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Section V:  Summary and Explanation of the Final Standard

Paragraph (d) General Requirements

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First-Aid Kits

At paragraph (d)(2) of the final rule, OSHA is requiring that employers provide first-aid kits. The proposed standard contained this provision. First aid kits are also required by every State Plan State logging standard. OSHA did not receive any comments opposing this requirement in general.

Paragraph (d)(2)(i) of the final rule requires that first-aid kits be at each work site when felling is being conducted, at each landing and on each employee transport vehicle. The proposed rule stated that first-aid kits be provided "at the work site." Several commenters said that OSHA should define the term "work site" (Ex. 5-39, 5-53, 5-55, 5-63) in the final rule. They also said that having kits available at the landing should provide adequate protection. However, another commenter said chain-saw operators working away from the landing need first-aid kits and should each be required to carry a small first-aid kit that contains supplies to stop bleeding (Ex. 5-28).

In the final rule, OSHA has clarified its intention regarding having first-aid kits at each work site. First, the records shows that first-aid kits are necessary at each work site when felling is being conducted and not just at landings. According to the WIR survey, more than one-half of all injuries occurred at the cutting site, while only one-fifth of the injuries were at landings (Ex. 2-1). OSHA believes that immediate assistance must be provided for injured cutters. As discussed above in the Major Issues section, many logging establishments have central offices, but their crews are performing operations miles from that central location. OSHA has received testimony that cutting crews are often spread out and in remote locations (Ex. 5-34; Tr. OR 21). These commenters said crews are often located more than one-half hour away from a central office or spread across five square miles. First-aid kits that require that much time to access are of limited value to an injured employee. When an injury is severe, the lack of immediately accessible first-aid materials and trained personnel could result in permanent disability or death. Therefore, OSHA is requiring that first-aid kits be provided at each work site where trees are being felled.

Second, OSHA is also requiring first-aid kits to be provided at each landing. As discussed above, one-fifth of all injuries reported in the WIR survey occurred at landings (Ex. 2-1). First-aid kits at landings are also necessary to provide assistance to other injured employees, such as those on skid trails. According to the WIR survey, nearly one-fifth of employees injured were on skid trails.

Third, OSHA is retaining the requirement from the proposed rule that first-aid kits be provided on each crew vehicle. The WIR survey indicates that employees are injured on employer-built roads while enroute to and from work sites (Ex. 2-1). One commenter stated that requiring first-aid kits on each employee transport vehicle could result in several kits being at each work site (Ex. 5-35). Nothing in the standard prohibits an employer from using the employee transport vehicle kits by a felling crew during the workshift, provided they are returned to the crew vehicle when it is moved at the end of the workshift.

Paragraph (d)(2)(i) of the final rule also requires that the employer, in determining the appropriate number and contents of first-aid kits, to consider the degree of isolation of the work site, the number of employees at the work site and the hazards reasonably anticipated at that work site. The further a crew is from a central landing, the more crucial a first-aid kit is for that remote crew. For example, large and well-supplied first-aid kits are needed where crews are so remotely located that rescue units (either vehicles or helicopters) cannot get to the injured person or not get there quickly. When crews are very small and located close to central landings smaller kits may be adequate, when supplemented by kits at central landing areas that contain a more comprehensive supply of first-aid materials.

Paragraphs (d)(2)(ii), (iii) and (iv) all deal with the adequacy of the contents of first-aid kits. At paragraph (d)(2)(ii) of the final rule, OSHA has specified that each first-aid kit must meet certain minimum content requirements. Those minimum content requirements are delineated in mandatory Appendix A. OSHA received comments urging OSHA to specify the contents needed for an "adequately supplied" first-aid kit (Ex. 5-21, 5-28, 5-50, 30). These commenters also pointed out that several State logging standards specify minimum first-aid content requirements (Ex. 2-18, 2-21, 2-22, 2-23, 38J, 38K). In addition, one commenter also provided a list of minimum contents needed for logging first-aid kits. Based on these comments and OSHA's expert judgment, the items listed in Appendix A are the type necessary for dealing with injured persons in remote areas of varying climatic conditions. OSHA points out that the specified contents are minimally adequate for a small logging crew of two to three employees. Where crews are larger, additional kits or kits with more supplies may be needed. In formulating this final rule, OSHA included Appendix A (First-aid supplies) and Appendix B (First-aid training) to provide the employer with a definitive means of determining the adequacy of the first-aid kits and the training that employees must receive.

OSHA has deleted from the final paragraph the proposed requirement that first-aid kits include snake bite kits. OSHA received several comments about this provision (Ex. 5-7, 5-17, 5-29, 5-35, 5-42, 5-50, 5-51, 5-55, 5-67). One commenter said this requirement should be deleted since there were no poisonous snakes in his area (Ex. 5-7). Other commenters said that some snake bite kits were not effective in treating bites or that they are outmoded and can do more damage than good (Ex. 5-17, 5-29, 5-35, 5-42, 5-50, 5-51, 5-55, 5-67). For example, NIOSH said that it is possible more serious injury will occur to a person by improper use of a snake bite kit (Ex. 5-42). According to the Regional Snake Bite Control Center at the University Medical Center in Cincinnati, OH, snake bite kits should not be used when medical treatment is available within one hour of the bite (Ex. 5-42). OSHA has determined that, given the regional differences in the logging industry, employers should be allowed to work with their health care provider to determine whether a snake bite kit is necessary and what kind of kit would be of most assistance for loggers working in that area. One of the factors the health care provider should consider is how far particular loggers are from medical facilities and trained medical personnel.

Paragraph (d)(2)(iii) requires a health care provider to review and approve annually the first-aid kits the employer provides, both as to the adequacy of the kit's contents and the number of kits provided. OSHA has added this requirement in the final rule for several reasons. First, 1910.151(b) already requires that first-aid kits be approved by consulting physicians. OSHA is aware that health care providers in addition to physicians are qualified to approve first-aid kits and OSHA wants to provide flexibility for employers in meeting this requirement. Second, 1910.151(b) only requires initial approval of first-aid kits rather than periodic approval. However, OSHA believes that a periodic review of first-aid kits is necessary and appropriate in the logging industry. This industry is one in which the workplace is often not near medical personnel, infirmaries, clinics, or hospitals that are best able to treat logging injuries. Therefore, it is important for a health care provider to assess the contents of first-aid kits to see that they contain those supplies that will provide effective assistance for an injured worker.

Once the kits are reviewed and approved, paragraph (d)(2)(iv) requires the employer to maintain the first-aid kits in accordance with the approval conditions. Employers have the duty to ensure that first-aid kits are adequately supplied and replenished as necessary. In addition, the employer is responsible for assuring that kit contents are usable, that is, there is no spoilage or damage due to weather conditions. For example, employers need to periodically check first-aid supplies to ensure that materials are still in clean and sterile condition.

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