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Tree Care Operations Stakeholders Questions

The tree care stakeholder meeting on July 13 included discussion on a variety of issues involving tree care operations, including the topics that OSHA highlighted in the Federal Register notice announcing the meeting. The following include some questions on topics which OSHA sought input during the stakeholder meeting.

I. Fatalities and injuries. Fatalities in tree care operations primarily result from falls, being struck by falling objects or vehicles, and electrocutions.

What are the primary causes, circumstances and factors that have led to fall, struck by, electrocution and other fatalities and injuries in your company and in the tree care industry?

  1. Have those hazards resulted in any fatalities or injuries?
  2. What actions did you take and control measures did you implement in response to those incidents?
  3. Are there other hazards to which your employees are exposed during tree care operations? Please describe those hazards.
  1. What are the primary hazards and causes of fatalities/injuries for employees?
  2. What control measures and safe work practices has your company or the tree care industry implemented?
  3. What personal protective equipment (PPE) do you or other tree care employers provide for employees? (e.g., head, eye/face, hearing, hand PPE)?
  4. What fall protection systems (personal fall arrest systems, work position systems) do you provide for employees who work in trees and/or bucket trucks?
    1. What practices do you or other tree care employers follow to ensure fall protection systems are maintained in safe working condition?
    2. What are the best practices to prevent workers from inadvertently cutting climbing ropes and proposed/final lanyards?
  1. What are the primary hazards and causes of fatalities/injuries for employees who work in ground operations?
  2. What control measures and safe work practices have you or other tree care employers implemented to protect employees working in ground operations from those hazards, particularly struck by hazards?
    1. What controls and practices have you or other tree care employers implemented in "drop zones" to protect workers from falling objects (e.g., establishing safe retreat paths, not removing brush/branches from a drop zone while tree is still be trimmed/removed)?
    2. What controls and practices have you or other tree care employers implemented to protect workers who perform chipping operations?
  3. What PPE do you or other tree care employers provide for workers who perform tree care operations on the ground (e.g., head, eye/face, hearing, leg/foot, hand PPE)?
  1. If you conduct accident reviews, please describe what they involve.
  2. If you do a job hazard analysis, please describe what they involve.
  3. If you conduct training or briefing, please describe what that training/briefing involves.
  1. What factors/hazards do you or other tree care employers consider in planning/assessing how to trim or remove a tree?
  2. What factors/hazards do you consider in assessing whether it is safe to climb a particular tree? If it is not safe to climb the tree, what controls and methods do you deploy?
  3. What factors/ hazards do you consider in planning/assessing tree care operations that are performed on slopes and hills?
  4. What hazards/factors do you consider when planning/assessing storm cleanup work? What controls and safe work practices do you or other tree care employers implement to protect workers who perform post-storm tree care operations?
  1. What are the best communication systems/methods for use in tree care operations?
  2. What communications systems/methods do you or other tree care employers use to ensure non-English speaking workers understand information/directions being communicated?
  1. What equipment do you or other tree care employers use for responding to emergency situations, especially at remote locations?
New technology and new trends in the tree care industry.
  1. What new technology is used or available that eliminates the need of workers to be in the drop zone during tree trimming/removal operations?
  2. What new technology is used or available to protect workers when they climb and work in trees?
  3. What new technology is used or available to protect workers from being pulled into chippers?
  1. Please describe/explain how this new technology and eliminated/reduced hazards and prevented worker fatalities/injuries.
  2. What did this new technology cost?
  3. To what extent has this new technology reduced costs, increased productivity and/or increased flexibility for your company?
  4. If OSHA decides to develop a tree care standard, what new technology should it require employers to use? Please explain.
III. State-Plan State and national consensus standards.

There are ANSI standards applicable to tree care operations; ANSI Z133 Safety Requirements for Arboricultural Operations and the ANSI A300 Standards for tree care operations. In addition, five states have issued standards on tree care operations: California, Maryland, Michigan, Oregon, Virginia.

IV. Vehicles and mobile equipment.
  1. What are the safety advantages and/or hazards associated with using vehicles and mobile equipment in tree care operations?
  2. What controls and safety mechanisms are your vehicles and mobile equipment equipped with to protect operators and employees working with or near them?
  3. What safety practices have you or other tree care employers implemented in tree care operations that use vehicles and mobile equipment?
  4. What controls and work practices have you or other tree care employers implemented to protect employees working near mobile equipment, vehicles and roadway traffic?
  5. What practices do you follow to ensure that vehicles and mobile equipment are maintained in safe working condition?
  6. To what extent, if any, has the use of vehicles and mobile equipment reduced your costs and increased your productivity?
  1. In what type of tree care operations do you and other tree care employers use aerial lifts/bucket trucks?
  2. What percent of your tree trimming/removal operations use bucket trucks/aerial lifts instead of having employees work in trees?
  3. Has your use of bucket trucks/aerial lifts to perform tree care operations increased? Please explain the reasons for this increase.
  4. What factors do you consider in determining whether to use an aerial lift/bucket truck or have an employee climb the tree to trim/remove it?
  5. Please explain whether there are worker safety advantages to using an aerial lift/bucket truck to trim/remove a tree rather than climbing and working in the tree.
  6. Does the use of aerial lifts/bucket trucks to perform tree care operations expose workers (in the bucket or on the ground) to hazards? Please explain.
  7. What controls and work practices have you or other tree care employers implemented to eliminate/reduce hazards and protect workers who operate, work in or work near aerial lifts/bucket trucks?
  8. To what extent, if any, has the use aerial lifts/bucket trucks to perform tree care operations reduced your costs and/or increased your productivity?
  1. What factors do you consider in determining whether to use a crane to perform a tree care operation?
  2. What controls and practices have you or other tree care employers implemented to protect tree care workers who operate, work with or work near cranes?
  3. Please explain whether there are worker safety advantages to using a crane to perform tree care operations?
  4. Does the use of cranes to perform tree care operations expose workers (in trees or on the ground) to increased hazards? If so, what are those hazards and what controls and/or work practices have you or other tree care employers implemented to eliminate/reduce the hazards and protect workers from fatality/injury?
  5. What are the costs of using a crane to perform a tree care operations?
  6. To what extent, if any, has the use of cranes to perform tree care operations reduced your costs and/or increased your productivity?
V. Information and training.
  1. What first aid and cardiopulmonary resuscitation training do you and/or the tree care industry provide?
  2. What information and training do you provide to prevent workers from being struck by vehicular traffic?
  3. If OSHA decides to develop a tree care standard, what workplace safety and health information and training should a standard require that employers provide and what topics should it cover?
  1. Do you train all new employees before they begin work or only those new employees who have no previous experience or training in tree care operations?
    1. What do you do to ensure that new employees, including new employees who have previous training, are able to perform tree care operations safely before being assigned to perform work?
  2. What training do you provide for temporary workers (e.g., day laborers)?
  3. What training do you provide for employees who climb and work in trees?
  4. What training do you provide for workers who operate and/or work in bucket trucks/aerial lifts?
  5. What training do you provide for crane operators?
  6. What training do you provide for workers who operate other types of vehicles/mobile equipment/machines?
  7. What training do you provide for workers who operate chippers?
  8. What training do you provide to workers who operate chain saws?
  9. What training do you provide to workers who operate stump grinders?
  10. What training do you provide for "qualified arborists"?
  11. Which workers do you train in first aid/CPR?
  1. What is the average number of training hours, including refresher training hours, provided by your company for each tree care employee?
  2. Does your training require that workers demonstrate safe work practices before they are assigned to perform particular tree care operations (e.g., tree climbing)?
  1. How frequently do you provide refresher training?
  2. Do you provide retraining after an incident occurs or when unsafe work practices are observed? If so, what does that training cover?
  1. How do you or other tree care employers communicate information so non-English speaking workers and workers with limited literacy understand it?
VI. Industry information.
  1. How many employees does the average tree care company employ?
  2. What is the average crew size for different types of tree care operations that you or other tree care employers perform?
  3. Are crew sizes large enough to enable a site supervisor to effectively perform their safety-related activities?
  1. What operations do temporary workers perform?
  2. What PPE do you or other tree care employers provide for temporary workers?
  1. Trimming/pruning trees?
  2. Utility line clearance?
  3. Piece-out tree removal?
  4. Tree felling?
  5. Land clearing/tree clearing?
  6. Other operations? Please describe those operations.
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