Comparable ISO standards appendix

Yes — Under 1910.266(Appendix C) an employer may use ISO 3471-1 in lieu of SAE J1040 when the ISO standard is applied correctly and the resulting ROPS meets the OSHA performance requirements. Appendix C says the listed ISO standards are comparable to the referenced SAE standards and that "Utilization of the ISO standards in lieu of the corresponding SAE standards should result in a machine that meets the OSHA standard." See 1910.266AppC and the related employer duties in 1910.266.

The list in 1910.266(Appendix C) is non‑mandatory and provided as an optional method for meeting the OSHA requirements. Appendix C is titled "Comparable ISO Standards (Non-mandatory)", meaning employers may choose to follow the listed ISO standards in place of the SAE standards, but OSHA enforces the performance and safety requirements of 1910.266, not the Appendix itself. See 1910.266AppC.

ISO 3449 is listed in 1910.266(Appendix C) as the comparable standard to SAE J231 for falling object protective structures (FOPS). Appendix C shows the direct equivalency: "SAE J231 | ISO 3449 | Minimum Performance Criteria for Falling Object Protective Structures (FOPS)." See 1910.266AppC and the general machine safety requirements in 1910.266.

Yes — Machines certified to ISO 6683 for operator restraint systems may be used to meet OSHA requirements, provided the ISO design and installation achieve the safety performance required by [1910.266]. Appendix C explicitly lists "ISO 6683 | Operator Restraint Systems for Off-Road Work Machines" as comparable to SAE J386 and notes that use of the ISO standard "should result in a machine that meets the OSHA standard." See 1910.266AppC and 1910.266 for employer obligations to provide safe machine configurations.

You should document the choice and the basis showing the ISO standard produces an equivalent level of protection and that the machine meets the OSHA performance requirements. Appendix C allows ISO standards as comparable alternatives, so employers should keep records showing which ISO standard was used (e.g., ISO 3471‑1), the machine model or modification details, test reports or certificates, and any manufacturer declarations demonstrating the machine meets [1910.266] performance expectations. See 1910.266AppC and 1910.266 for required machine safety duties.

No — Using an ISO standard does not relieve the employer of inspection and maintenance duties; the employer must still ensure equipment remains safe and compliant with [1910.266]. Appendix C only addresses comparable design standards (ISO vs. SAE); it does not change ongoing inspection, maintenance, or training obligations required by 1910.266. See 1910.266AppC for the comparability guidance and 1910.266 for operational requirements.

If the ISO standard does not address a feature covered by the SAE standard, the employer must ensure the machine still meets the safety performance required by [1910.266], either by applying the SAE requirement, an appropriate alternative that provides equivalent protection, or by consulting the manufacturer and retaining documentation. Appendix C offers comparable ISO standards "should" produce machines that meet OSHA requirements, but where gaps exist the employer must bridge them to satisfy 1910.266. See 1910.266AppC and 1910.266.

Yes — ISO standards listed in Appendix C can be used for retrofits provided the retrofit design and installation meet the OSHA performance objectives in [1910.266]. Appendix C indicates the listed ISO standards are comparable to the SAE standards and "should result in a machine that meets the OSHA standard," but employers must verify the retrofit achieves equivalent protection for the specific machine and document testing or engineering evaluations. See 1910.266AppC and 1910.266 for requirements on machine modifications.

No — Appendix C is non‑mandatory informational guidance and does not create new legal obligations or change the enforceable requirements of [1910.266]. Appendix C simply lists ISO standards comparable to referenced SAE standards and notes that using them "should result in a machine that meets the OSHA standard." Employers remain responsible for meeting the performance and safety obligations in 1910.266. See 1910.266AppC and 1910.266.

ISO 2897 is listed as the comparable standard to SAE J185 for access systems on off‑road machines in Appendix C. Appendix C shows the equivalency: "SAE J185 | ISO 2897 | Access Systems for Off-Road Machines." See 1910.266AppC and review 1910.266 for employer responsibilities regarding safe access.

Employers should ask for documented evidence such as manufacturer test reports, conformity certificates, engineering drawings, or third‑party test results showing the machine or component was designed and tested to the cited ISO standard and that performance meets OSHA requirements in [1910.266]. Appendix C indicates the ISO standards are comparable alternatives, but employers must verify the actual machine meets the OSHA safety performance expectations. Keep records of the documentation and any assessments. See 1910.266AppC and 1910.266.

Yes — an employer can rely on a credible foreign test lab certificate if it demonstrates testing to the appropriate ISO standard listed in Appendix C and the certificate, testing methods, and results show the machine meets the performance levels required by [1910.266]. Appendix C lists ISO standards as comparable alternatives; the key is that the testing and certification actually demonstrate compliance with OSHA's safety performance requirements. Retain the certificate and underlying test data for your compliance records. See 1910.266AppC and 1910.266.

If no comparable ISO standard exists, the employer must follow the referenced SAE standard or otherwise ensure the machine meets the OSHA performance requirements in [1910.266] by using an equivalent, documented method. Appendix C only lists ISO standards where comparability has been identified; absent a listed ISO alternative, compliance depends on meeting the SAE specification or demonstrating an equivalent level of protection with testing and documentation. See 1910.266AppC and 1910.266.

No — Using an ISO standard does not change the OSHA labeling, warning, or operator instruction requirements; employers and manufacturers must still provide the warnings, instructions, and training required by [1910.266]. Appendix C addresses comparable technical design standards but does not alter the operational, warning, or training provisions enforced under 1910.266. See 1910.266AppC for the comparability guidance.