Date: Sep 25, 2014
Proposed Regulation for Tractor-Mounted Personnel Transport Carriers

The California Occupational Safety & Health Standards Board (Cal/OSHA) has distributed a proposed regulation for the use of agricultural personnel transport carriers (PTCs).  PTCs have been used for many years to transport workers in operations involving the installation and removal of irrigation piping.  But their use came under scrutiny in 2012 when former Division of Occupational Safety and Health (DOSH) Chief Ellen Widess required agricultural operations to apply for and obtain a variance permitting use of the carriers or face citations carrying steep fines for operating them without a variance.

In response to a consolidated petition requesting that the Board develop general safety standards related to the use of PTCs, the Standards Board convened an advisory committee last May consisting of stakeholders, including Western Growers staff, to discuss a draft proposal.  The Standards Board has now distributed a revised draft proposal that was developed out of the meeting to committee members for their comment.  A final proposal will be considered at a future public hearing.

General Industry Safety Orders §3441 prohibits riders on agricultural equipment such as tractors, other than the operator and others needed for assistance or training. The draft proposal creates an exception for PTC use.

Below is a brief summary of the current draft proposal:

  • Use of PTCs would be limited to employees installing, removing or maintaining irrigation pipe for low-lying row crops.
  • PTCs must use ASTM Grade B steel tubing or better; other structural elements must meet the specifications of ASTM A36 for structural steel; and welding or repairs must meet specified standards; and the design must be approved for their intended use by a qualified person for structural integrity and design.
  • PTCs must be equipped with: approved seat belts and seat cushions; steps and handholds so that employees can maintain three-point contact while entering and exiting the platform; a door, gate or safety chain at passenger entry/exit points. PTCs would also have to be equipped with an “effective and reliable” means by which passengers can communicate with the tractor operator.
  • Speed would be limited to five miles per hour. Employees would be required to exit the carrier whenever the tractor reaches the end of the row, and reenter after the tractor completes the turn.  Passengers also would not be permitted to ride on the carrier when the tractor is within 10 feet of a ditch, canal, retention pond, or other location that present an overturn hazard.
  • TPC safety training for all employees using PTPs, including tractor operators, would be required before the initial use and at least annually thereafter.

WG Staff Contact

Jason Resnick
Vice President & General Counsel

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