OSHA Instruction CPL 2-1.22 September 27, 1996 Directorate of Compliance
SUBJECT: Logging Operations, Inspection Procedures and Interpretive
Guidance Including Twelve Previously Stayed Provisions
A. Purpose. This instruction establishes revised policies and
provides clarification to ensure uniform enforcement of the Logging
Operations Standard (29 CFR 1910.266). These policies and procedures have
been amended in part to clarify enforcement of the previously stayed
provisions of the standard.
B. Scope. This instruction applies OSHA-wide.
C. References. 29 CFR 1910.95, 29 CFR 1910.106, 29 CFR 1910.109, 29
CFR 1910.132, 29 CFR 1910.133, 29 CFR 1910.135, 29 CFR 1910.147, 29 CFR
1910.155, 29 CFR 1910.156, 29 CFR 1910.157, 29 CFR 1910.211, 29 CFR 1910.212,
29 CFR 1910.261, 29 CFR 1910.265, 29 CFR 1910.266, 29 CFR 1910.269, 29 CFR
1928.21, STP 2.22A CH-3 (Changes to the State Plan Policies and Procedures
Manual, February 27, 1990), CPL 2-1.19, Logging Operations, Inspection
Procedures and Interpretive Guidance, March 17, 1995, and CPL 2.103, Field
Inspection Reference Manual (F.I.R.M.), September 26, 1994, are referenced in
D. Action. Regional Administrators and Area Directors shall ensure
that the general inspection procedures and clarifications in this instruction
are followed, that compliance officers are familiar with the content of the
new standard, and that they are aware of the expiration of the administrative
stay of 12 provisions of the standard, of the corrections and technical
amendments to the standard published September 8, 1995.
E. Federal Program Change. This is a Federal Program Change which
impacts State Programs.
1. The Regional Administrator (RA) shall ensure that this change is
promptly forwarded to each State designee using a format consistent with the
Plan Change Two-way Memorandum in Appendix A, State Plan Policies and
Procedures Manual (SPM).
2. The RA shall explain the content of this change to the State
designee as required.
3. The State shall respond to this change within 70 days in
accordance with paragraph I.1.a.(2)(a) and (b), Chapter III of the
4. The State's acknowledgment shall include (a) the State's plan to
adopt and implement an identical change and (b) the State's plan to develop
an alternative, which is as effective, or the reasons why no change is
necessary to maintain a program which is as effective. The State shall
submit a plan supplement within six months in accordance with I.1.a.(3)(c),
Chapter III of the SPM.
5. The RA shall inform the State designees that this directive
incorporates the relevant provisions of the settlement agreement concerning
OSHA's logging operations standard that was recently signed with the
Equipment Manufacturers Institute (EMI).
6. The Regional Administrator shall review policies, instructions
and guidelines issued by the State to determine that this change has been
communicated to State compliance personnel.
F. Application. The standard applies to all logging operations
where trees are harvested regardless of the end use of the product. Logging
operations include, but are not limited to, the operations of marking (i.e.,
marking danger trees in areas being harvested and marking felled trees to be
cut to length), debarking, yarding, chipping, felling, limbing, bucking,
loading and unloading equipment and personnel to, from and between logging
sites, and other operations associated with felling trees and moving logs
from the stump to the point of delivery. The standard does not cover the
construction or use of cable yarding systems or the construction of roads or
trails to logging sites.
G. Effective Date of Requirements. The effective date for the
Logging Operations Standard was February 9, 1995, except for certain
provisions listed below, which were stayed until August 9, 1995, and later
extended until September 8, 1995.
Provision: General Subject:
(d)(1)(v) (Foot Protection--but only as it relates to
chain-saw resistance of foot protection) (d)(1)(vii) (Eye and Face
protection--but only as it relates to face protection) (d)(2)(iii)
(Annual Review and Approval of First-Aid kit Contents) (f)(2)(iv)
(Machine Operation on Slopes) (f)(2)(xi) (Discharge of Stored Energy
from Hydraulic and Pneumatic Storage) (f)(3)(ii) (ROPS Criteria)
(f)(3)(vii) (Lower Portion of Cab Enclosure) (f)(3)(viii) (Upper
Portion Enclosure with Mesh) (f)(7)(ii) (Secondary Braking
System--but only as it relates to parking brakes stopping a machine or
vehicle in the event the primary service brakes fail) (g)(1)
(Vehicle Maintenance--but only as it relates to employee-owned vehicles)
(g)(2) (Vehicle Inspection--but only as it relates to
employee-owned vehicles) (h)(2)(vii) (Backcuts--but only as it relates
to backcuts in trees being felled by the Humboldt cutting methods)
H. Background. The old Pulpwood Logging Standard applied only to
the harvesting of trees to be used for pulpwood. The Logging Operations
standard expanded coverage to provide protection for all logging employees,
regardless of the end use of the forest product that they are harvesting
(e.g., saw logs, veneer bolts, pulpwood, or chips).
1. The Logging Operations standard includes various requirements
for the provision, inspection and maintenance of equipment (e.g., personal
protective equipment, tools, vehicle requirements and machines) used in
performing logging operations. The standard incorporates performance
requirements that provide flexibility to employers in developing safety and
health programs to suit logging operations in all regions of the country.
The standard also requires employers to provide training for each employee
who has not been trained previously.
2. The employer is responsible for ensuring that employees can
properly and safely perform the work tasks and properly and safely operate
the tools, equipment, machines and vehicles used in their jobs.
3. The standard requires employers to maintain certification of
training which indicate the date of the training completion or, in the case
of previously trained employees, the date on which the employer determined
that prior training was adequate. In addition, the standard requires each
logging employee to have current first aid and CPR training (e.g.,
4. The Logging Operations standard addresses hazards unique to
logging operations in addition to hazards covered by other 29 CFR 1910
General Industry standards. It strengthened and clarified the requirements
of the previous standard. Compliance with this standard will significantly
decrease the number of injuries and fatalities resulting from logging
5. Many of the requirements included in the standard have been
directed at the most hazardous logging operations: felling, limbing, bucking
and yarding. Regional Administrators and Area Directors shall ensure that
inspections focus on these high hazard operations, giving particular
attention to observing whether safe work practices are being followed in
I. General Inspection Procedures. Not all provisions and paragraphs
are included in the Directive. Refer to the Compliance Directive for Logging
Operations CPL 2-1.19 published March 17, 1995, the Standard and its preamble
published October 12, 1994, and the notice correcting and amending the final
rule published on September 8, 1995, for further guidance on specific
subjects and on additional topics not covered here. The CSHO shall determine
whether the following items are in compliance with the revised standard.
J. Definitions and clarifications
1. Paragraph (c) - Definitions
a. Logging operations. This definition has been revised
to clarify that "marking" covered by the final rule includes only marking
that is done attendant to and at the same time as felling, cutting and moving
trees in a particular logging work site. Some marking operations include
marking danger trees and sizing and marking felled trees to be cut to length.
These particular marking operation inform loggers working in the area or on
the tract whether and how to cut trees.
(1) Marking activities which take place in advance of and
separate from the tree harvesting are not covered by the final logging rule.
Incidental marking of danger trees or wildlife trees at the same time tracts
of land are being marked also is not covered by the final rule because no
tree harvesting is undertaken in the area at this time. These preparatory
activities do not involve the hazards associated with logging
(2) OSHA has revised the definition of logging operation to
express more accurately its intention that logging operations cover the
transportation of machines, equipment and personnel between as well as to and
from logging sites.
b. Definition of Machine. OSHA has revised the final
rule to clarify that airplanes or helicopters are not machines covered by the
new logging operations rule.
c. Vehicle. Vehicles covered by the final rule include
only those cars, buses, trucks, trailers, or semi-trailers owned, leased or
rented by the employer and used for transportation of employees or movement
2. Paragraph (d) - General Requirements
a. Personal Protective Equipment. The final rule
requires that the employer provide, at no cost to the employee, appropriate
eye, face, head, hand and leg protection. The employer is not required to
provide logging boots for employees. The cost of logging boots may be borne
by employees. The employer must assure, however, that logging boots, as well
as all PPE provided by the employer, are worn by employees and are in
serviceable condition and meet the requirements of paragraph
b. Protective material may be damaged or destroyed in the
course of work (e.g., while stopping a chain saw). When only the outer
covers of the protective equipment have been penetrated, it does not
necessarily mean that the equipment is no longer serviceable. However, where
there are also cuts or tears in the protective material of the logging boot
or leg protection, such equipment is no longer in serviceable condition.
Such cuts and tears in the protective material compromise the ability of the
PPE to provide the level of protection which is necessary. In situations
where footwear and leg protection cannot be repaired it must be replaced with
PPE which is serviceable.
(1) Paragraph (d)(1)(iii) - Gloves. OSHA has revised the
requirement that employees handling wire rope wear hand protection to state
that any type of gloves or hand protection is permitted provided that it
provides adequate protection against puncture wounds, cuts and lacerations.
Employers may provide employees with cotton, leather or rubber gloves if such
gloves provide the type of protection required.
(2) Paragraph (d)(1)(iv) - Leg protection. Employees
must use leg protection constructed of cut-resistant material any time they
operate a chain saw. Chain-saw kickback and sudden cut-through, which are
major causes of chain-saw injuries, are not dependent on whether the chain
saw is used frequently or regularly by the operator. OSHA believes that a
feller, who operates a chain saw as a regular part of the job, and a logging
truck operator, who may operate a chain saw occasionally or incidentally to
operating a vehicle, both face a significant risk of injury when using a
chain saw. As such, leg and foot protection are required whenever an employee
is operating a chain saw.
(3) Paragraph (d)(1)(v) - Cut-resistant foot protection.
Employers shall assure that foot protection worn by each employee who
operates a chain saw, including rubber, caulk-soled and other slip-resistant
boots, is chain-saw cut-resistant.
(a) Material is deemed to be "chain-saw cut-resistant" if
it either provides enough resistance to give the employee time to react
before the chain saw cuts through the boot material or jams the flywheel and
chains, thereby causing the saw to stop.
(b) The chain-saw cut-resistant foot protection requirement
applies to all employees who operate a chain saw as a regular part of the
employee's job as well as incidental to the job. Based upon the hazards to
employees when they use a chain saw, OSHA requires that all employees who use
a chain saw be protected against foot injury, regardless of the frequency of
chain saw usage.
(c) The foot protection requirement is expressed in
performance terms. Nothing in the final rule requires a specific type of
construction of protective footwear, such as steel-toed logging boots.
Steel-toed boots meeting the foot protection requirements of ANSI Z 41-1991,
"American National Standard for Personal Protection-Protective Footwear,"
provide adequate protection for the toe. However, if the logging boots do
not have material to protect the rest of the foot from the chain-saw cuts
they do not comply with the final rule. The final rule requires that logging
boots for chain-saw operators provide cut-resistant protection for the foot,
not just the toe. Employees are free to use foot protection constructed with
other cut-resistant material to protect against chain saw
(4) Paragraph (d)(1)(vii) - Eye and Face protection. The
employer must assure that each employee who is at risk of eye and face injury
wear protection meeting the requirements of subpart I of Part 1910. For
example, some employees (e.g., machine maintenance employees), may only need
eye protection to guard against injury.
(a) In other logging operations such as, but not limited
to, chipper operations, and cutting limbs, branches and spring poles, face
protection must be worn because there is a potential for facial injury (e.g.,
flying wood, needles, and splinters; cutting limbs and springpoles; moving
through dense underbrush). For operations such as chipping, face protection
must meet the requirements of subpart I.
(b) For chain-saw operations, logger-type mesh face screens
may be worn even though most logger-type mesh face screens do not meet the
requirements of Subpart I. They do not comply with the referenced ANSI
standards, ANSI Z87.1-989 or ANSI Z87.1-1968 because they are not able to
pass the impact and penetration resistance tests required by the ANSI
standard. In chain-saw operations however, there is not the same hazard of
objects hitting the face screen at a high speed or penetrating through the
mesh openings. Mesh screens provide adequate protection to keep small limbs,
branches, and saplings from poking the employee's eye or cutting the
employee's face when the employee is moving through the woods, yet do not
restrict vision in wet weather or fog up. Face protection comprised of mesh
screens is readily available in the industry.
(c) Where both eye and face protection is necessary, and
the employee is provided with face PPE that protects both eyes and face, the
employee is not also required to wear separate eye
3. Paragraph (d)(2) First-aid kits
a. Paragraph (d)(2)(i) - Location of first-aid kits.
OSHA has revised the provision of the final rule specifying that first-aid
kits must be located at each active landing, and on each employee transport
vehicle. First-aid kits also must be readily accessible to each work site
where felling, limbing and bucking are being done.
(1) Where one of these cutting worksites is located more than
one-half mile, under optimal conditions, from another worksite, landing or
employee transport vehicle, a first-aid kit must also be provided at that
worksite. In these situations, the first-aid kits which are at the landing,
on the vehicle, or at other worksites are too distant to be considered
(2) Where conditions are not optimal, such as steep or
mountainous terrain, very muddy terrain, heavy brush, or snowy and icy
conditions, first-aid kits cannot be as far as one-half mile from a cutting
area and still be considered immediately accessible. Where such conditions
exist or are reasonably anticipated, the employer will have to evaluate their
severity in determining whether cutting operations need first-aid kits to be
located closer to the worksite.
b. Paragraph (d)(2)(iii) - Review of First-aid kits.
OSHA has amended the standard to indicate that annual review and approval of
first-aid kits by a health care provider is permitted but not required by the
standard. Each first-aid kit must contain at least the items listed in
Appendix A of the Logging Standard, which has also been revised, as discussed
c. Appendix A to 1910.266 - First-Aid Kit Contents
(mandatory) The final rule specifies the minimum contents of first-aid
kits that employers must provide. The minimum content list was developed in
conjunction with OSHA's offices of occupational medicine and occupational
health nursing. The final rule has been revised to delete tourniquets,
recordkeeping forms, pens, and diphenhydramine hydrochloride elixir or
capsules (i.e., Benadryl) from the mandatory appendix specifying required
The requirement that each first-aid kit contain blankets was
revised to indicate that each kit must, at a minimum, contain at least one
blanket. The final rule also requires that each first-aid kit contain a
splint. Examples of acceptable splints include wire, inflatable and air
d. Paragraph (i)(7)(i) - First-aid training. The final
rule requires that the employer assure that every employee performing logging
operations has first-aid and CPR training which is current. Employers are
not required to provide the training. Employers are free to require, as a
condition of employment, that new employees have or obtain a first-aid and
e. Paragraph (i)(7)(ii) - Frequency of first-aid
training. Employers must assure that each employee's first-aid and CPR
training remains current.
(1) The American Red Cross first-aid training program, which is
the most widely used program in the country, requires first-aid training
every three years and annual CPR training to maintain a current certificate.
The American Heart Association follows the same requirements for maintaining
current certification. The American Medical Association also recommends
following the training procedures established by the American Red Cross and
the American Heart Association. In addition, States may have established
minimum requirements for first-aid training certification.
(2) While OSHA is aware that some States only require CPR
training every two years to maintain a current certification (e.g., Idaho)
there are no States which permit CPR certificates to remain current for a
longer period. OSHA has revised the final rule to conform its retraining
requirements to the requirements established by State regulations and
organizations that provide first-aid and CPR certification training programs.
Therefore, as long as the employer assures that each employee has current
first-aid and CPR training which meet State requirements or the requirements
of certifying organizations, the employer is in compliance with the final
rule. To reflect this clarification, OSHA deleted paragraph (i)(7)(ii) of
the final rule and redesignated paragraph (i)(7)(iii) as paragraph
4. Paragraph (d)(5) - Environmental Conditions
a. The final rule requires that work terminate and employees
move to a place of safety when environmental conditions create a hazard for
an employee. OSHA has revised the final rule to indicate that hazardous
environmental conditions include strong winds which may adversely affect the
fall of a tree.
b. Fire is also identified as a hazardous environmental
condition. However, the standard, read in its entirety, does not require
employees to leave the area any time a fire starts. Other requirements of
the standard contemplate that an employee may be called upon to put out a
fire. However, if a fire were to start in an area where there is no fire
extinguisher or other equipment or supplies which allow the employee to
safely suppress it, the employer would be responsible for assuring that
employees are moved out of the danger area. Likewise, where a fire, because
of its size, intensity or the conditions of the area, creates a hazard for an
employee who remains in the area, either to work or to attempt to suppress
the fire, the employer must also assure that employees are removed from the
area of danger instead of trying to extinguish the fire. The standards on
fire protection in Subpart L of Part 1910 and not the Logging Operations
standard govern the fighting and suppression of fires at logging
5. Paragraph (d)(6) - Workareas
a. Paragraph (d)(6)(iii) - Working within visual or audible
contact. This provision of the final rule applies to each employee
working at a logging worksite, including watchmen and other employees
performing logging operations at remote logging worksites. The final rule
has been revised to indicate that the requirement does not apply to vehicle
operators who are not at the logging site, but only to vehicle operators
while they are at a logging worksite.
b. Paragraph (d)(6)(iv) - End of workshift accounting of
employees. The final rule requires that the employer account for each
employee at the end of each workshift. The employer need not personally
conduct the actual end of shift accounting of each employee, but may delegate
this task. The employer remains ultimately responsible under the standard
for assuring that employees are not inadvertently left in the
c. The standard does not require employers to prohibit
employees from remaining at the work site after the end of the work shift to
engage in personal activities, such as hunting, camping, or cutting fire wood
for personal use. Rather, OSHA's intent is to assure that no employee,
particularly an injured employee, be inadvertently left in the woods without
After the workshift has ended and the employer has ascertained
that the employee is done with work, including overtime work, and is safely
accounted for, the standard does not prohibit the employer from allowing
employees to remain in the area for personal reasons.
6. Paragraph (d)(9)(i) Flammable and Combustible Liquids
a. Paragraph (d)(9)(i) - Storage and handling of flammable
and combustible liquids. The standard requires that flammable and
combustible materials be stored, handled and transported in accordance with
the requirements of subpart H of Part 1910.
Subpart H permits Class IB liquids, which OSHA interprets as
including chain-saw fuels, to be carried in safety cans approved by
Underwriters Laboratories (UL) or Factory Mutual (FM). Safety cans which are
permitted under subpart H are further defined as containers approved by a
nationally recognized testing laboratory (NRTL), which do not hold more than
5 gallons capacity, have a spring-closing lid and spout, and are designed to
safely relieve internal pressure when subjected to fire exposure. This
definition is broad enough to include plastic safety cans, provided that such
containers are approved by a NRTL as meeting the other requirements of the
b. Paragraph (d)(9)(iii) - Machine Fueling. The Logging
Operations standard has been revised to permit diesel-powered machines and
vehicles to be fueled while idling, provided that continued operation is
intended and that the employer follows safe fueling and operating procedures.
OSHA is permitting this exception because the hazard which this provision
seeks to address, sudden flash fires, is typically not present during fueling
of diesel-powered engines because diesel fuel has a higher flash point than
that of gasoline, and unlike gasoline its vapors do not evolve as suddenly.
Therefore, it is unlikely that a fire will erupt during fueling of
At the same time, however, OSHA is requiring that other
safe-fueling and operating procedures be followed during fueling of
diesel-powered machines. Employers must train employees in safe practices
during fueling. These include vapor containment, spill prevention, and
procedures the operator must follow before leaving the machine cab to fuel
c. Paragraph (d)(9)(iv) - Starting Fires. OSHA has
revised the final rule to allow flammable and combustible liquids, such as
chain-saw and diesel fuel, to be used in certain conditions to start a fire.
OSHA believes that this flexibility will allow piles of wood or slash to be
burned when permitted by forestry officials.
(1) However, the revised provision does not permit flammable
and combustible liquids to be used whenever a fire is needed. The revised
provision only permits such liquids to be used where the employer assures
that their use does not create a hazard for an employee.
(2) Employers must train employees to know under what
conditions it is safe to start a fire with chain-saw fuel and in what
situations using fuel may create a hazard for an employee. For example,
using chain-saw fuel to start a fire in an enclosure is not safe and is not
permitted. There are other ways to start fires where chain-saw fuel may
create a hazard, for example, light-weight fire starters made of sawdust and
7. Paragraph (e) - Hand and portable powered tools
a. Paragraph (e)(2)(i) - Chain brakes. Each chain saw
placed into initial service after February 9, 1995 must be equipped with a
chain brake. In addition, each chain saw shall meet the chain saw brake and
other performance and safety requirements of the ANSI B175.1 - 1991 "Safety
Requirements for Gasoline - Powered Chain Saws." No chain-saw kick back
device shall be removed or otherwise disabled.
A chain-saw manufacturer challenged the chain-brake provision
and requested the U.S. Court of Appeals for the Fourth Circuit to stay the
provision. The court denied the petition for review and upheld the
chain-brake provision. (Homlite v. OSHA, No. 94-2588, Decided January 17,
b. Paragraph (e)(2)(iv) - Refueling chain saws. The
final standard has been revised to require that chain saws be fueled and
started at least 10 feet from any open flame or source of ignition and
fueling area. A 10-foot distance provides adequate ventilation in both
situations because outdoors, where constant air movement dissipates vapors,
it is unlikely there could be a concentration of flammable vapors beyond 10
c. Paragraph (e)(2)(vi) - Starting chain saws. The
final rule requires that chain saws be started on the ground or where
otherwise firmly supported. The final rule has been revised to state
explicitly that drop starting chain saws is prohibited.
Nothing in the final rule prohibits an employee from standing
upright when starting a chain saw, provided that the employee has firmly
supported or secured the chain saw. For example, a chain saw operator would
be in compliance if he or she rested the chain saw firmly on a log or other
stationary item and started the chain saw while standing
d. Paragraph (e)(2)(xii) - Carrying chain saws. The
final rule requires chain-saws to be carried in a manner that will prevent
employee contact with the cutting chain and muffler. There are devices
currently available and used in the logging industry to prevent cuts and
burns while carrying a chain saw, including leather and felt shoulder pads.
These devices are not required by the final rule.
e. Paragraph (e)(2)(xiii) - Retreating with chain saws.
The final rule has been revised to require that the chain saw be shut off or
the throttle released before the feller begins his retreat. The feller is
not required to remain next to the tree waiting for the chain saw to idle
down before retreating a safe distance from the falling tree. Rather, as soon
as the feller releases the throttle, placing the machine into idle, he should
immediately move on the retreat path a safe distance from the falling
8. Paragraph (f) Machines
a. Paragraph (f)(2)(iv) Machine Stability - To maintain
stability, the employer must assure that each machine is operated within the
limitations imposed by the manufacture as described in the operating and
maintenance instructions for the machine.
There are many ways in which an employer can accomplish this
obligation. Manufacturers' operating instructions can be incorporated into
operator training programs. Compliance with these operating instructions can
be reinforced during regular safety and health meetings, and through spot
checks on employees' operating performance.
b. Paragraphs (f)(2)(x) and (xi) - Machine shutdown
procedures. Paragraph (f)(2)(xi) of the final rule has been revised to
require that the hydraulic and pneumatic energy storage devices that can move
elements of a logging machine even after the machine has been shut down must
be discharged as specified by the manufacturer.
Paragraph (f)(2)(x) of the final rule has been revised to
require that any time the operator leaves the machine cab brakes must be
applied, the moving elements must be grounded or secured, and the
transmission must be placed in the manufacturer's specified park
c. Paragraph (f)(3)(i) - Protective structures for logging
machines. OSHA has revised the final rule to require that the following
logging machines placed into initial service after February 9, 1995 have FOPS
and/or ROPS: tractors, skidders, swing yarders, log stackers, log loaders and
mechanical felling devices, such as tree shears or feller
d. Paragraph (f)(3)(ii) - ROPS specifications. OSHA has
revised the final rule to require that logging machines manufactured after
August 1, 1996, be equipped with rollover protection structures (ROPS) that
are tested, installed and maintained in accordance with the Society of
Automotive Engineers (SAE) J1040, April 1988, Performance Criteria for ROPS
for Construction Earthmoving, Forestry and Mining Machines.
(1) The final rule also requires that ROPS and FOPS, which are
required on logging machines placed into initial service after February 9,
1995, must also meet the requirements of SAE J397, April 1988, "Deflection
Limiting Volume - ROPS/FOPS Laboratory Evaluation." The 1988 standard
updated a 1979 SAE standard on deflection limiting volume. There is no
significant functional difference between the criteria of the 1988 and 1979
SAE standards. Therefore, ROPS and FOPS certified to meet the requirements
of either the 1988 or 1979 SAE standards shall be deemed to be in compliance
with the final logging standard.
(2) OSHA will collect and distribute a list of model numbers of
machines that will show, with respect to manufacturers who, as of July of
1994, were making equipment not complying with the ROPS requirements of J1040
April 1988, the last model number or serial number on noncomplying equipment
they manufactured or, if as of August 1, 1996, they are still manufacturing
such equipment, the latest serial number of such equipment manufactured on or
before August 1, 1996.
e. Paragraph (f)(3)(vii) and (viii) Machine cab
enclosures. OSHA has revised the final rule to require that logging
machines manufactured after August 1, 1996, shall have cabs which are
completely enclosed, including entrances (paragraph (f)(3)(viii). The
machine cab may be enclosed either with mesh material (with openings no
greater than 2 inches (5.08 cm) at its least dimension) or with other
material(s), provided the employer demonstrates that the alternative provides
visibility and protection from penetrating objects which is equivalent to
(1) For those logging machines manufactured on or before August
1, 1996, paragraph (f)(3)(viii) provides that such machines may either comply
with paragraph (f)(3)(vii) or be equipped with a protective canopy for the
operator which meets the following requirements:
a. The protective canopy shall be constructed to protect
the operator from injury due to falling trees, limbs, saplings or branches
which might enter the compartment side areas and from snapping winch lines or
b. The lower portion of the cab shall be fully enclosed
with solid material, except at entrances, to prevent the operator from being
injured from obstacles entering the lab;
c. The upper rear portion of the cab shall be fully
enclosed with open mesh material with openings of such size as to reject the
entrance of an object larger than 2 inches in diameter. It shall provide
maximum rearward visibility; and
d. Open mesh shall be extended forward as far as possible
from the rear corners of the cab sides so as to give the maximum protection
against obstacles, branches, etc., entering the cab area.
(2) If the cab enclosure or any other item is attached to a
ROPS, the attachment shall not affect the function or performance of the
(3) Materials that satisfy the performance criteria of the
Society of Automotive Engineers SAE J1084, April 1980, "Operator Protective
Structure Performance Criteria for Certain Forestry Equipment" are deemed to
comply with the Logging Operation standard.
NOTE: OSHA intends the term "cab" to include any machine
operator station, even if it is not a total enclosure providing weather and
f. The employer must assure that any machine used for logging
operations is in compliance with the other provisions of paragraph (f)(3).
For example, all machines used in logging operations must have two means of
egress. To the extent that any machine in service does not have a second
means of egress, the machine must be retrofitted (e.g., replacing the
stationary windowshield with a hinged window to allow egress) or removed from
9. Paragraph (f)(7)(ii) - Machine brakes
a. Logging machines placed into initial service after September
8, 1995, must be equipped with three braking systems - service brakes,
secondary brakes that are sufficient to stop the machine in the event the
service brakes fail, and parking brakes.
b. Some older machines were manufactured with primary brakes,
but without secondary or parking brakes. OSHA is permitting these older
machines to remain in use, provided that the employer assures the primary
brakes are inspected and maintained at their designated level of
effectiveness (i.e., are sufficient to stop and hold the machine and its
rated capacity on the slopes over which it is being operated).
c. Logging machines with braking systems meeting the following
Society of Automotive Engineers (SAE) or International Standards Organization
(ISO) standards are deemed to be in compliance with the final rule, provided
that the employer assures that such braking systems are maintained in a
SAE J1026, April 1990, "Brake Performance - Crawler Tractors
And Crawler Loaders"
SAE J1178, June 1987, "Braking Performance - Rubber Tired
SAE J1473, October 1990, "Brake Performance - Rubber Tired
SAE J1178/ISO 11169, December 1994, "Machinery for Forestry
- Wheeled Special Machines - Vocabulary, Performance Testing, and Criteria
for Brake Systems"
ISO 11512, March 1995, "Machinery for forestry - Tracked
Special machines - Performance criteria for brake
ISO 3450, November 1985, "Earth moving machinery - Wheeled
machines - Performance requirements and test procedures for braking
10. Paragraph (g) Vehicles
a. Paragraph (g)(1) and (2) - Maintenance and inspection of
vehicles. OSHA has revised the final rule to cover only those vehicles
owned, rented, or leased by the employer. Therefore, vehicle inspection and
maintenance requirements do not apply to employee-owned vehicles. However,
OSHA notes that the employer has the duty to provide safe access to the
b. With regard to inspections of equipment (e.g., vehicles,
PPE, tools, and machines) covered by the final rule, OSHA never intended that
the employer must conduct the actual inspection of the equipment. Employers
may assign to others, including employees using the items, performance of the
required inspection and maintenance procedures for equipment, but ultimately
the employer remains responsible for safe equipment at the
c. The inspection requirements for equipment in the final rule
apply only if the equipment is used during the workshift. If it is not to be
used, it does not need to be inspected.
11. Paragraph (h) Tree Harvesting
a. Paragraph (h)(1)(ii) - Unfamiliar or unusually hazardous
conditions. The final rule requires that employees contact their
immediate supervisor for approval when unfamiliar or unusually hazardous
conditions are encountered before cutting is commenced.
(1) Certain situations are clearly covered by this paragraph,
including worsening weather conditions which begin to impair the logger's
vision; deepening snow or mud which begins to affect a logger's mobility;
felling very large or very tall trees; cutting trees whose lean, structure,
or location make it difficult to fell in the desired or safest direction; and
using a driver tree to fell a danger tree.
(2) It is also important that employers train their employees
that when they encounter situations with which they have not dealt with
before, they need to work with the supervisor to handle the situation. This
concept should also be reinforced in regular safety and health
b. Paragraph (h)(1)(iii) - Felling distances. The
standard requires that while manual felling is in progress, yarding machines
shall not be operated within two tree lengths of trees being manually felled.
OSHA has revised the final rule to clarify that this requirement does not
apply to tree pulling operations where tree pulling and other team operations
c. Paragraph (h)(1)(ix) - Domino felling. The standard
prohibits domino felling. Domino felling is defined in the final rule as
"[tlhe partial cutting of multiple trees which are left standing and
then pushed over with a pusher."
(1) OSHA has revised the final rule to clarify that the
definition of domino felling does not include the felling of a single
tree with a another tree. The domino felling that is prohibited in the final
rule is the felling of multiple trees with another
(2) The practice of felling a danger tree by felling another
one into it, while not prohibited in general, is not automatically permitted
to be used whenever a danger tree is felled. Paragraph (h)(1)(vii) of the
standard also requires that where a danger tree is felled or removed, the
feller must use a technique that "minimize[s]" employee exposure to the
hazard. In some cases, felling a danger tree by felling another tree into it
will not minimize employee exposure to the hazards, but rather may increase a
risk the feller faces in removing the danger tree. In such circumstances,
safer method to remove a danger tree is to pull the tree down with a skidder
or mechanical feller.
(3) OSHA permits a danger tree to be felled in this manner only
where a careful examination of mechanical techniques is made first and where
it is also determined that the hazards of felling the danger tree in this
manner can be sufficiently minimized.
d. Paragraph (h)(2)(i) - Retreat paths. The final rule
requires that before a feller begins cutting a tree a retreat path must be
planned and cleared. OSHA has revised the final rule to state that once the
backcut has been completed the feller must immediately move to a safe
distance away from the tree on the retreat path.
e. Paragraph (h)(2)(iv) - Spring poles. The standard
requires that when a spring pole or other tree under stress (hereafter
collectively referred to as spring poles) is cut, no employee other than the
feller shall be closer than two tree lengths when the stress is
(1) Spring poles are danger trees and the requirements of
paragraphs (h)(1)(vi) and (vii) must be followed to minimize exposure to
hazards when felling danger trees. These requirements include felling danger
trees by using mechanical means or other methods that minimize employee
exposure to the hazards associated with the danger tree. Any employee
cutting spring poles must have his body and chain saw in the clear when the
stress in the spring pole is released.
(2) Because of the inherent dangers of spring poles, OSHA is
also stressing that only trained workers are allowed to fell spring poles
(paragraph (i)). This training includes recognition of the hazard associated
with spring poles (i.e., extreme stress on the entire tree), as well as the
methods for dealing with spring poles. This training should stress that the
preferred method of dealing with spring poles is to avoid them where possible
(i.e., mark them and not work within two tree lengths of them), rather than
felling or removing them. However, if avoidance is not possible, training
should emphasize that the safest way to remove spring poles is by
(3) Where employees are trained in safe felling techniques for
spring poles and where the employer provides the necessary reinforcement of
safe work practices through regular safety and health meetings and spot
checks, the potential for death and injury in felling spring poles will be
f. Paragraph (h)(2)(vii) - Backcuts
(1) Open Face felling. OSHA has revised the final rule
to clarify that the requirements that backcuts be placed above the level of
the horizontal face cut does not apply to open face felling since there is no
horizontal face cut where this method is being used.
(2) In open face felling two facecuts are made diagonally into
the stem producing a notch that is very open (i.e., 70 to 90 degrees). The
openness of this notch allows the tree either to fall completely to the
ground, or to fall a much greater distance than in conventional cutting
before the notch closes and the hinge breaks.
(3) Where the tree is able to fall a greater distance before
pressure is placed on the hinge, the tree is more likely to fall in the
intended direction and is less likely to kick back off the stump when the
notch does close.
(4) Humboldt cutting The requirement that the backcut
be placed above the level of the horizontal facecut does apply when the
Humboldt cutting method is used. In the Humboldt cutting method, a horizontal
cut is made into the face of the tree and a notch is cut into the stump below
the horizontal cut at an angle. By contrast, in conventional felling, the
notch is cut at a diagonal above the horizontal facecut.
(5) In logging operations where the Humboldt method is most
heavily used, fellers most often only cut a notch no greater than 45 degrees,
making this method similar to that of conventional felling. Fellers do this
to keep the stumps as short as possible and thereby reduce the loss of wood.
At 45 degrees, however, the face notch alone does not fully address both the
hazards of misdirected falling and kickback.
(6) Proper backcuts that provide sufficient hinge wood are
critical. Sufficient hinge wood helps to hold the tree to the stump during
most of its fall and thereby allows the hinge to steer the falling tree in
the right direction. If the hinge is inadequate or if the pressure is placed
on the hinge, it will break too soon and the tree will be left without a
steering mechanism. Without the hinge wood, the tree may twist and bend, and
fall in the wrong direction.
(7) Placing the backcut above the horizontal face cut is also
necessary to provide a platform to block the tree from kicking back once the
hinge does break. Where there is potential that the face notch will close
before the tree hits the ground, which is the case with most cutting using
the conventional and Humboldt methods, this platform is necessary to prevent
kickback. Where the backcut is at the same level as the horizontal cut,
there is no platform to block the backward movement of the tree should
(8) OSHA has not specified in the final rule how far above the
face cut the backcut must be placed. OSHA believes that a backcut placed at
least one inch above the face cut creates an adequate platform to prevent
kickback and to allow the hinge to direct the falling of the tree. OSHA
believes that a one-inch platform would provide an adequate margin of safety
for the feller while still providing the contractor with a fairly square-end
NOTE: OSHA's decision to require that backcuts in Humboldt
cutting be above the horizontal face is based in part on the fact that most
loggers currently using this method are making the notch the same size as in
conventional felling--45 degrees. A 45-degree notch is generally not open
enough to control for both misdirected falling and kickback hazards.
However, where a notch of 70 degrees or greater is cut, the notch in Humboldt
cutting acts as it does in open face felling. As discussed above, in open
face felling, because of the 70-to-90 degree notch, it is unlikely that the
tree will fall in the wrong direction or kickback, due to the openness of the
notch rather than the type of cutting method being employed. Where the notch
is at least 70 degrees, it is not as critical that the backcut be above the
horizontal face cut or the notch of the face cut, regardless of whether the
open face or Humboldt method is being used.
g. Paragraph (h)(3)(i) - Bucking and limbing
(1) The final rule has been revised to require that whenever
rolling or sliding of the tree is reasonably foreseeable, bucking and limbing
must be done from the uphill side of the tree. The revised final rule does
not permit bucking and limbing to be done from the downhill side. Where a
tree cannot be limbed or bucked from the uphill side, the tree must be moved
to a stable position where there is no potential for the tree to roll or
(2) Because of the hazards associated with bucking and limbing
and the high injury rate in these operations, employees must be trained to
evaluate the following five potential hazards associated with limbing and
(a) Overhead hazards;
(b) Spring poles;
(c) Forward butt movement, to assess back pressure on
(d) Butt twist, to assess sideways pressure on limbs;
(e) Position of the butt of the tree in relation to the
ground, to assess tension in the tree stem.
(3) Paragraph (h)(5)(v) - Yarding. The final rule has
been revised to require that yarding lines not be moved unless the yarding
machine operator has clearly received and understood the signal. When in
doubt, the machine operator must repeat the signal and wait for a confirming
signal before moving the line. These requirements apply to all yarding
machines and not just yarders.
(4) Paragraph (h)(5)(viii) Hazardous Obstructions in
yarding. This final rule has been revised to require that yarding
machines and their loads be operated in a manner that prevents contact with
obstructions which could create a hazard for an employee. The types of
obstructions which are known to be hazardous include, but are not limited to,
boulders, danger trees, stumps, log piles, power lines, and cable
(5) Paragraph (h)(6)(ii) - Loading. The final rule
requires that only the machine operator and other essential personnel be
allowed in the work area during loading and unloading. The work area covered
by this provision is the immediate loading work area as opposed to the entire
logging work area (e.g., landing.)
(6) Loading/Unloading of Trees. The loading of trees at
the logging work site and loading/unloading of trees at trans-shipment points
such as satellite wood yards are covered by the final rule.
a. With regard to unloading logs at pulp, paper and
paperboard mills (hereafter pulp mills) and sawmills, OSHA has other
standards which address some of the hazards associated with such unloading
(See, Pulp, Paper and Paperboard Mills, 29 CFR 1910.261, and Sawmills, 29 CFR
1910.265). To the extent that certain hazards associated with unloading
trees are addressed by these other standards, they apply instead of the final
logging rule. For example, both the pulp mills and sawmills standards
include provisions specifying how binders and stakes must be released from
the load of logs. As such, the similar provision contained in the logging
final rule does not apply.
b. To the extent that the final logging rule addresses
hazards not covered by other standards, the logging rule applies. For
example, neither the pulp mills nor the sawmills standard addresses the
hazards faced by log truck operators who remain in their cabs during
unloading. Thus, paragraph (h)(6)(iii) applies to loading and unloading of
trees at pulp mills and sawmills as well as at logging sites and satellite
Joseph A. Dear Assistant
Distribution: National, Regional and Area Offices All Compliance Officers
State Designees NIOSH Regional Program Directors 7(c)(1) Consultation Project
Managers OSHA Training Institute