"Did you see the new MSHA Program Information Bulletin No P10-04? It deals with Safe Access, Fall Prevention and Fall Protection involving self-propelled mobile equipment. It appears to now give recognition to compliance with the ISO 2867 and SAE J185 standards as "providing safe access, fall prevention and fall protection" and says that operators are responsible for providing documentation to verify that the equipment is ISO 2867 certified. Most of the equipment now being cited by MSHA (under either the railings or fall protection standards) is compliant with this, as the work platforms are less than 2 meters high off the ground. The equipment manufacturers' materials should verify such certification. It also says that modifications to such equipment should not be made without an engineering evaluation and concurrence by the manufacturer.

So, it would appear, the many citations now under contest issued against equipment that is ISO-compliant should be vacated. Please spread the word. We have more than a half-dozen such cases and are trying to reach the various CLRs and solicitors to see if they will stand behind the new MSHA policy. The PIB is attached."

Adele L. Abrams, Esq., CMSP


ISSUE DATE: 06/16/10
FROM: NEAL H. MERRIFIELD Acting Administrator for Metal and Nonmetal Mine Safety and Health
SUBJECT: Safe Access, Fall Prevention and Fall Protection involving Self-Propelled Mobile Equipment
This Program Information Bulletin (PIB) applies to Safety and Health Administration (MSHA) enforcement personnel, underground and surface mine operators, and independent contractors.
This PIB provides information on providing safe means of access, fall prevention, and fall protection to miners operating, conducting maintenance or service activities, or accessing work platforms of self-propelled mobile equipment.
Accessing, operating or maintaining self-propelled mobile equipment often requires activities such as climbing ladders, or walking on machinery surfaces which expose miners to hazard such as falls during all types of weather conditions. Modern mobile equipment is designed to minimize slip and fall hazards; but, large machinery, new and old, can require access at heights with a fall potential that can cause serious injury. The following precautions can reduce slip and fall accidents from mobile equipment.

Equipment should be inspected for icy, wet, or oily areas at the start of each shift and whenever conditions dictate. Before climbing on, off or around mobile equipment, footwear should be free of mud or other substances that could cause slipping.

Persons climbing on or off mobile equipment should face the machine. Both hands should be free for gripping the ladder, handrail, or handhold. When necessary, a cord, rope, or other line should be used to lift and lower lunch pails, thermos bottles, or tools.

Walkways should be no narrower than their original manufactured widths, constructed with slip-resistant surfaces, and securely attached. Unobstructed access should be provided to all areas of the machine where a person might travel.

Handholds or handrails should be within easy reach at critical locations.


In addition, equipment manufacturers may be providing safe access, fall prevention and fall protection by complying with ISO 2867, “Earthmoving Machinery – Access Systems” or SAE J185, “Recommended Practice for Access Systems for Off-Road Machines.” Any modifications to mobile equipment should generally not be made without an engineering evaluation and concurrence by the manufacturer of the equipment. Unsafe access and fall hazards from mobile equipment can be reduced by the use of:

  1. portable ladders and work platforms,
  2. safety belts or harnesses and lanyards utilizing suitable anchor points,
  3. man-lifts,
  4. mobile work stations,
  5. docking stations, and
  6. relocating service points to safe areas, e.g., installing extended grease lines.

Operators are responsible for providing documentation to verify that their equipment is ISO 2867 certified. Inspectors may use the certification documents in considering if safe access, fall prevention and fall protection is being provided.
What is the background of this bulletin?
Equipment manufacturers have asked for clarification of MSHA’s requirements for fall protection on mobile equipment.
What is the authority for this bulletin?
The Federal Mine Safety and Health Act of 1977, as amended, 30 U.S.C. § 801 et. seq.; and
30 C.F.R. §§ 56/57.11001; 30 C.F.R. §§ 56/57.11002; 30 C.F.R. §§ 56/57.11027; 30 C.F.R. §§ 56/57.15005
Who are the MSHA contact persons for this program information bulletin?
Metal and Nonmetal Mine Safety and Health
Safety and Health Division
Lawrence J. Trainor Jr. P.E., (202) 693-9644
E-mail: trainor.lawrence@dol.gov
Is this program information bulletin available on the Internet?
This bulletin may be viewed on the World Wide Web by accessing the MSHA home page (http://www.msha.gov) and choosing “Compliance Info” and “Program Information Bulletins.”
Who will receive the program information bulletin?
MSHA Program Policy Holders Underground and Surface Mine Operators
Underground and Surface Independent Contractors Special Interest Groups
Miners’ Representatives