U. S. Department of Labor

Occupational Safety and Health Administration

Directorate of Technical Support & Emergency Management

Office of Science and Technology Assessment

SHIB 01-12-2009

Safety and Health Information Bulletin

Hazards Associated with Operating Skid-Steer Loaders with

Bypassed and/or Improperly Maintained Safety Devices

Introduction

Skid-steer loaders (Figure 1) are manufactured with

safety features to prevent unexpected or inadvertent

movement of the loader arm and hydraulics when the

operator is not in the cab. However, these safety

features can be bypassed, defeated or improperly

maintained which can result in serious injury or death

to the operator and/or other employees working on or

around the equipment.

 Figure 1: Typical Skid-Steer Loader

Purpose

The purpose of this Safety and Health Information

Bulletin is to:

· raise public awareness about recent

fatalities that have occurred with skidsteer loaders due to bypassed safety

devices;

· alert employers and employees about

the need to review and follow manufacturer

instructions regarding the installation, use,

testing, inspection, and maintenance of safety

devices on skid-steer loaders; and

· emphasize the importance of conducting

training on the proper use of skid-steer

loaders.

Scope

This SHIB focuses on the seatbelts and safety

interlock systems typically found on skid-steer loaders

intended primarily for earth moving. Such vehicles are

not covered by the requirements of OSHA’s Powered

Industrial Truck standard, 29 CFR 1910.178.

This Safety and Health Information Bulletin is not a standard

or regulation, and it creates no new legal obligations. The

Bulletin contains recommendations as well as descriptions

of mandatory safety and health standards. The

recommendations are advisory in nature, informational in

content, and are intended to assist employers in providing a

safe and healthful workplace. The Occupational Safety and

Health Act requires employers to comply with safety and

health standards promulgated by OSHA or by a state with

an OSHA-approved state plan. In addition, pursuant to

Section 5(a)(1), the General Duty Clause of the Act,

employers must provide their employees with a workplace

free from recognized hazards likely to cause death or serious

physical harm. Employers can be cited for violating the

General Duty Clause if there is a recognized hazard and they

do not take reasonable steps to prevent or abate the hazard.

However, failure to implement any recommendations in this

SHIB is not, in itself, a violation of the General Duty Clause.

Citations can only be based on standards, regulations, and

the General Duty Clause.
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Background

Common safety features of a skid-steer loader include

the seatbelt for operator restraint, Falling Object

Protective Structure (FOPS), Roll-Over Protective

Structure (ROPS), and a Control Interlock System.

Some of these machines are equipped with a pulldown armrest (seat bar) that may be used to interlock

the machine control systems (as shown in Figure 2).

The seatbelt helps prevent the operator from being

thrown about inside or falling out of the skid-steer

loader. The FOPS and ROPS protect the operator

from falling objects and injury due to accidental

rollovers. Control Interlock Systems and/or operator

seats used on some machines typically activate a

safety interlock system that is intended to prevent

inadvertent movement of the machine’s controls when

the operator is not in the proper operating position

(i.e., seated).

 Figure 2: Typical Control Interlock System

 (seat bar, shown in raised position)

Review of OSHA’s Integrated Management

Information System (IMIS) reveals that between 1997

and 2007, 100 accidents were recorded specifically

involving skid-steer loaders. The deliberate bypassing

of safety features (such as seatbelts and control

interlock systems) was identified as the direct cause of

20% of these incidents, with all but one resulting in a

fatality. Three cases are described below:

Case 1:

An employee was working alone, operating a skidsteer loader for “fine grading” or smoothing out dirt to

provide the final contouring around a new home that

was nearing completion. While operating the skidsteer loader, one of the bucket bolt pins, which

connects the loader arm to the bucket, fell out. The

employee dismounted the vehicle with the engine still

running, manually lowered the lap bar safety device,

and operated the hydraulic controls from outside the

vehicle. The employee was attempting to realign the

loader arm hole with the bucket hole and reinsert the

bucket bolt pin. In the process, he was trapped

between the bucket and the body of the skid-steer

loader and was crushed. The employee was found in a

position that allowed him to operate the controls from

outside the vehicle with the bucket bolt pin and a large

hammer nearby.

Upon inspecting the skid-steer loaders on this job site,

the following conditions were noted:

· The interlock control system was disabled on

the unit involved in the accident. This system

was intended to prevent the loader’s controls

from operating unless the operator was in the

proper operating position. The absence of the

operator’s weight should have deactivated an

electronic switch under the seat that allows the

loader controls to function when the lap bar is

also in a lowered position. The system ensures

that the engine stops when the operator leaves

the seat of the skid-steer loader or attempts to

lower the lap bar to operate the loader

controls from outside of the skid-steer loader.

· Interlock control systems on other skid-steer

loaders on site had also been disabled or were

not functioning properly. This condition

allowed the operator to activate the loader’s

controls with the seat bar in the raised

position.
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· Backup alarms did not work on some units.

· Seatbelts had been removed from the skidsteer loaders.

The employer received a citation for a serious

violation under the General Duty Clause of the

Occupational Safety and Health Act (OSH Act)

(Section 5(a)(1)).

Case 2:

An employee was ordered by his company to repair a

leak in the hydraulic slave cylinder of a skid-steer

loader. He drove the skid-steer loader into the

warehouse and began the repair. He bypassed the

safety bar by jamming it into the interlocks without

being seated in the cab. He then started the skid-steer

loader and raised the bucket over the cab. Upon

exiting the cab, his foot inadvertently pressed the

down pedal for the bucket. The bucket came down

and trapped him between the lift and the cab. He then

hit the left side lever, causing the skid-steer loader to

move in reverse. It crashed into a parked forklift and

he was killed.

Upon investigation, the three causes of the accident

were identified as:

· Employee’s intentional bypassing of the safety

features of the skid-steer loader to perform

maintenance,

· Failure to use an approved lift arm support

device, and

· Improper employee training on operating,

servicing, or maintaining the skid-steer loader

according to the manufacturer’s instructions.

The employer received a citation for a serious

violation under the General Duty Clause of the OSH

Act (Section 5(a)(1)).

Case3:

An employee at a tractor implement dealership was

cleaning debris from a wash bay using a skid-steer

loader. This particular skid-steer loader was

equipped with a manual seat bar as well as a pressure

switch in the seat to detect the presence of an

operator. The operator was able to leave the cab to

wash the skid-steer loader bucket while it was still

operational. The bucket was left sitting on its nose

which prevented the loader arms from resting against

the body of the vehicle as it was designed to do. This

position made it difficult to enter and exit the cab. As

the employee attempted to get back into the cab, he

slipped and fell face-first into the cab seat. The loader

arms dropped and caught him between the body of

the skid-steer loader and the loader arms, and he was

killed.

The two major contributing factors to this accident

were:

· Employee’s intentional bypassing of the safety

systems of the skid-steer loader, and

· Improper employee training on the safety

features associated with the skid-steer loader.

“On-the-job” training did not include a review

of the operator’s manual.

The employer received a citation for a serious

violation under the General Duty Clause of the OSH

Act (Section 5(a)(1)).

Conclusion

Properly maintained and functioning seatbelts and

control interlock systems are critical to the safe

operation of skid-steer loaders. Field reports have

shown injuries and fatalities can occur by operating
skid-steer loaders with one or both of these safety

systems bypassed, disabled, or improperly

maintained.

OSHA Requirements

While OSHA does not have a standard requiring

employers to use control interlock systems or

seatbelts on skid-steer loaders, it is important for

employers to understand that under the General Duty

Clause of the OSH Act (section 5(a)(1)), employers

must provide their employees with a workplace free

from recognized hazards likely to cause death or

serious physical harm. OSHA may cite an employer

for a violation under the General Duty Clause if

recognized hazards exist and the employer does not

take feasible, effective measures to abate such

hazards.

OSHA takes the position that an employee who

moves from the proper position on a skid-steer loader

while it is energized, by doing such activities as

performing maintenance or repair operations, creates

the recognized hazards of crushed-by and/or caught

in-between. The failure to use seatbelts also increases

the risk of employee injury in the event of rollover. [1, 2]

Employers may abate these hazards by, among other

things, communicating and effectively enforcing work

rules prohibiting employees from disabling or

bypassing safety equipment, including safety interlock

systems, and requiring employees to use seatbelts at

all times when operating a skid-steer loader.

When equipment such as a skid-steer loader is used in

construction activities, 29 CFR 1926.20(b)(2)

requires construction employers to develop safety and

health programs that provide for frequent and regular

inspections by competent persons designated by the

employee of 1) the job sites, 2) materials, and 3)

equipment. In addition, 29 CFR 1926.21(b)(2)

requires construction employers to instruct employees

in the recognition and avoidance of unsafe conditions

and the regulations applicable in their work

environment to control or eliminate hazards or other

exposures to prevent illness and injury.

If skid-steer loaders are used in situations covered by

29 CFR Part 1910, then the requirements of OSHA’s

Control of Hazardous Energy (lockout/tagout)

standard, 29 CFR 1910.147, may be applicable.

Such situations may include, but are not limited to, use

of skid-steer loaders in warehousing operations or

servicing and maintenance performed on skid-steer

loaders in maintenance facilities.

Safety Practices

The following practices will minimize hazardous

situations associated with operating and maintaining

skid-steer loaders:

· Always read and understand the operator’s

manual before using the piece of equipment.

Always follow the manufacturer’s

recommendations and specifications when

operating it.

· Always lower the bucket or attachment so

that it is flat on the ground. Do not attempt to

activate the skid-steer loader’s controls from

outside the operator’s compartment.

· Do not leave the operator’s seat while the

engine is on. Never attempt to activate the

controls unless properly seated with the

seatbelt fastened and the seat bar (if

equipped) lowered. Keep all body parts

inside the cab while operating a skid-steer

loader.

· Never modify, bypass, disable, or override

safety systems. Similarly, never operate

equipment in which safety systems have been

modified or are not working properly.

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Services, Inc. Guidelines for ROPS on pneumatic

compactors and “skid steer” equipment. (March 16)

2. OSHA-McQuade. 1998. Letter of Interpretation

addressed to Brian McQuade, Laborer’s Health and

Safety Fund of North America. ROPs/seatbelts for

roller compactors; lockout/tagout in construction.

(March 16) http://www.osha.gov/pls/oshaweb/

owadisp.show_document?p_table=INTERPRETATIONS&p_id=22547

3. OSHA-Roth. 2003. Letter of Interpretation

addressed to Joel Roth, Southfield, MI.

Requirements to use seatbelts during the operation of

earthmoving equipment. (December 15)

http://www.osha.gov/pls/oshaweb/

owadisp.show_document?p_table=INTERPRETATIONS&p_id=24902

4. The Morbidity and Mortality Weekly Report

(MMWR) is prepared by the Centers for Disease

Control and Prevention (CDC). The data in the

weekly MMWR are provisional, based on weekly

reports to CDC by state health departments. http://

www.cdc.gov/mmwr/preview/mmwrhtml/00043153.htm

5. NIOSH Fatality Assessment and Control

Evaluation (FACE) Program. The FACE program

concentrates on investigations of fatal occupational

injuries. The primary intent of this program is to

provide interested users with access to the full text of

hundreds of fatality investigation reports. http://

www.cdc.gov/niosh/face/stateface/mi/04mi176.html

6. NIOSH Alert, Preventing Injuries and Deaths from

Skid Steer Loaders. http://www.cdc.gov/niosh/

skidalt.html

· Equipment with modified or malfunctioning

safety systems should be taken out of service

until repaired or replaced.

· Never permit riders on the skid-steer loader,

in the bucket or attachment, or in the

operator’s compartment unless the

compartment is designed to accommodate a

second rider.

· Always keep bystanders a safe distance away

from the work area.

· Establish a routine maintenance and inspection

program in accordance with the

manufacturer’s recommendations. Inspect the

skid-steer loader to ensure that all safety

systems are functioning properly prior to

operating the equipment.

· Follow the manufacturer’s instructions for

maintaining the skid-steer loader. Never

attempt maintenance or other work while lift

arms or attachments are raised without using

an approved lift arm support device. Replace

protective guards and shields after repairs or

service.

· Train personnel on the proper inspection, use,

maintenance, and repair of skid-steer loaders

according to the manufacturer’s instructions.

Train supervisory personnel to identify

hazards, such as safety systems that have been

bypassed, disabled, or that require

maintenance.

References and additional information

1. OSHA-Beisel. 1998. Letter of Interpretation

addressed to Robert Beisel, Hazard Recognition

http://www.osha.gov/pls/oshaweb/

owadisp.show_document?p_table=INTERPRETATIONS&p_id=22546

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