U.S. Department of Labor
Occupational Safety and Health Administration
Directorate of Technical Support and Emergency Management
Office of Science and Technology Assessment
Hazards Associated with Operating Skid-Steer Loaders with Bypassed and/or Improperly Maintained Safety Devices
Safety and Health Information Bulletin
SHIB 01-12-2009
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.
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 skid-steer
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.
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 skid-steer
loader for "fine grading" or smoothing out dirt to
provide the final contouring around a new home that
was nearing completion. While operating the skid-steer
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.
Backup alarms did not work on some units.
Seatbelts had been removed from the skid-steer
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)).
Case 3:
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.
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.
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.
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.
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