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Text from the OSHA Logging Preamble Text from the OSHA Logging Preamble

Section V:  Summary and Explanation of the Final Standard

Paragraph (h) Tree Harvesting

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Loading and Unloading

Paragraph (h)(6) of the final rule specifies various work practice requirements regarding loading and unloading trees onto transport machines or vehicles. These requirements were based on those in the 1978 logging standard and various State logging standards (Ex. 2-17, 2-18, 2-19, 2-20, 2-22, 38J, 38K). OSHA believes these work practices are necessary to protect employees from being hit by machines, vehicles, trees and logs during loading and unloading. The WIR survey indicates that five percent of the injuries reported occurred during loading or unloading (Ex. 2-1). The State of Washington study indicated that five percent of all deaths occurred during loading and unloading operations (Ex. 4-129).

Paragraph (h)(6)(i) of the final rule requires that the transport machine or vehicle be positioned to provide working clearance between the vehicle and deck of trees or logs. This provision parallels the requirement contained in the proposed rule. The 1978 ANSI logging standard contained a similar provision.

Several commenters supported the need for adequate room between transport equipment and trees or logs (Ex. 5-21, 5-74 through 5-92). These commenters pointed out that room needs to be provided on the landing for the transport machine or vehicle and its counterweights, especially when landings are on sloped terrain. The record supports these commenters' position. According to the State of Washington study, almost 10 percent of all deaths reported occurred when an employee was struck by mobile equipment and five percent of all deaths involved employees performing loading operations (Ex. 4-129). OSHA believes that the employer must consider several factors in determining an adequate work clearance for loading and unloading. These factors include, but are not limited to, the type of loading machine and transport vehicle being used, the physical characteristics of the load being moved, and the layout of the area where the operation is being conducted. For example, if the vehicle is a self-loading log truck, it will have to be positioned close to the deck of logs to allow the truck to be loaded. On the other hand, if a crane or other material handling machine is used to load and unload the transport vehicle, the machine must be positioned so that it can reach both the deck of logs and the vehicle without exceeding the rated capacity of the machine.

Paragraph (h)(6)(ii) of the final rule requires that only the loading or unloading machine operator and other personnel that the employer demonstrates are essential shall be allowed in the work area during loading and unloading. This provision parallels the provision contained in the proposed rule and in the 1978 ANSI logging standard. There were no comments opposing this provision. OSHA believes this provision is necessary because, as discussed above, many injuries and fatalities in the logging industry involve loading operations. For example, the State of Washington study reported that three employees were killed when they were struck by logs falling from the transport vehicle during loading (Ex. 4-129).

In the final rule, OSHA is clarifying its intention that the employer bears the burden of proving that personnel other than the machine operator who are in the loading or unloading area are essential to that activity. OSHA notes that this is a case-by-case determination that requires the employer to evaluate the needs and conditions present at the time.

Paragraph (h)(6)(iii) of the final rule requires that no transport vehicle operator remain in the cab during loading and unloading if logs are carried or moved over the cab, unless the employer demonstrates that it is essential for the operator to be in the cab. This provision also requires that when the transport vehicle operator remains in the cab during loading or unloading operations, the employer must provide operator protection such as, but not limited to, reinforcement of the cab. The proposed rule specifies that no transport vehicle operator remain in the cab during loading and unloading unless the employer demonstrates that it was necessary for the operator to be in the cab. The 1978 ANSI logging standard contained a similar requirement.

OSHA received many comments on this provision (Ex. 5-17, 5-21, 5-33, 5-34, 5-74 through 5-92). Several commenters stated that there were so many situations in which it is essential for transport vehicle operators to be in the cab or on the vehicle during loading and unloading that the exceptions would overwhelm the rule (Ex. 5-21, 5-34, 5-36, 5-74 through 5-92). For example, commenters said that self-loading logging trucks must be operated by the driver from an elevated seat above the cab (Ex. 5-21, 5-36). In other loading operations the operator is required to move the transport vehicle back and forth in the loading chute to position the log on the load (Ex. 5-34).

Several commenters said that the cab may be the safest place for the transport vehicle operator to be during loading and unloading (Ex. 5-17, 5-33, 5-34). One commenter said that greater hazards were posed for the operator when not in the cab (Ex. 5-34). For example, the operator outside the cab can be struck by logs that fall off the load or come out of the jaws of the loading machine, or by the loading machine itself. This commenter pointed out that in the State of Washington there have been numerous fatalities and serious injuries reported when the operator was outside the cab, but none reported when the operator was in the cab (Ex. 5-34). As such, this commenter said that many logging establishments will only permit logs to be unloaded if the transport vehicle operator is in the cab (Ex. 5-34).

OSHA believes the record shows that in some situations the safest place for the transport vehicle operator will be in the cab (e.g., Ex. 4-129). The WIR survey appears to support this position, in that only three percent of all injuries reported involved mobile equipment (Ex. 2-1). By contrast, almost one-fourth of all injuries reported resulted from being hit by a tree or falling in the work site. However, there are some hazards to operators who remain in cabs during loading and unloading. Any time logs are carried or moved over the cab, it is possible due to equipment failure or operator error that the log could fall on the cab and seriously injure the operator.

In other standards OSHA has recognized the hazard of carrying loads over people. These standards include requirements that material handling equipment operators avoid this practice (See 29 CFR 1910.179, 29 CFR 1910.180, 29 CFR 1910.181). In many new self-loading trucks, the hoist mechanism is behind the cab, a location which prevents the movement of logs over the cab (Ex. 5-71). In other situations, however, logs are still moved or carried over the cab. It is not safe for the operator to be in the cab in those situations. Therefore, when logs are carried or moved over the cab, the final rule requires that the operator not remain in the cab if the employer has not demonstrated that it is essential for the operator to do so. If it is essential for the operator to be in the cab when logs are carried or moved over the cab, the employer must provide protection for the operator. The final rule states that this protection includes but is not limited to reinforcement of the cab.

Paragraph (h)(6)(iv) of the final rule requires that each log be placed on the transport vehicle in an orderly manner and tightly secured. This provision parallels the requirement contained in the proposed rule. There were no comments opposing this provision.

OSHA believes that this provision is necessary to protect employees from the hazards that result from haphazard loading and inadequately securing the load. For example, when the load is not properly stacked and/or tightly secured, logs can swing in the tie downs and hit an employee. In addition, the load can shift and cause both the trailer and transport machine or vehicle to rollover. Proper stowage of vehicle loads has the added advantage of providing, in most cases, a more compact load with a lower center of gravity, one that is safer to move.

Paragraph (h)(6)(v) of the final rule requires that the load be positioned to prevent slippage or loss during handling and transport. This requirement parallels the provision contained in the proposed rule. OSHA did not receive any comments opposing this provision. A load that is improperly positioned can roll or shift at any time, thereby potentially endangering any employee who might be close at hand.

Paragraph (h)(6)(vi) of the final rule requires that each stake and chock used to trip loads must be constructed so the tripping mechanism is activated on the side opposite the release of the load. OSHA has adopted this provision from the proposed rule. The 1978 ANSI logging standard also contained a similar provision. There were no comments opposing this provision. OSHA believes this provision is necessary to protect employees from sudden or unexpected shifts or movements of the logs when a load is released. Only by keeping employees out of the potential paths of the shifting or moving logs can there be assurance that the employee will not be struck by a log.

Paragraph (h)(6)(vii) of the final rule requires that each tie down be left in place over the peak log to secure the logs until the unloading lines or other equivalent protection have been put in place. This provision also specifies that a stake of sufficient strength to withstand forces of shifting logs shall be considered to provide protection equivalent to a tie down, provided that the logs are not loaded higher than the stake. This provision parallels the requirement contained in the proposed rule.

The West Virginia Forestry Association supported this provision (Ex. 5-54). They said that several recent serious logging accidents had occurred in their state because logs loaded too high have fallen off the transport vehicle.

Due to the vibration of the load during transport, the load can shift or move so that when the restraints are removed, the load will roll or otherwise fall off the truck, thereby endangering the employee who must remove the restraints. For this reason, OSHA has specified the necessary and appropriate work practices that must be followed to ensure the safe unloading of transport vehicles.

Paragraph (h)(6)(viii) of the final rule requires that each tie down be released only from the side on which the unloading machine operates. This provision also permits two exceptions to this requirement in situations when the tie down is released by a remote control device and when the employee making the release is protected by racks, stanchions or other protection the employer demonstrates is capable of withstanding the force of moving and shifting logs. This requirement parallels the provision contained in the proposed rule and the 1978 ANSI logging standard.

Several commenters suggested that the exceptions to the release requirement be eliminated (Ex. 5-21, 5-36, 5-74 through 5-92). However, these commenters did not provide any discussion to support their position. OSHA believes that adequate protection is provided in the alternate releasing methods that are excepted from this provision to protect the machine or vehicle operator from being hit by moving or shifting trees or logs.

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