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OSHA 1926.1002

ROPS for construction tractors

Subpart W

19 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.1002(a), which tractors does this ROPS requirement cover?

This section covers wheel-type agricultural and industrial tractors used in construction work that have more than 20 engine horsepower. See 1926.1002(a) and the definitions in 1926.1002(e).

Under 1926.1002(b), what ROPS standards apply to equipment manufactured before July 15, 2019?

Protective frames on equipment manufactured before July 15, 2019 must meet the test and performance requirements of SAE Standard J334a and J168, or comply with the consensus ISO standard ISO 5700:2013. See 1926.1002(b) and the incorporation rules at 1926.6.

Under 1926.1002(c), what ROPS standards apply to equipment manufactured on or after July 15, 2019?

Protective frames on equipment manufactured on or after July 15, 2019 must meet the test and performance requirements of ISO 5700:2013 or ISO 3471:2008. See 1926.1002(c).

Under 1926.1002(e)(1), how does OSHA define "agricultural tractor" for construction use?

An "agricultural tractor" for this subpart means a wheel-type vehicle of more than 20 engine horsepower used in construction work that is designed to furnish the power to pull, propel, or drive implements. See 1926.1002(e)(1).

Under 1926.1002(e)(2), how does OSHA define "industrial tractor"?

An "industrial tractor" is a wheel-type tractor of more than 20 engine horsepower (other than the rubber-tired loaders and dozers described in 29 CFR 1926.1001) used in operations such as landscaping, construction services, loading, digging, grounds keeping, and highway maintenance. See 1926.1002(e)(2).

Under 1926.1002(d), where do I find overhead protection requirements for these tractors?

Overhead protection requirements for wheel-type agricultural and industrial tractors used in construction are found in 1926.1003, not in 1926.1002(d) alone. See 1926.1002(d).

Under 1926.1002, do the ROPS rules apply to rubber-tired loaders and dozers?

No. The definition of "industrial tractor" in 1926.1002(e)(2) explicitly excludes rubber-tired loaders and dozers described in 1926.1001.

Under 1926.1002, what must protective frames do if they do not meet the listed consensus standards?

Protective frames must meet the test and performance requirements of the applicable standards listed in the rule (SAE J334a/J168 for pre‑2019 or ISO 5700/ISO 3471 as applicable) to be compliant; otherwise they do not satisfy the requirements of 1926.1002. See 1926.1002(b) and 1926.1002(c).

Under 1926.6, how are the SAE and ISO standards referenced in 1926.1002 treated?

The SAE and ISO standards cited in 1926.1002 are incorporated by reference through 1926.6, meaning compliance requires meeting those external standards' test and performance requirements as specified in 1926.1002(b) and 1926.1002(c).

Under 1926.1002, does the standard specify the tests to prove a ROPS meets performance requirements?

Yes—the standard requires that protective frames meet the test and performance procedures contained in the named SAE or ISO standards, so those referenced documents specify the actual test methods; see 1926.1002(b) and 1926.1002(c) and the incorporation mechanism at 1926.6.

Under 1926.1002(e), are tractors with 20 engine horsepower or less covered by this ROPS rule?

No. Both the "agricultural tractor" and "industrial tractor" definitions in 1926.1002(e) apply only to wheel-type tractors of more than 20 engine horsepower. See 1926.1002(e)(1) and 1926.1002(e)(2).

Under 1926.1002(b), if I acquire a used tractor built in 2010, which ROPS tests must the frame meet?

A tractor manufactured before July 15, 2019 (such as 2010) must have protective frames that meet SAE J334a and J168 test and performance requirements or the ISO 5700:2013 consensus standard as allowed by 1926.1002(b).

Under 1926.1002(c), may a manufacturer meet either ISO 5700:2013 or ISO 3471:2008 for new tractors?

Yes; for equipment manufactured on or after July 15, 2019, protective frames must meet either ISO 5700:2013 or ISO 3471:2008 as specified in 1926.1002(c).

Under 1926.1002, who enforces these ROPS frame requirements on a construction site?

OSHA enforces compliance with the ROPS requirements for construction under Part 1926, so employers are responsible for ensuring tractors used in construction meet the 1926.1002 requirements; see general Part 1926 authority. Employers should verify frames meet the referenced SAE/ISO standards in 1926.1002(b) and 1926.1002(c).

Under 1926.1002(e)(1), why did OSHA adopt the SAE definition of "agricultural tractor" for this subpart?

OSHA adopted the SAE definition because Part 1926 applies only to construction work and the SAE definition describes wheel-type agricultural tractors; see the explanation in 1926.1002(e)(1).

Under 1926.1002(e)(2), would a tractor used for landscaping on a construction site be covered as an "industrial tractor"?

Yes—use in landscaping is explicitly listed in the definition of "industrial tractor" in 1926.1002(e)(2), so such a wheel‑type tractor over 20 horsepower used in those operations is covered by the ROPS requirements. See 1926.1002(e)(2).

Under 1926.1002, what is the compliance significance of the July 15, 2019 date?

The July 15, 2019 date determines which test standard applies: equipment manufactured before that date must meet SAE J334a/J168 or ISO 5700:2013 per 1926.1002(b), while equipment manufactured on or after that date must meet ISO 5700:2013 or ISO 3471:2008 per 1926.1002(c).

Under 1926.1002, if a tractor is used for highway maintenance, does it fall under the ROPS rules?

Yes—highway maintenance is listed as an example of operations for an "industrial tractor" in 1926.1002(e)(2), so wheel‑type tractors over 20 horsepower used in highway maintenance are covered by the ROPS requirements. See 1926.1002(e)(2).

Under 1926.1002, where should I look for detailed test procedures for a ROPS I need to verify?

You should review the specific SAE or ISO standards named in 1926.1002(b) and 1926.1002(c), and note that those documents are incorporated by reference through 1926.6 which makes their test procedures part of the compliance requirements.