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OSHA 1926.601

Motor vehicle requirements

Subpart O

25 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.601(a), which motor vehicles are covered by this standard?

Vehicles that operate within an off-highway jobsite not open to public traffic are covered by 1926.601(a).

  • Vehicles or equipment that are covered by 1926.602 (equipment with its own specific rules) are not covered by this section.
  • If you’re unsure whether a piece of equipment is a “motor vehicle” under this section or is covered by 1926.602, treat it as equipment subject to the more specific standard until clarified.

Under 1926.601(b)(1), what brake systems must every vehicle have and be maintained in?

Every vehicle must have a service brake system, an emergency brake system, and a parking brake system, and they must be maintained in operable condition under 1926.601(b)(1).

  • These systems may share components but all three functions (service, emergency, parking) must be available and operable.
  • Keep maintenance records and repair defects before placing the vehicle into service, consistent with the pre-shift check requirement in 1926.601(b)(14).

Under 1926.601(b)(2)(i) and (ii), when are headlights and taillights required and are brake lights always required?

When visibility conditions warrant additional light, vehicles must have at least two operable headlights and two operable taillights under 1926.601(b)(2)(i), and brake lights must be operable at all times under 1926.601(b)(2)(ii).

  • Even in daylight or good lighting, brake lights must work.
  • Headlights/taillights are required when extra light is needed (e.g., night, fog, dust, tunnels).

Under 1926.601(b)(3), what warning device is required on vehicles?

All vehicles must be equipped with an adequate audible warning device at the operator’s station and it must be operable, per 1926.601(b)(3).

  • The horn or warning device must be loud enough and positioned so the operator can use it quickly.
  • Test the device during the pre-shift check required by 1926.601(b)(14).

Under 1926.601(b)(4)(i)–(ii), what must an employer do before using a vehicle with an obstructed rear view?

You cannot use a vehicle with an obstructed rear view unless it has an audible reverse signal alarm audible above surrounding noise levels 1926.601(b)(4)(i) or the vehicle is backed up only when an observer signals that it is safe 1926.601(b)(4)(ii).

  • The reverse alarm must be louder than ambient noise so nearby workers can hear it.
  • If using an observer, the observer must be positioned to have a clear view and give clear signals before backing begins.
  • Correct defects to the alarm or assign an observer before operating the vehicle, per the pre-shift inspection rule in 1926.601(b)(14).

Under 1926.601(b)(5), what are the windshield and wiper requirements for vehicles with cabs?

All vehicles with cabs must have windshields and powered wipers, and cracked or broken glass must be replaced; vehicles that experience fogging or frosting must have operable defogging or defrosting devices, per 1926.601(b)(5).

  • Replace damaged glass before placing the vehicle in service.
  • Ensure wipers and defoggers/defrosters are checked on each shift as required by 1926.601(b)(14).

Under 1926.601(b)(6), when must haulage vehicles have cab shields or canopies?

Haulage vehicles whose payloads are loaded by cranes, power shovels, loaders, or similar equipment must have a cab shield and/or canopy adequate to protect the operator from shifting or falling materials under 1926.601(b)(6).

  • The shield or canopy must be strong enough for anticipated loads and maintained in good condition.
  • If work operations change, reassess whether the shield or canopy remains adequate and repair or upgrade as needed.

Under 1926.601(b)(7), how must tools and materials be transported when employees share the same compartment?

Tools and materials transported in the same compartment with employees must be secured to prevent movement under 1926.601(b)(7).

  • Use tie-downs, bins, racks, or covers so loose items cannot shift and strike occupants during travel.
  • Inspect securing devices during the pre-shift inspection required by 1926.601(b)(14).

Under 1926.601(b)(8), what seating is required for vehicles used to transport employees?

Vehicles used to transport employees must have seats that are firmly secured and adequate for the number of employees to be carried under 1926.601(b)(8).

  • Do not allow employees to ride in beds or areas without proper, secured seating.
  • Seats must be inspected for secure mounting and structural soundness during pre-shift checks in 1926.601(b)(14).

Under 1926.601(b)(9), are seat belts required on construction motor vehicles and what standard governs them?

Yes — seat belts and anchorages meeting the requirements of 49 CFR part 571 (Federal Motor Vehicle Safety Standards) must be installed in all motor vehicles under 1926.601(b)(9).

  • Employers must maintain and ensure employees use seat belts where required by corporate or site policy and applicable laws.
  • Check seat belt condition and anchorages on each shift as part of the checklist in 1926.601(b)(14).

Under 1926.601(b)(10), what safety requirement applies to trucks with dump bodies during maintenance or inspection?

Trucks with dump bodies must have a positive means of support that is permanently attached and capable of being locked in position to prevent accidental lowering during maintenance or inspection under 1926.601(b)(10).

  • Never rely solely on hydraulic pressure to hold a dump body up during service; use the designed mechanical supports.
  • Inspect the support and locking devices regularly and before maintenance per 1926.601(b)(14).

Under 1926.601(b)(11), what must operating levers controlling hoisting or dumping devices have?

Operating levers controlling hoisting or dumping devices on haulage bodies must be equipped with a latch or other device to prevent accidental starting or tripping under 1926.601(b)(11).

  • Ensure latches are functional and not bypassed or jammed.
  • Test lever latches during pre-shift inspections required by 1926.601(b)(14).

Under 1926.601(b)(12), how must tailgate trip handles be arranged for dump trucks?

Tailgate trip handles for dump trucks must be arranged so that when the truck is dumping the operator will be in the clear, per 1926.601(b)(12).

  • Design or position trip handles so the operator does not have to stand in or reach into the danger zone during dumping.
  • Train operators on proper use and verify correct clearance during the pre-use inspection in 1926.601(b)(14).

Under 1926.601(b)(13)(i)–(ii), when are fenders required and when may mud flaps be used instead?

All rubber-tired motor vehicle equipment manufactured on or after May 1, 1972 must have fenders; equipment manufactured before that date had to have fenders by May 1, 1973 1926.601(b)(13)(i). Mud flaps may be used instead of fenders when the equipment was not designed for fenders 1926.601(b)(13)(ii).

  • If your equipment lacks factory fenders because it wasn’t designed for them, mud flaps are acceptable.
  • Inspect mud flaps or fenders for damage and secure attachment during the shift-start inspection in 1926.601(b)(14).

Under 1926.601(b)(14), what must be checked at the beginning of each shift before putting a vehicle into service?

At the beginning of each shift, employers must check that service brakes (including trailer brake connections), parking system (hand brake), emergency stopping system, tires, horn, steering mechanism, coupling devices, seat belts, operating controls, and safety devices are in safe operating condition and free of apparent damage under 1926.601(b)(14).

  • All defects discovered must be corrected before placing the vehicle in service.
  • This inspection also applies to lights, reflectors, windshield wipers, defrosters, fire extinguishers, and other equipment where necessary.
  • Use a written checklist to document inspections and repairs for accountability.

Under 1926.601(b)(14), do the pre-shift inspection requirements include emergency equipment like fire extinguishers and lighting?

Yes — the pre-shift inspection requirement in 1926.601(b)(14) explicitly applies to equipment such as lights, reflectors, windshield wipers, defrosters, and fire extinguishers when such equipment is necessary.

  • If the vehicle is expected to operate at night or in low visibility, check headlights, taillights, and reflectors.
  • Ensure fire extinguishers are charged, accessible, and inspected per employer policy or manufacturer guidance.

Under 1926.601(b)(4)(i), how loud must a reverse signal alarm be?

A reverse signal alarm must be audible above the surrounding noise level so that it can be heard by those in the area, as required by 1926.601(b)(4)(i).

  • The alarm should be tested under normal operating noise conditions to ensure it stands out.
  • If ambient noise varies across the site, consider directional alarms or observers as allowed in 1926.601(b)(4)(ii).

Under 1926.601, are defects found during pre-shift checks allowed to be deferred until after the vehicle is used?

No — 1926.601(b)(14) requires that all defects discovered during the beginning-of-shift check be corrected before the vehicle is placed in service.

  • If a defect cannot be fixed immediately, the vehicle must be taken out of service or restricted from operations that would create risk.
  • Keep records of defects and corrective actions to demonstrate compliance.

Under 1926.601(b)(3) and (14), who is responsible for testing the audible warning device and how often?

The employer is responsible for ensuring the vehicle’s audible warning device is operable and it must be checked at the beginning of each shift per 1926.601(b)(3) and the pre-shift checklist in 1926.601(b)(14).

  • Operators should test the horn/warning device during the shift-start inspection and report defects immediately.
  • Employers must repair or replace defective devices before allowing the vehicle back in service.

Under 1926.601(b)(8) and (9), can employees ride in a vehicle without seats or seat belts if the employer provides other protections?

No — vehicles used to transport employees must have firmly secured seats adequate for the number of employees (1926.601(b)(8)), and all motor vehicles must have seat belts and anchorages meeting 49 CFR part 571 (1926.601(b)(9)).

  • Other protections do not substitute for required seating and seat belts when transporting employees.
  • Ensure employees are trained to use seat belts and that belts are maintained and inspected per 1926.601(b)(14).

Under 1926.601(b)(10)–(11), what controls should be in place to prevent accidental lowering or activation of dump or hoisting mechanisms?

Trucks with dump bodies must have permanently attached positive support devices capable of being locked to prevent accidental lowering (1926.601(b)(10)), and operating levers for hoisting or dumping must have latches or devices to prevent accidental starting or tripping (1926.601(b)(11)).

  • Maintain and test locking supports and lever latches during inspections called for in 1926.601(b)(14).
  • Train workers on lockout/tagout and safe procedures before performing maintenance under raised dump bodies.

Under 1926.601(b)(13) and (14), what should you do if your older rubber‑tired equipment has no fenders and was designed that way?

If the equipment was not designed for fenders, you may use mud flaps in lieu of fenders per 1926.601(b)(13)(ii); however, ensure the mud flaps are in good condition and properly attached and inspect them each shift under 1926.601(b)(14).

  • Replace or repair worn or damaged mud flaps promptly to prevent thrown objects or reduced visibility for nearby workers.
  • Document inspections and repairs as part of your vehicle maintenance records.

Under 1926.601(b)(4)(ii), how should an observer signal when backing a vehicle with obstructed view?

When relying on an observer because the vehicle has an obstructed rear view, the vehicle must be backed only when the observer signals that it is safe to do so as stated in 1926.601(b)(4)(ii).

  • Use clear, standardized hand signals or two-way radios agreed upon before the maneuver.
  • Position the observer where they can see the entire backing path and be visible to the operator; train observers on their responsibilities and authority to stop the vehicle.

Under 1926.601(b)(14), are trailer brake connections included in the pre-shift inspection?

Yes — 1926.601(b)(14) specifically requires that service brakes, including trailer brake connections, be checked at the beginning of each shift to ensure they are in safe operating condition and free of apparent damage.

  • Verify secure hitching, air or hydraulic connections, and proper brake function before moving combination vehicles.
  • Correct any trailer brake defects before placing the vehicle in service.

Under 1926.601, can employers rely on a vehicle’s manufacturer maintenance schedule instead of the shift-start checks required by 1926.601(b)(14)?

Employers must perform the beginning-of-shift checks required by 1926.601(b)(14) in addition to following manufacturer maintenance schedules; the shift checks are an operational safety requirement and defects found must be corrected before use.

  • Manufacturer maintenance schedules (e.g., periodic servicing) do not replace the need for daily operability checks.
  • Combine both approaches: daily checks catch immediate hazards while scheduled maintenance prevents long-term failures.