Standard Interpretations - Table of Contents
• Standard Number: 1928.51

November 5, 1991

Mr. Edward A. Fritz
Manager, Component Endurance & Field Test
J I Case
7 South 600 County Line Road
Hinsdale, Illinois 60521

Dear Mr. Fritz:

Thank you for your letter and technical information concerning the need for the Occupational Safety and Health Administration (OSHA) to evaluate the technical differences between the various standards for Rollover Protective Structures (ROPS) used on agricultural wheeled tractors.

Your primary concern is directed towards OSHA acceptance of the present industry standards published by the Society of Automotive Engineers (SAE) standard, SAE J2194, and the American Society of Agricultural Engineers (ASAE) standard, ASAE S519. You indicate that these standards, when compared to the OSHA requirements, provide for equivalent or superior operator protection. Further, you expressed this concern due to the present compatibility between the International Standards Organization (ISO) standards, ISO 3463 and 5700 and these new industry standards.

The OSHA standard at 29 CFR 1928.51(b)(1), of Subpart C, specifies that ROPS for agricultural wheeled tractors comply with the requirements of 1928.52 or 1928.53. (This standard was adopted from SAE J168-1970.) Alternatively, compliance with the requirements of the OSHA construction standard, 29 CFR 1926.1002, is permitted.

The standard at 29 CFR 1926.1002(a)(5) specifies that ROPS shall comply with SAE J168 (July 1970). The standard, 29 CFR 1926.1002(j)(1), defines agricultural tractor as, "a wheel-type vehicle of more than 20 engine horsepower designed to furnish the power to pull, carry, propel, or drive implements that are designed for agricultural usage." That definition was adopted from SAE J333a. In 1977, SAE J168a, SAE J333b and SAE J334b were replaced by SAE J1194 which incorporated the information contained formerly in those s