OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

August 30, 1999

Mr. Richard Lewis
APA President
American Pulpwood Association, Inc.
600 Jefferson Plaza, Suite 350
Rockville, Maryland 20852

Dear Mr. Lewis:

Thank you for your June 29, 1999 letter to Mr. Charles N. Jeffress, Assistant Secretary, Occupational Safety and Health Administration (OSHA), regarding the Powered Industrial Truck Operator Training, Final Rule, December 1, 1998. You request clarification of the types of forestry-related equipment covered by OSHA standard 29 CFR 1910.178(l). Your request was forwarded to the Directorate of Compliance Programs for response. We appreciate the opportunity to provide you with clarification on this matter.

You indicate that the American Pulpwood Association was informed that the State of Pennsylvania has interpreted this new OSHA standard to include log skidders. Log skidders drag or skid logs and pulpwood from tree felling sites in the forest to landing areas along roads.

Question: Do the Powered Industrial Truck Operator Training requirements (1910.178(l)) apply to operators of log skidders?

Response: In tree felling operations, OSHA's logging standard, 1910.266 would be applicable. This standard is intended to deal with workplace hazards that are unique to logging operations. It contains employee training requirements for forestry-related machines such as log skidders at 1910.266(i)(3)(ii). A logging employer must therefore comply only with the requirements at 1910.266(i)(3)(ii), but such employers may find it useful to consult the general standard for industrial truck operator training for additional guidance when developing training programs.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at http://www.osha.gov. If you have any further questions, please contact the Office of General Industry Compliance Assistance at (202) 693-1850.


Richard Fairfax, Director
Directorate of Compliance Programs