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OSHA 1926.1001

Rollover protective structures criteria

Subpart W

15 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.1001(a), which types of construction machines are covered by the rollover protective structures (ROPS) minimum performance criteria?

The ROPS minimum performance criteria apply to the machines listed in 1926.1001(a): rubber-tired self-propelled scrapers; rubber-tired front end loaders and rubber-tired dozers; crawler tractors and crawler-type loaders; motor graders; compactors; and rubber-tired skid steer equipment. See 1926.1001(a) for the official list.

Under 1926.1001(c), what ROPS standard must equipment manufactured on or after July 15, 2019 meet?

Equipment listed in 1926.1001(a) that was manufactured on or after July 15, 2019 must meet the test and performance requirements of ISO 3471:2008. See 1926.1001(c) which incorporates ISO 3471:2008 as the applicable standard for equipment manufactured on or after that date.

Under 1926.1001(b), what options exist for protective frames on equipment manufactured before July 15, 2019?

For equipment listed in 1926.1001(a) and manufactured before July 15, 2019 (excluding compactors and rubber-tired skid steer equipment), the protective frames must either conform to the applicable Society of Automotive Engineers (SAE) Recommended Practices listed in 1926.1001(b) or comply with the consensus standard ISO 3471:2008. See 1926.1001(b) and the incorporated references in 1926.6.

Under 1926.1001(b), which SAE documents correspond to which equipment categories for machines manufactured before July 15, 2019?

The SAE Recommended Practices in 1926.1001(b) map to equipment as follows: SAE J320a for rubber-tired, self-propelled scrapers; SAE J394 for rubber-tired front end loaders and rubber-tired dozers; SAE J395 for crawler tractors and crawler-type loaders; SAE J396 for motor graders; and SAE J397 for critical zone characteristics and operator dimensions, as applicable. See 1926.1001(b) for the complete list and 1926.6 for incorporated references.

Does 1926.1001 require compactors and rubber-tired skid steer equipment manufactured on or after July 15, 2019 to meet ISO 3471:2008?

Yes. 1926.1001(c) applies to the equipment listed in 1926.1001(a) manufactured on or after July 15, 2019, which includes compactors and rubber-tired skid steer equipment, and requires the protective frames to meet ISO 3471:2008. See 1926.1001(c).

Under 1926.1001(b), what does the parenthetical phrase "excluding compactors and rubber-tired skid steer equipment" mean for equipment manufactured before July 15, 2019?

The phrase means that the list of SAE Recommended Practices in 1926.1001(b) is specified for the equipment named there except that compactors and rubber-tired skid steer equipment are not covered by that particular set of SAE documents for machines manufactured before July 15, 2019. Review 1926.1001(b) and consider the applicability of 1926.1001(c) (which governs machines manufactured on or after July 15, 2019) when determining which standard to follow.

Under 1926.1001, if a protective frame meets ISO 3471:2008, does it satisfy OSHA's ROPS performance criteria?

Yes. Compliance with ISO 3471:2008 satisfies the ROPS performance criteria in 1926.1001 for equipment manufactured on or after July 15, 2019, and is also listed as an alternative for certain equipment manufactured before that date. See 1926.1001(c) and 1926.1001(b).

Where can I find the official list of standards that 1926.1001 incorporates by reference?

The official incorporation-by-reference information for OSHA construction standards is provided in 1926.6, which explains which external standards (like SAE or ISO) are incorporated into Part 1926 and how to obtain them. See 1926.6 for details.

Under 1926.1001, are the performance criteria limited only to the protective frame, or do they apply to complete ROPS assemblies?

1926.1001 prescribes minimum performance criteria for rollover protective structures (ROPS) and refers to the protective frames and their performance; it sets the performance requirements that the protective frames (the structural part of an ROPS) must meet. See the general scope in 1926.1001(a) and the detailed equipment-specific references in 1926.1001(b) and 1926.1001(c).

Under 1926.1001, if I have an older machine (manufactured before July 15, 2019) that already has a certified SAE-compliant ROPS, is that acceptable?

Yes; for machines covered by 1926.1001(b) (the equipment listed in 1926.1001(a) excluding compactors and rubber-tired skid steer equipment) manufactured before July 15, 2019, protective frames that conform to the applicable SAE Recommended Practices meet the rule's minimum performance criteria. See 1926.1001(b).

Under 1926.1001, what date is the regulatory cutoff that determines whether SAE standards or ISO 3471:2008 apply?

The regulatory cutoff date is July 15, 2019: equipment manufactured on or after that date must meet ISO 3471:2008 under 1926.1001(c), while the SAE Recommended Practices listed in 1926.1001(b) apply to certain equipment manufactured before that date.

Under 1926.1001, if my machine was manufactured before July 15, 2019 but does not fall under the SAE-listed categories (for example, a compactors or rubber-tired skid steer), what does the standard say?

1926.1001(b) explicitly excludes compactors and rubber-tired skid steer equipment from the SAE-listed requirements for machines manufactured before July 15, 2019; the regulation does not prescribe those particular SAE documents for those excluded machines. See 1926.1001(b). For machines manufactured on or after July 15, 2019, however, 1926.1001(c) requires ISO 3471:2008, which does cover the equipment listed in 1926.1001(a).

Under Part 1926 generally, where does 1926.1001 sit and who enforces these ROPS requirements?

1926.1001 is in Part 1926 (Safety and Health Regulations for Construction), Subpart W (Rollover Protective Structures; Overhead Protection), and OSHA enforces these construction safety regulations. For the regulation text and its placement in the construction standards, see Part 1926 and 1926.1001.

Under 1926.1001, can an employer comply by using either the SAE documents or ISO 3471:2008 for older equipment?

For equipment listed in 1926.1001(a) and manufactured before July 15, 2019 (excluding compactors and rubber-tired skid steer equipment), the employer may meet the standard by using the applicable SAE Recommended Practices or by complying with ISO 3471:2008; 1926.1001(b) expressly provides those alternatives. See 1926.1001(b) and the ISO requirement in 1926.1001(c).

Under 1926.1001, where can I read the official title and scope of the ROPS performance-criteria standard?

The official title and scope for 1926.1001 are published in the regulation header: "Minimum performance criteria for rollover protective structures for designated scrapers, loaders, dozers, graders, crawler tractors, compactors, and rubber-tired skid steer equipment." You can read this in the standard page for 1926.1001 and view Part 1926 at https://www.osha.gov/laws-regs/regulations/standardnumber/1926.