Safety and Health Information Bulletin
Introduction
Skis-steer loaders (Figure 1) are manufactured with safety features to prevent unexpected or inadvertent movement of the loader arm and hydraulic when the operator is not in the cab. However, these safety features can be bypass, 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.
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 device;
- Alert employers and employees about the need to review and follow manufacturer instruction regarding the installation, use, testing, inspection, and maintenance of safety devices on skid-steer loaders;
- Emphasize the importance of conducting training on the proper use of skid-steer loaders.
Scope
This SHIB focuses on the seat belts and safety interlock system typically found on skid-steer loaders intended primarily for earth moving machine. Such vehicles are not covered by the requirements of OSHA's Powered Industrial Truck standard, 29 CFR 1910.178.
Background
Common safety feature 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 system (as shown in figure 2). The seat belt helps prevent the operator 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 System 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 control when the operator is not in the proper operating position (i.e.,seated)
Review of OSHA's Integrated Management Information System (IMIS) reveals that between 1997 and 2007, 100 accidents were recorded specially involving skid-steer loaders. The deliberate bypassing of safety features (such as seatbelts and control interlock system) was identified as the direct cause of 20% of this 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 pin and a large hammer nearby.
Upon inspecting the skid-steer loader on this job site, the following condition were noted:
- The interlock control system was disabled on the unit involved in the accident. This system was intended to prevent the loader's control 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 allow's 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 system on other skid-steer loaders on site had also 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.
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 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 lever 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 to move in reverse. It crashed into a parked forklift and he was killed.
Upon investigation, the three cause 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,
- Improper employee training on operating, servicing, or maintaining the skid-steer loader according to the manufacturer's instructions.
Case 3:
An employee at a tractor implement dealership was cleaning
debris from a wash bay by using a skid-steer loader. This particular skid-steer loader was equipped with a manual seat bar as well as a pressure switch 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 setting on its nose which prevented the loader arms from resting a against the body of the machine as it was designed to do. This position made it difficult to enter and exit the cab. As the employee attempted to get into the cab, he slipped and fell face-first into the cab seat. The loader arms dropped and cought him between the body of the skid-steerloader and the loader arms, and he was killed.
The two major contributing factors to this accident were:
- Employee's intentional bypassing of the safety system of the skid-steerloader,
- Emproper employee training on the safety feature associated with the skid-steer loader. "On-the-job" training did not include a review of the operator's manual.
The employer recieved a citation for a serious violation under the General Duty Clause of the Occupational Safety and Health Act (OSH Act) (Section5(a)(1)).
Conclusion
Properly maintained and functioning seatbelts and control interlock system are critical to the safe operation of skid-steer loaders. Field reports have shown injuries and fatalities can occurby operating the skid-loader 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 seatbelt 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 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 while it is energized, by doing such activities as performing maintenance or repair operations, creates the recognized hazard 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 others 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 skid-steer loader is used in construction activities, 29 CFR 1926.20(b)(2) requires contruction employers to develop safety and health programs that provides for frequent and regular inspection 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 regognition and avoidance of unsafe condition and the regulations applicable in their work environment to control or eliminate hazards or other exposure to prevent illness and injury.
If skid-steer loaders are used in situation 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 situation 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 situation associated with operating and maintaining skid-steer loaders:
- Always read and understand the operator's manual before using the piece of equipment. Always follow manufacturers recomendations and specifications when operating it.
- Do not leave the operator's seat while the engine is on. Never attemp to activate the controls unless properly seated with the seatbelt fastened and the seat bar (if equipped) lowered. Keep the body inside the cab while operating a skid-steer loader.
- Always lower the bucket or attachment so that it is flat on the ground. Do not attempt to activate the skid-steer loader's control from outside the operator's compartment.
- Never modify, bypass, disable, or override safety system. Similarly, never operate equipment in which safety system have been modified or not working properly.
- 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
- Follow the manufacturer's instruction for maintaining the skid-steer loader.
- Train personnel in the proper inspection, use, maintenance, and repair of skid-steer loaders according to the manufacturer's instruction.
- OSHA-Beisel. 1998. Letter of interpretation addressed to Robert Beisel, Hazard Recognition Services, Inc. Guidelines for ROPS on pneumatic compactors and skid-steer equipment. (March 16)
- OSHA-Roth. 2003. Letter of Interpretation addressed to Joel Roth, Southfield, MI. Requirements to use seat belts during the operation of earthmoving equipment. (December 15)
Watch the video of safety to avoid deaths from skid-steer loaders
WAIT FOR 5 SECS COUNTDOWN AT THE UPPER RIGHT CORNER OF YOUR SCREEN AND PRESS SKIP ADS
Skid-Steer Loader Safety by David W. Smith, Extension Safety Program, AGRELIFE Extension
Source: U.S Department Labor, Agri life Extension David W. Smith
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