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OSHA 1915.93

Motor vehicle safety requirements

Subpart F

18 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.93(a)(1), does this motor vehicle safety standard apply to vehicles operating on public streets and highways?

No — 1915.93(a)(1) expressly says the section does not apply to motor vehicle operation on public streets and highways. The rule only applies to motor vehicles used at worksites engaged in shipyard employment to transport employees, materials, or property. If vehicles are traveling on public roads, other federal or state motor vehicle rules and traffic laws (not this shipyard provision) will usually govern.

Under 1915.93(a)(1), what motor vehicles are covered by this standard at shipyard worksites?

The standard covers any motor vehicle used to transport employees, materials, or property at worksites engaged in shipyard employment, per 1915.93(a)(1). This includes employer-provided vehicles used within the shipyard worksite (not public roads) for moving people or cargo.

Under 1915.93(a)(2), which specific requirements of 1915.93 apply to employee-provided motor vehicles?

Only the limited provisions in 1915.93(a)(2) apply to employee-provided motor vehicles: the employer must follow the requirements in 1915.93(b)(2) (seat belt use), 1915.93(b)(4) (secure seating for transported employees), and 1915.93(c)(2) (securing tools and materials before operation). Employers are not required by this section to retrofit employee vehicles with other equipment unless covered by these specific paragraphs.

Under 1915.93(a)(3), what parts of 1915.93 apply to powered industrial trucks and where do I find the rest of the powered industrial truck requirements?

Only paragraphs 1915.93(b)(1) through (b)(3) apply to powered industrial trucks, and the separate powered industrial truck standard continues to govern the rest. In other words, 1915.93 limits its requirements for powered industrial trucks to the equipment rules in 1915.93(b)(1)–(b)(3), while the maintenance, inspection, operation, and training obligations for powered industrial trucks remain in 29 CFR 1910.178.

Under 1915.93(b)(1), are employers required to provide safety belts in all employer-provided vehicles?

Yes — 1915.93(b)(1) requires employers to ensure each motor vehicle acquired or initially used after August 1, 2011 is equipped with a safety belt for each employee operating or riding in the vehicle. The standard excludes vehicles that were not equipped with safety belts at the time of manufacture, so the requirement does not apply to those older vehicles.

Under 1915.93(b)(2), must employees wear safety belts when riding in employer-provided vehicles at shipyards?

Yes — 1915.93(b)(2) requires employers to ensure that each employee uses a safety belt, securely and tightly fastened, at all times while operating or riding in a motor vehicle. Employers must make sure seat belts are available and that employees actually use them while the vehicle is in operation.

Under 1915.93(b)(3), can vehicle safety equipment be removed from employer-provided vehicles?

No — 1915.93(b)(3) requires employers to ensure that vehicle safety equipment is not removed from any employer-provided vehicle and that any removed safety equipment is replaced. Employers must maintain required safety devices so they remain in place and functional.

Under 1915.93(b)(4), what are the employer's obligations for seats when transporting employees?

Employers must provide firmly secured seats for each employee being transported and ensure all employees use those seats, according to 1915.93(b)(4). This means vehicles used to transport employees at shipyard worksites must have a seat for every passenger and employers must ensure no employees ride standing or otherwise without a secured seat during transport.

Under 1915.93(c)(1), when must an employer remove a motor vehicle from service?

An employer must remove a motor vehicle from service whenever it is not maintained in a serviceable and safe operating condition, per 1915.93(c)(1). Common examples that justify removal include defective brakes, steering failure, major tire damage, nonworking steering lights or other safety-critical failures; the key point is the vehicle must not be used until it is repaired and safe.

Under 1915.93(c)(2), what must employers do about tools and materials being transported in motor vehicles?

Employers must ensure that, before a motor vehicle is operated, any tools and materials being transported are secured if their movements may create a hazard for employees, as stated in 1915.93(c)(2). Practical steps include using tie-downs, cargo nets, bulkheads, or other restraints to prevent shifting loads that could strike or distract vehicle occupants or other workers.

Under 1915.93(c)(3), what measures can employers implement to help vehicle operators see and avoid pedestrians and bicyclists at shipyards?

Employers must implement measures to ensure operators can see and avoid pedestrians and bicyclists, per 1915.93(c)(3). The standard lists examples employers may use, including:

Employers should choose the combination of measures that fits their site hazards and traffic patterns.

Under 1915.93(c)(3)(vii), how can an employer show that an "other" measure is as effective as the listed measures at protecting pedestrians and bicyclists?

An employer can use other measures if it can demonstrate they are as effective as the listed options in 1915.93(c)(3)(i)–(vi). To show equivalence, employers should document the hazard analysis, explain why the chosen measure provides comparable protection, and keep records of implementation steps (e.g., engineering controls, signage, visibility aids, worker training, monitoring data). The documentation should show how the alternative reduces the same risks to an equivalent level.

Under 1915.93(b)(1), does the seat belt equipment requirement apply to vehicles that were manufactured without seat belts?

No — 1915.93(b)(1) specifically excludes motor vehicles that were not equipped with safety belts at the time of manufacture from the requirement to be equipped after August 1, 2011. That means employers are not required by this paragraph to retrofit older vehicles that lacked seat belts from the factory, but employers must ensure seat belt use in vehicles that are equipped and meet other applicable duties in the standard.

Under 1915.93(a)(3), do the inspection and training rules for powered industrial trucks change because of 1915.93?

No — 1915.93(a)(3) says only paragraphs (b)(1) through (b)(3) of 1915.93 apply to powered industrial trucks; the maintenance, inspection, operation, and training requirements continue to be governed by 29 CFR 1910.178. Employers must therefore follow 1910.178 for powered industrial truck training, inspection, and maintenance while also meeting the limited equipment rules in 1915.93.

Under 1915.93(c)(3)(v), when should employers provide reflective vests or visibility gear to pedestrians and bicyclists?

Employers should provide reflective vests or other visibility gear whenever pedestrian or bicyclist presence could be difficult for vehicle operators to see, as permitted by 1915.93(c)(3)(v). Practical examples include low-light conditions, busy vehicle traffic areas, locations with heavy shadows or blind spots, and during nighttime operations. The employer must ensure the gear is used and maintained so it remains effective.

Under 1915.93(c)(2), what are practical ways to secure tools and materials in vehicles to prevent hazards?

You must secure tools and materials before operating a vehicle if their movement may create a hazard, per 1915.93(c)(2). Practical methods include:

  • Using tie-down straps, ratchet straps, or cargo nets for loose items.
  • Installing bulkheads, partitions, or racks to separate cargo from occupants.
  • Stowing small tools in locked toolboxes or compartments.
  • Blocking or chocking wheeled equipment and palletized loads.

Choose the method that prevents shifting under expected travel conditions and periodically inspect restraints for wear.

Under 1915.93, does the standard require employers to set speed limits inside shipyards, and if so, what guidance does it give?

Yes — 1915.93(c)(3)(iii) lists establishing appropriate speed limits as one measure employers may implement to protect pedestrians and bicyclists. The standard does not set a numeric speed; instead, employers should set limits appropriate to their site layout, traffic density, visibility, and types of vehicles, post and enforce the limits, and combine them with other controls (separation, signs, and training) to reduce risk.

Under 1915.93, does the standard mandate training for drivers of employer-provided motor vehicles (other than powered industrial trucks)?

No specific driver training requirement for general employer-provided motor vehicles is stated in 1915.93, but training and operation rules continue to apply for powered industrial trucks under 29 CFR 1910.178, as noted in 1915.93(a)(3). Employers should still train employees as needed to operate site vehicles safely and to follow the measures in 1915.93(c)(3) (e.g., speed limits, pedestrian awareness), even though 1915.93 does not spell out a formal training program for every motor vehicle type.