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OSHA 1926.1003

Overhead protection for tractor operators

Subpart W

11 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.1003(a), to whom does the overhead protection rule apply?

This section applies to operators of wheel-type agricultural and industrial tractors when those tractors are used in construction work. See 1926.1003(a).

  • The rule sets design and installation requirements for any overhead protection that is provided on such tractors to minimize injuries from overhead hazards and from the protective structure itself if the machine upsets.
  • It does not, in this language, itself require that every tractor have overhead protection; it prescribes how that protection must be designed and installed when it is provided. See 1926.1003(a).

Under 1926.1003(b), what overhead protection standard must be followed for tractors manufactured before July 15, 2019?

For tractors manufactured before July 15, 2019, the overhead protection must be designed and installed according to the test and performance requirements of Society of Automotive Engineers Standard J167, or it may comply with the consensus standard ISO 27850:2013. See 1926.1003(b).

  • These referenced standards are incorporated by reference via 1926.6.
  • If you maintain or restore older tractors, follow SAE J167 or ISO 27850:2013 to meet the design and installation requirements stated in 1926.1003(b).

Under 1926.1003(c), what overhead protection standard must be followed for tractors manufactured on or after July 15, 2019?

For tractors manufactured on or after July 15, 2019, the overhead protection must be designed and installed to meet the International Organization for Standardization standard ISO 27850:2013. See 1926.1003(c).

  • That ISO standard describes falling-object protective structures and their test procedures and performance requirements and is incorporated by reference via 1926.6.
  • Use ISO 27850:2013 for new tractors (manufacture date on or after 7/15/2019) when installing overhead protection under 1926.1003(c).

Under 1926.1003(d), if a machine is covered by the site clearing rule (1926.604), which overhead protection standards may be used?

If a machine is subject to the site clearing requirements in 1926.604, you may use either the overhead protection required by 1926.604 or the overhead protection required by 1926.1003. See 1926.1003(d).

  • In practice, this gives employers flexibility: use the protective design called for in the site-clearing standard or follow the test/performance standards referenced in 1926.1003(b)-(c).

Under 1926.1003, what hazards is overhead protection intended to reduce for tractor operators?

Overhead protection is intended to minimize the possibility of operator injury from overhead objects (for example, flying or falling objects) and to reduce injury from the overhead cover itself in the event the tractor accidentally upsets. See 1926.1003(a).

  • Design and installation requirements referenced in 1926.1003(b)-(c) aim to ensure that the protective structure performs under realistic impact and upset conditions.
  • Use the applicable test procedures (SAE J167 or ISO 27850:2013) to verify performance for the machine's manufacture date range.

Under 1926.1003(b), can overhead protection on older tractors comply with ISO 27850:2013 instead of SAE J167?

Yes. For tractors manufactured before July 15, 2019, overhead protection may be designed and installed according to SAE J167 or it may alternatively comply with ISO 27850:2013. See 1926.1003(b).

  • This gives owners of older equipment the option to meet the later ISO consensus standard if they choose, as permitted explicitly in 1926.1003(b).
  • The incorporation of those standards is handled through 1926.6, which lists materials incorporated by reference.

Under 1926.1003, does the standard tell you how to obtain the SAE J167 or ISO 27850:2013 test procedures?

The standard identifies which consensus test and performance standards apply (SAE J167 and ISO 27850:2013) and notes that they are incorporated by reference under 1926.6, but it does not provide the full text of those standards. See 1926.1003(b)-(c).

  • To review the detailed test methods and performance criteria you will need to obtain the SAE or ISO standards from their publishers or from an authorized distributor referenced through the incorporation details in 1926.6.
  • Employers and equipment manufacturers should follow those test documents to ensure compliance with 1926.1003(b)-(c).

Under 1926.1003, does the section require retrofitting overhead protection on tractors that currently lack it?

The language of 1926.1003 prescribes design and installation requirements "when overhead protection is provided," but it does not itself state a general requirement to retrofit tractors that do not already have overhead protection. See 1926.1003(a).

  • If an employer chooses (or is otherwise required by another rule or manufacturer guidance) to provide overhead protection, that protection must meet the applicable design/test standard in 1926.1003(b)-(c).
  • Other standards, employer policies, or equipment-specific regulations may impose retrofit obligations; consult those requirements as well as 1926.1003 when making decisions.

Under 1926.1003, what is the difference in required standards before and after July 15, 2019?

The difference is which test/performance standard the overhead protection must meet: for tractors manufactured before July 15, 2019, overhead protection must meet SAE J167 (or may comply with ISO 27850:2013), while for tractors manufactured on or after July 15, 2019, overhead protection must meet ISO 27850:2013. See 1926.1003(b)-(c).

  • In short: older machines—SAE J167 or ISO 27850; newer machines—ISO 27850 required. See 1926.1003(b)-(c).

Under 1926.1003, does the phrase "overhead protection" include protection against the overhead cover failing in a rollover?

Yes. The standard requires overhead protection that minimizes operator injury both from overhead objects (like flying or falling objects) and "from the cover itself in the event of accidental upset," which covers the risk of the protective cover causing injury during a rollover or upset. See 1926.1003(a).

  • Use the test and performance criteria in the referenced standards (SAE J167 or ISO 27850:2013, as applicable) to ensure the structure protects the operator during upset scenarios. See 1926.1003(b)-(c).

Under 1926.1003, where can I read the full OSHA regulation for overhead protection for tractor operators?

You can read the full OSHA text of the overhead protection regulation at 1926.1003.

  • That page includes the scope (a), the requirements for equipment manufactured before July 15, 2019 (b), requirements for equipment manufactured on or after that date (c), and the site-clearing provision (d). See 1926.1003.