OSHA AI Agent
Get instant answers to any safety question.
Request Demo
OSHA 1928.52

Tractor protective frame requirements

Subpart C

24 Questions & Answers
10 Interpretations

Questions & Answers

Under 1928.52(a) — What is the purpose of the protective frame standard for wheel‑type agricultural tractors?

The purpose is to set test and performance requirements for protective frames (ROPS) so they reduce the frequency and severity of operator injuries from accidental tractor upsets. See the purpose in 1928.52(a) and the general operator protection requirement in 1928.51.

Under 1928.52(b) — What types of tests must a protective frame model undergo?

A protective frame model must be tested by (1) a laboratory energy‑absorption test (static or dynamic) and (2) a field‑upset test to the side and rear under controlled conditions, unless an exception applies. See 1928.52(b) and the detailed subparagraphs at 1928.52(b)(1) and 1928.52(b)(2).

Under 1928.52(b)(2)(i) and (ii) — When may the field‑upset test be omitted?

The field‑upset test can be omitted when laboratory test analysis shows the frame's energy absorption ratios exceed the standard margins: either (A) both FERis and FERir exceed 1.15 from the static energy‑absorption analysis, or (B) the dynamic test shows the frame can withstand an impact 15% greater than the required impact for the tractor weight. See 1928.52(b)(2)(i) and 1928.52(b)(2)(ii), and the FER definitions in 1928.52(d)(2)(ii).

Under 1928.52(c)(1) — What is a "protective frame" for a wheel‑type agricultural tractor?

A protective frame is a structure of uprights mounted to the tractor and extending above the operator's seat designed to protect the operator in an upset. A typical two‑post frame example is shown in the standard. See the definition at 1928.52(c)(1).

Under 1928.52(c)(2) and (3) — Can an overhead weather shield or falling‑object device be in place during tests?

Yes — an overhead weather shield or an overhead falling‑object protection device may remain attached during tests provided it does not contribute to the strength of the protective frame. See 1928.52(c)(2) and 1928.52(c)(3).

Under 1928.52(d)(1)(i–iii) — Which tractor weight, test article, and measurements are required for tests?

Use the weight of the heaviest tractor model on which the protective frame is to be used; each test must be performed on a new protective frame with the same mounting‑connection design; and instantaneous deflection must be measured and recorded for each segment of the test. See 1928.52(d)(1)(i), 1928.52(d)(1)(ii), and 1928.52(d)(1)(iii).

Under 1928.52(d)(1)(vii) — Are rear input energy tests always required for frames on 4‑wheel‑drive tractors?

No — rear input energy tests (static, dynamic, or field‑upset) are not required for frames mounted on tractors that have four driven wheels and place more than one‑half of their unballasted weight on the front wheels. See 1928.52(d)(1)(vii).

Under 1928.52(d)(2)(i)(A–C) — What mounting and instrumentation are required for static tests?

For static tests the laboratory mounting base must be the tractor chassis or its equivalent; the frame must be instrumented to obtain required load‑deflection data at specified locations; and for one‑ or two‑upright designs, mounting connections must be instrumented to record forces before any installation load is applied. See 1928.52(d)(2)(i)(A), 1928.52(d)(2)(i)(B), and 1928.52(d)(2)(i)(C).

Under 1928.52(d)(2)(ii) — How are the required energy inputs and FER defined for side and rear loads?

The side input energy Eis = 723 + 0.4 W (ft‑lb) and the rear input energy Eir = 0.47 W (ft‑lb), where W is tractor weight in pounds; FER (factor of energy ratio) is the ratio of strain energy absorbed Eu to required input energy (FERis = Eu/Eis and FERir = Eu/Eir). See the definitions and formulas at 1928.52(d)(2)(ii).

Under 1928.52(d)(2)(iii)(A) — Where is the rear static load applied and when must the rear static test be stopped?

The rear static load is applied to the upper extremity of the frame at a point midway between the center of the frame and the inside of the frame upright, distributed on an area no greater than 160 sq. in. The rear test is stopped when the frame has absorbed the required Eir energy, when deflection exceeds the allowable deflection, or when the frame load limit is reached before allowable deflection. See 1928.52(d)(2)(iii)(A) and the stop criteria at 1928.52(d)(2)(iii)(A)(1)–(3).

Under 1928.52(d)(2)(iii)(F–J) — What is the procedure for the side static test and the calculations required afterward?

Apply the side load to the upper extremity at a 90° angle to the vehicle centerline on the side farthest from the rear load, stop the test when the frame absorbs Eis or allowable deflection is exceeded or load limit is reached, then construct the L‑D curve and calculate Eis, FERis, and FSB as required. See 1928.52(d)(2)(iii)(F) and the follow‑up tasks at 1928.52(d)(2)(iii)(G)–(J).

Under 1928.52(d)(3)(i) — What are the key dynamic test setup requirements (pendulum, height, restraint, tires)?

Dynamic tests use a 4,410‑lb (2,000‑kg) pendulum with a 27±1 in. impact face, suspended from a pivot 18–22 ft above impact, with the tractor restrained by cables having strength at least that of 0.50‑in. steel cable (and limited elasticity), and tires inflated to manufacturer’s maximum operating pressure with no liquid ballast. See 1928.52(d)(3)(i)(B) and the restraining/tire requirements at 1928.52(d)(3)(i)(C) and 1928.52(d)(3)(i)(D).

Under 1928.52(d)(3)(iii)(A–B) — In what sequence and position must dynamic impacts be applied?

Evaluate the frame first with a rear dynamic impact and then with a side impact on the same frame, using the pendulum height per paragraph (d)(3)(ii), positioning the pendulum so the initial impact point lies on the pendulum CG arc; for rear impact position the pendulum 20° from vertical before impact. See 1928.52(d)(3)(iii)(A) and 1928.52(d)(3)(iii)(B).

Under 1928.52(d)(3)(i)(C) — What are the restraining cable strength and angle requirements during dynamic tests?

Restraining members must have strength no less than, and elasticity no greater than, that of 0.50‑in. (12.7‑mm) steel cable; attachment points must provide restraining cable angles of 15° to 30° to the horizontal and be located behind the rear axle and in front of the front axle as specified. See 1928.52(d)(3)(i)(C).

Under 1928.52(d)(3)(i)(E–G) — Are repairs or repeats allowed during dynamic tests?

No repairs or adjustments may be made during the dynamic test; if any cables, props, or blocking shift or break during the test the test must be repeated. See 1928.52(d)(3)(i)(F) and 1928.52(d)(3)(i)(G).

Under 1928.52(d)(4)(i)(B) — What soil conditions and standard are required for the field‑upset soil bank test?

The field‑upset side test must be conducted on a dry, firm soil bank with an average cone index of at least 150 (0–6 in. layer), and cone index must be determined per ASAE recommendation R313.1‑1971. See 1928.52(d)(4)(i)(B)(1) and the referenced ASAE standard citation at 1928.52(d)(4)(i)(B)(2).

Under 1928.52(d)(4)(ii) — How must rear and side field upsets be induced during field‑upset tests?

Rear upsets must be induced by engine power driving the tractor forward up a minimum 60°±5° slope at 3–5 mph at governed rpm (or equivalent), and side upsets must be induced by driving under power at a minimum 10 mph (or max speed if under 10 mph) over the specified ramp. See 1928.52(d)(4)(ii)(A) and 1928.52(d)(4)(ii)(B).

Under 1928.52(e)(1)(i) — What deformations are allowed during tests and what operator‑area clearances must be preserved?

Frames and nearby parts may deform but must not shatter, leave sharp edges, or encroach on the specified operator‑area clearances: d = 2 in. inside upright to vertical seat centerline, e = 30 in. longitudinal centerline, f = ≤4 in. rear edge of crossbar forward of the SRP, g = 24 in. minimum, and m ≤12 in. See 1928.52(e)(1)(i).

Under 1928.52(d)(1)(iv) — How is the seat‑reference point (SRP) determined for testing?

The SRP is the intersection where a vertical line tangent to the most forward point at the longitudinal seat centerline of the seat back meets a horizontal line tangent to the highest point of the seat cushion, determined with the seat unloaded and adjusted to its highest and most rearward position for seated operation. See 1928.52(d)(1)(iv).

Under 1928.52(e)(1)(ii) — What low‑temperature test or Charpy impact values are required for frame materials?

The protective structure and fasteners must pass static, dynamic, or field tests at 0°F (−18°C) or the material must meet Charpy V‑notch impact‑strength minimums: for 10×10 mm specimen 8.0 ft‑lb at −20°F, 10×7.5 mm 7.0 ft‑lb, 10×5 mm 5.5 ft‑lb, or 10×2.5 mm 4.0 ft‑lb (all at −20°F). Specimens are longitudinal from flat, tubular, or structural stock before forming or welding. See 1928.52(e)(1)(ii).

Under 1928.52(e)(2) — What are the static test performance thresholds for FER and FSB?

For static tests both FERis and FERir must be greater than 1.0, and when the ROPS has only one or two uprights the mounting‑connection design margin FSB must be greater than 1.3. See 1928.52(e)(2).

Under 1928.52(e)(3) — What must dynamic test performance demonstrate?

Dynamic test performance must meet the structural requirements using the clearances and dimensions specified in paragraph (e)(1) for both side and rear impacts so that operator space is preserved during dynamic loading. See 1928.52(e)(3) and 1928.52(e)(1).

Under 1928.52(d)(2)(i)(C) — When must instrumentation be placed on mounting connections for one‑ or two‑upright frames?

Instrumentation must be placed on mounting connections before any installation load is applied so that the required peak forces in the connections are recorded during testing. See 1928.52(d)(2)(i)(C).

Subject: ROPS equivalency for tractors — Will OSHA accept ROPS tested to ISO, SAE, or ASAE standards as equivalent to 29 CFR Part 1928 requirements?

OSHA will accept ROPS meeting the performance requirements of ISO test standards as equivalent when the SAE standard recognizes those ISO tests and the ROPS also meet the SAE/ASAE temperature/material and seat‑belt requirements; however OSHA does not independently verify equivalency — the employer is responsible for compliance. This is discussed in the OSHA letter on ROPS equivalency, which explains OSHA's willingness to accept ISO per SAE and ASAE [see the Letter of Interpretation at https://www.osha.gov/laws-regs/standardinterpretations/1997-07-08-0] and the regulatory ROPS requirements in 1928.51 and 1928.52.