Last summer, OSHA canceled the agency’s long-standing tree care directive, “Citation Guidance Related to Tree Care and Tree Removal Operations” (CPL 02-01-045), because the administration believes these hazards are adequately addressed in other regulations. To further explain, OSHA released “Inspection Guidance for Tree Care and Tree Removal Operations.”

OSHA’s General Industry Standard regulates many hazards found in tree trimming and vegetation management. People doing this type of work are at risk when climbing, changing location and performing elevated work in trees. Struck-by hazards are the leading cause of injury and death for tree care workers. Therefore, standards addressing ladder safety, aerial lift devices and protection from falls and falling objects (29 CFR 1910 subparts D and I, 29 CFR 1910.67) apply to tree trimming and vegetation management operations.

What is in the OSHA guidance?

According to OSHA's guidance, “Compliance safety and health officers (CSHOs) shall also assess whether employers provide and ensure employees use required PPE in connection with hazards other than those associated with falls and falling objects (for example, the provision and use of cut-resistant leg protection while operating chain saws).”

This is in accordance with standards involving the provision and use of personal protective equipment in connection with other hazards (i.e., 29 CFR Part 1910 Subpart I and other PPE requirements).

Electrical workers are particularly interested in avoiding the risk of electrocution. If tools, equipment or other objects come into contact with overhead or underground lines or energized sources, the outcome can be dire. Therefore, it is imperative for contractors to adhere to electrical safety requirements.

The OSHA guidance notes: “Depending on the work being performed and the employees performing that work, different OSHA standards apply to protect workers against electrical hazards (see, for example, the Electric Power Generation, Transmission, and Distribution standard, 29 CFR 1910.269, and the general industry electrical standards, 29 CFR 1910 Subpart S). For example, some line-clearance tree trimming is covered under 29 CFR 1910.269, some line-clearance tree trimming is covered under 29 CFR 1910 Subpart S, and some tree trimming is covered under the Telecommunications standard, 29 CFR 1910.268.”

Other regulations that apply to tree care workers include Occupational Noise Exposure (29 CFR 1910.95); Materials Handling and Storage (29 CFR 1910 Subpart N); Hand and Portable Powered Tools and Other Hand-Held Equipment (29 CFR 1910 Subpart P); Line-clearance tree-trimming (29 CFR 1910.269(r)); Machinery and Machine Guarding (29 CFR 1910 Subpart O and 29 CFR 1910.269); Medical Services and First Aid (29 CFR 1910.151 and 29 CFR 1910.269); and Portable Fire Extinguishers (29 CFR 1910.157).

Tool considerations

Workers engaged in tree trimming and vegetation management often use noisy tools and equipment such as chain saws and wood chippers. They should adhere to hearing conservation program requirements and use the appropriate hearing protection when noise thresholds are reached. Materials Handling and Storage mostly applies to tree care workers as it pertains to safely operating cranes, lifts and aerial devices.

The compliance directive instructs CSHOs to ensure that all tools used in tree trimming and vegetation management operations are in safe working order and have been properly maintained. It also directs them to ensure that any tools being used for a specific job are handled properly. For example, when involved in line clearance, gasoline powered chain saws are required to be started on the ground and not from an elevated position.

As indicated by the OSHA guidance, “When workers are using brush chippers, stump cutters, chain saws, or other machinery, CSHOs should assess whether the employer is complying with the applicable general industry standards on Machinery and Machine Guarding. Employers should be cited under the relevant provisions of Subpart O if employees are not provided with the appropriate machine guarding measures required by the standard.”

If an incident occurs, workers should render basic first aid and employers must have an emergency response plan in place to comply with all OSHA General Industry requirements. Additionally, tree care vehicles should be equipped with working, tested and certified fire-extinguishers.

Finally, employers should be aware that they can be cited for additional violations not specifically addressed in existing standards, if deemed preventable under the general duty clause. For example, if a tree care worker is struck by a car due to improper traffic safety zones being established, the employer could be held liable. Most general industry standards do not address traffic control requirements.

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