Text from
the OSHA Logging Standard Amendment issued September 8, 1995 in the Federal RegisterParagraph
(h)(3)(i) -- Limbing and Bucking
The final rule requires that whenever rolling or sliding of the tree is reasonably
foreseeable, limbing and bucking must be done on the uphill side of the tree. While it is
possible to limb and buck from the uphill side in almost all situations, the Agency
provided an exception for those cases where the employer demonstrated that it was not
feasible to limb or buck from the uphill side. In those limited cases, the provision
required that the tree be secured with chocks to prevent rolling, sliding or swinging.
After publication of the final rule, OSHA was told by various parties that they knew of
no cases where manual bucking and limbing from the uphill side would be infeasible. They
also said that the procedure of setting chocks itself would put the employee in a
dangerous position. Therefore, they told OSHA that the exception allowing work on the
downhill side should be deleted from the final rule.
A review of the rulemaking record supports these comments. There were no comments or
hearing testimony identifying any situations in which it would be infeasible to buck or
limb a tree from the uphill side. Moreover, the Agency is aware that machines can move
trees to a stable position so there is no potential for rolling of the tree during limbing
and bucking. Therefore, OSHA agrees that the exception to allow limbing and bucking from
the downhill side is unnecessary, and is correcting the final rule to remove it.
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