By Kristine Catimbang, Guest Contributor

OSHA issued a memorandum to OSHA regional administrators updating its enforcement guidelines for tree care and tree removal operations. On June 24, 2021, OSHA cancelled the OSHA instruction CPL 02-01-045, Citation Guidance Related to Tree Care and Tree Removal Operations (the Tree Care Directive) (OSHA, 2021). It recognizes that tree care operations expose workers to a number of hazards including falls from elevation, struck-by objects, lacerations, and contact with energized powerlines. The update provides enforcement guidelines to compliance safety and health officers (CSHOs) when inspecting workers who are engaging in tree care and tree removal operations.

OSHA currently does not have any comprehensive standards for tree care operations; however, the tree care industry must comply with all the general industry standards (29 CFR 1910). The memorandum addresses some specific hazards faced by workers engaged in tree care and tree removal operations, and some general industry standards that address those hazards. These standards include (OSHA, 2021):

• Protection from Falls and Falling Objects (29 CFR 1910 Subparts D and I, 29 CFR 1910.67)
• Provision and Use of Personal Protective Equipment (PPE) in Connection with Other Hazards (29 CFR Part 1910, Subpart I and other PPE Requirements)
• Electrical Safety (29 CFR 1910.269 and 1910 Subpart S)
• Flammable Liquids (29 CFR 1910.106)
• 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, 29 CFR 1910.269(r), and the General Duty Clause) Machinery and Machine Guarding (29 CFR 1910 Subpart O and 29 CFR 1910.269)
• First-Aid Providers and First-Aid Kits (29 CFR 1910.151 and 29 CFR 1910.269)
• Fire Extinguishers (29 CFR 1910.157)
• Protective Structures (the General Duty Clause) Traffic Safety (the General Duty Clause)

Inspectors may issue citations under OSHA’s General Industry standards (29 CFR 1910), where applicable. In some cases, inspectors may also issue citations under Section 5(a)(1) of the OSH Act, 29 U.S.C. 654(a)(1) (the General Duty Clause). You can read more about the tree care and tree removal enforcement guidance here.

References

Occupational Safety and Health Administration (OSHA). (June 2021). Enforcement Inspection Guidance for Tree Care and Tree Removal Operations. Retrieved from: https://www.osha.gov/memos/2021-06-30/inspection-guidance-for-tree-care-and-tree-removal-operations