By  Daniel R. Birnbaum, Adam R. Young, and Craig B. Simonsen

Image from OSHA.

Seyfarth Synopsis: OSHA has recently highlighted tractor operator safety by increasing use of rollbars or cage frames.

Employers use tractors to clear winter snows.  As snow season approaches, OSHA warns that many older tractors are in use that are not equipped with rollover protective structures (“ROPS”).  While all tractors manufactured after October 25, 1976 are required to be installed with ROPS and a seatbelt, using ROPS and a seat belt system regardless of tractor age can help reduce injuries.  

Employers can focus on ensuring appropriate training occurs of workers on safe tractor operations, both initially and annually.  Employers should also ensure the ROPS are replaced if overturn occurs and ensure the ROPS meets all applicable OSHA standards.  Employers should also ensure that manufacturer labeling is not removed from the ROPS.

Employees can also minimize the risk of injuries by ensuring they securely fasten their seat belts, do not carry passengers, and exercise caution when operating the trailer, such as driving slower near hazards, saying clear of steep slopes, being alert when approaching row ends or rows, and avoiding sharp turns and sudden stops.  Employees should also ensure brakes are set when stopping a tractor and appropriately using park locks.

Equipment should also be regularly maintained, including inspection when a rollover occurs and checking tractor batteries, fuel tanks, oil reservoirs and coolant system seals.  Foldable ROPS should be kept in the up position, unless operating near low-clearance objects.  Employers should avoid using self-made ROPS, unless it complies with OSHA test procedures and performance requirements.

OSHA’s General Duty Clause requires employers to provide a workplace free from any recognized hazard. OSHA has published additional guidance on Tractor Safety for the Landscaping and Horticultural Services Industry and a Protecting Farmworkers from Tractor and Harvester Hazards QuickCard.

For more information on this or any related topic, please contact the authors, your Seyfarth attorney, or any member of the Workplace Safety and Health (OSHA/MSHA) Team.