01-2
Date issued
October 1, 1991
Status
Active
OSHA marks the posted letter corrected August 16, 2007.
Status last verified October 9, 2026

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October 1, 1991
Mr. Riley H. Mayhall, Jr.
M & M Consulting
[Recipient address omitted]

Dear Mr. Mayhall:
This is in response to your July 3, 1991, request for clarification of whether the Occupational Safety and Health Administration's (OSHA) regulations addressing motor vehicles apply to end dump trucks operating on jobsites and on public highways between jobsites. We apologize for the delay in responding to your inquiry.
Please be advised that all end dump trucks operating between jobsites on the public highways must comply with all the provisions of 29 CFR 1926.601 when the trucks enter off-highway jobsites. However, if there is a conflict between these regulations and those of the U.S. Department of Transportation (DOT), then the DOT regulations have precedence while the trucks are operating on the public highways.
With respect to your question concerning the meaning of the term "other devices" used in 29 CFR 1926.601(b)(11), please be advised that it means any system specifically designed by the manufacturer to prevent accidental tripping or operating of the haulage body hoist or dump mechanism. Such a system may consist of a hydraulic interlock, an electric interlock, or a spring activated lever lock.
If we can be of any further assistance, please contact [by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 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.]
Patricia K. Clark, Director
Directorate of Compliance Programs
[Corrected 08/16/2007]

[The requester’s July 3 letter reproduced on the OSHA page is omitted here.]

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