- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
June 13, 1977
William G. Wadman
Assistant Executive Director
Associated General Contractors
of Maine, Inc.
P.O. Box N
Augusta, Maine 04330
Dear Mr. Wadman:
Subject: Barricading Swing Radius of Backhoes
We offer the following comments in response to your letter of May 19, 1977, requesting interpretation of 1926.550(a)(9) of the OSHA Construction Standards as it applies to backhoes.
As 1926.550(a)(9) indicates, the purpose of a barricade around the rotating superstructure of a crane is to prevent an employee from being struck by the superstructure or crushed between the superstructure and other objects or another part of the crane. The hazard is the same when the superstructure of excavating equipment is rotated.
Granted, 1926.550(a)(9) covers only cranes. There is no similar specific standard in Section 1926.602(b). However, 1926.602(b)(2) does require that the excavating equipment conform to the nomenclature and dimensions for cranes and shovel and hoe attachments described in Society of Automotive Engineers' Standard SAE J-958. Also, 1926.602(b)(3) requires that the safety requirements contained in Power Crane and Shovel Association Standards Nos. 1, 2 and 3 shall be applied to excavating equipment.
Appendix A of PCSA Standard No. 1 contains Society of Automotive Engineers' Standard SAE J-958. Moreover, Section 3 of each of these three PCSA Standards contains the same descriptions of the basic components of the machines, including the mountings, the superstructure, and the various types of front end attachments, which may be applied to the basic machines for different purposes, including lifting and excavating.
When the same basic machines can be used for either lifting or excavating, the same safety precautions required for cranes should logically be applied to excavating equipment. Since it is common practice to provide barricades around the swing radius of the superstructure of the machine when it is used as a crane, it should be common practice to provide such a barricade when the machine is used as a shovel or backhoe. For this reason, it is OSHA policy to apply 1926.550(a)(9) to excavating equipment when the same basic machine can be used for either lifting or excavating.
Sincerely,
Gilbert J. Saulter
Regional Administrator
for Occupational Safety and Health