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OSHA 1928SubpartCAppA

Tractor operating instructions

Subpart C

12 Questions & Answers

Questions & Answers

Under Appendix A to Subpart C of Part 1928, must a tractor operator wear a seat belt when the tractor is equipped with a ROPS (rollover protective structure)?

Yes — if the tractor has a ROPS, the operator must securely fasten the seat belt before operating. See Appendix A to Subpart C of Part 1928 which states "Securely fasten your seat belt if the tractor has a ROPS."

  • Fastening the seat belt helps keep the operator within the protection zone of the ROPS during a rollover.
  • If the tractor does not have a ROPS, using a seat belt may not provide the same protection and could increase risk; follow manufacturer guidance and applicable OSHA tractor guidance when deciding seat belt use on non-ROPS tractors.

Under Appendix A to Subpart C of Part 1928, how should an operator approach working near ditches, embankments, and holes?

Avoid operating the tractor close to ditches, embankments, and holes whenever possible. The appendix states "Where possible, avoid operating the tractor near ditches, embankments, and holes." See Appendix A to Subpart C of Part 1928.

  • Stay a safe lateral distance from edges; soft ground or undercut banks can collapse under a tractor.
  • If crossing is unavoidable, slow down, choose the shallowest crossing point, and cross perpendicular to the slope when safe.
  • If visibility or ground conditions are poor, dismount and inspect the route on foot before proceeding.

Under Appendix A to Subpart C of Part 1928, when should an operator reduce speed on a tractor?

Reduce speed when turning, crossing slopes, and on rough, slick, or muddy surfaces. The appendix advises to "Reduce speed when turning, crossing slopes, and on rough, slick, or muddy surfaces." See Appendix A to Subpart C of Part 1928.

  • Slowing helps prevent loss of control, skidding, and tip-overs.
  • Reduce speed further if visibility is limited or if towing heavy implements.
  • Use low gears and avoid sudden braking or steering inputs on slippery terrain.

Under Appendix A to Subpart C of Part 1928, how can an operator tell if a slope is too steep for safe tractor operation?

Do not operate on slopes that are too steep for safe operation; if you are unsure, avoid using that slope. The appendix states "Stay off slopes too steep for safe operation." See Appendix A to Subpart C of Part 1928.

  • A slope is unsafe if the tractor feels unstable, if wheels slip, or if the operator must make large steering corrections to maintain direction.
  • When possible, test a slope on foot first, inspect for soft spots, and use a recommended maximum slope from the tractor manufacturer.
  • If you must work on slopes, follow manufacturer guidance: keep heavy implements lowered, drive straight up and down the slope rather than across, and avoid sudden maneuvers.

Under Appendix A to Subpart C of Part 1928, what precautions should an operator take to "watch where you are going" at row ends, on roads, and around trees?

Constantly monitor your path and slow down in tight or obstructed areas like row ends, roads, and around trees. The appendix advises "Watch where you are going, especially at row ends, on roads, and around trees." See Appendix A to Subpart C of Part 1928.

  • Reduce speed before turns or when approaching obstacles so you have time to react.
  • Use mirrors and, when practical, have a spotter for limited-visibility maneuvers.
  • Signal and yield to other vehicles and pedestrians on roads; be extra cautious at blind corners and near overhead branches.

Under Appendix A to Subpart C of Part 1928, are passengers allowed to ride on tractors?

No — do not permit others to ride on the tractor. The appendix plainly states "Do not permit others to ride." See Appendix A to Subpart C of Part 1928.

  • Riding as a passenger on tractor fenders, hitches, or implements is hazardous and prohibited by this guidance.
  • If work requires more than one person, provide a separate safe seat or transport vehicle designed for riders, and follow manufacturer and OSHA guidance.

Under Appendix A to Subpart C of Part 1928, what does it mean to "operate the tractor smoothly," and why is it important?

Operate the tractor with steady, controlled inputs and avoid jerky turns, starts, or stops. The appendix says to "Operate the tractor smoothly - no jerky turns, starts, or stops." See Appendix A to Subpart C of Part 1928.

  • Smooth operation reduces the chance of skidding, loss of control, and rollover.
  • Gradual acceleration and braking protect attachments and reduce stress on the tractor.
  • Plan maneuvers in advance so you can change speed and direction safely rather than making sudden corrections.

Under Appendix A to Subpart C of Part 1928, where should implements and trailers be attached to the tractor?

Only hitch implements to the drawbar or to hitch points recommended by the tractor manufacturer. The appendix directs "Hitch only to the drawbar and hitch points recommended by tractor manufacturers." See Appendix A to Subpart C of Part 1928.

  • Using incorrect hitch points can change the tractor’s stability and increase overturn risk.
  • Use the manufacturer’s recommended hitch height and position; if the manufacturer provides no clear guidance, use the drawbar rather than elevated or improvised hitch points.
  • When towing heavy loads, maintain proper weight distribution and consider using a weight transfer hitch or ballast as recommended.

Under Appendix A to Subpart C of Part 1928, what should an operator do when a tractor is stopped?

When the tractor is stopped, set the brakes securely and use the park lock if it is available. The appendix states "When tractor is stopped, set brakes securely and use park lock if available." See Appendix A to Subpart C of Part 1928.

  • If no park lock exists, leave the transmission in gear (for manual transmissions) and engage the parking brake.
  • On slopes, chock wheels or place blocks to prevent rolling in addition to setting the parking brake.
  • Lower attached implements to the ground when parked to prevent unintended movement.

Under Appendix A to Subpart C of Part 1928, what is a ROPS and why does the appendix link seat belt use to a ROPS-equipped tractor?

A ROPS is a rollover protective structure that helps protect the operator in a tractor rollover, and the appendix links seat belt use to ROPS because the belt keeps the operator inside the protected zone. The appendix states "Securely fasten your seat belt if the tractor has a ROPS." See Appendix A to Subpart C of Part 1928.

  • ROPS are structural frames or cabs designed to reduce the risk of injury in rollovers by maintaining a survival space around the operator.
  • A seat belt, used with ROPS, helps keep the operator within that survival space; without a seat belt the operator may be thrown out and crushed despite the ROPS.
  • Follow tractor manufacturer guidance when inspecting or maintaining ROPS and seat belt systems.

Under Appendix A to Subpart C of Part 1928, how can an employer turn the nine operating instructions into a practical pre-operation checklist for tractor operators?

Create a short pre-operation checklist that covers each instruction: ROPS/seat belt, edge hazards, speed control, slope assessment, visibility, no riders, smooth operation, correct hitching, and secure stopping. The appendix lists these specific operating instructions and can be used as the checklist source; see Appendix A to Subpart C of Part 1928.

  • Example checklist items: verify ROPS and fasten seat belt; inspect area for ditches/holes; check tires/traction; plan route across slopes; clear sightlines; confirm no passengers; warm up engine and operate controls smoothly; attach implements at drawbar/manufacturer points; test and set brakes/park lock when stopping.
  • Keep the checklist with the tractor or in a toolbox and require operators to complete it before use.

Under Appendix A to Subpart C of Part 1928, what steps should employers take to train workers on these tractor operating instructions?

Train workers on each instruction using practical demonstrations, hands-on practice, and reinforcement until they can perform the behaviors safely. The appendix provides the operating rules to teach; see Appendix A to Subpart C of Part 1928.

  • Use tractor-specific demonstrations: show how to fasten seat belts, inspect slopes, and hitch implements properly.
  • Include supervised driving practice in safe areas and assess skills like smooth control and stopping procedures.
  • Document training, review these rules regularly, and refresh training after incidents or when equipment or tasks change.