|
Text from
the OSHA Logging Preamble
Section V: Summary and
Explanation of the Final Standard
Paragraph (e) Hand and Portable Powered Tools
* * *
Chain Saws
At paragraph (e)(2) of this final rule, OSHA specifies various requirements for the
proper use of chain saws in the logging industry. OSHA believes these requirements are
necessary to protect loggers from injury when using chain saws. Several commenters also
supported the proposed chain saw requirements as reasonable practices (Ex. 5-21, 5-36,
5-74 through 5-92). As discussed earlier, the WIR survey indicates that chain saw
accidents accounted for 20 percent of the reported accidents (Ex. 2-1). According to a
Maine BLS, from 1980-87 there were an average of 362 disabling chain-saw injuries each
year (Ex. 4-176).
In recent years there have been many improvements in chain saw safety due to the
introduction of devices such as chain brakes, bar tip guards, and reduced kickback bars
and chains. Also, the availability of protective chaps and pads of ballistic nylon or
other lightweight protective materials have provided further protection for chain-saw
operators. OSHA believes that proper use of improved chain saws and personal protective
equipment, and compliance with the work practices will greatly improve the safety record
of chain saw operations. OSHA also believes that proper training in these requirements
will result in better understanding of how these safety devices and work practices can
work to reduce chain-saw related injuries.
At paragraph (e)(2)(i), OSHA is requiring each chain saw placed into initial service
after the effective date of this section be equipped with a chain brake. In addition, this
paragraph requires that chain saws meet all other requirements of the ANSI standard
B175.1-1991 "Safety Requirements on Gasoline-Powered Chain Saws." This
incorporation by reference of ANSI B175.1-1991, has been approved by the Office of the
Federal Register, in accordance with the requirements of 5 U.S.C. 552(a) and 1 CFR part
51. The final rule has been revised to reflect this approval and provides the requisite
information regarding access to the text of ANSI B175.1-1991.
Paragraph (e)(2)(i) also requires that each chain saw placed into service before the
effective date of this section be equipped with a protective device that minimizes
chain-saw kickback. Finally, this provision also requires that chain-saw kickback devices
not be removed or otherwise disabled.
The proposed rule did not require installation of chain brakes or other devices. The
proposed rule did, however, require that when such devices were present they should be
inspected frequently and maintained. The need for devices to prevent kickback was
specifically raised as an issue in the notice of hearing.
OSHA received many comments on whether chain-saw protective devices should be required
in the final rule. These comments have been discussed above in the Major Issues section.
One commenter suggested that loggers be allowed to remove chain brakes when, in the
judgment of the operator the presence of the chain brake creates a hazard greater than the
hazard the brake was designed to avoid (Ex. 5-55). This commenter suggested that it is
more hazardous to have a chain brake when the saw is operated on its side and at other
unspecified times. However, the commenter did not provide any data or other evidence to
support his contention. There is no other data or evidence in the record that chain brakes
may create additional hazards at any time during the cutting process. Additionally, OSHA
believes that once the chain brake is removed it is likely the operator will leave it off
and remain exposed to injury from chain saw kickback. As noted in the earlier discussion,
commenters stated that removal of devices is occurring, thereby exposing the operator to
the risk of injury due to kickback. Therefore, OSHA is requiring that chain-saw kickback
devices not be removed or otherwise disabled.
At paragraph (e)(2)(ii) of the final rule, OSHA is requiring that each gasoline-powered
chain saw be equipped with a continuous throttle system which stops the running chain when
pressure on the throttle is released. This provision has been adopted from the proposed
rule. OSHA received one comment that stated that if the safety equipment that came with
the chain saw were in place, the accidents listed in the preamble would not have occurred
(Tr. W1 66). Therefore, this requirement has been retained in the final rule.
NIOSH recommended that OSHA require chain saws be equipped or retrofitted with mufflers
meeting the chain-saw manufacturer's specifications (Ex. 5-42). NIOSH said mufflers would
be effective for noise reduction. OSHA has not adopted NIOSH's recommendation. First,
retrofit mufflers may cause operational difficulties. Second, retrofit mufflers may also
contribute to an increase in back pressure for the operator.
Paragraphs (e)(2)(iii) through (e)(2)(xiv) specify various requirements for safe
operation of chain saws. OSHA believes these work practices are essential in reducing the
number of injuries that occur to chain-saw operators. According to the WIR survey, the
vast majority of chain-saw injuries reported indicates that unsafe work practices were
involved (Ex. 2-1). In contrast, only four percent of chain-saw injuries were the result
of equipment failure.
At paragraph (e)(2)(iii) of the final rule, OSHA is requiring that the chain saw be
operated and adjusted in accordance with the manufacturer's instructions. This provision
adopts the requirement contained in the proposed rule. OSHA did not receive any comments
opposing this requirement.
At paragraph (e)(2)(iv) of the final rule, OSHA is requiring that the chain saw be
refueled at least 20 feet from any open flame or other source of ignition. This provision
adopts the requirements contained in the proposed rule. This requirement was also
contained in the 1978 ANSI logging standard. The OSHA pulpwood logging standard required
only that chain saw operators be instructed to refuel the saw only in safe areas and not
in areas conducive to fire.
OSHA believes that a separation between a fueling area and any source of ignition, such
as a cigarette, is necessary to prevent ignition of vapors from spills or from overfilled
chain-saw tanks. The final rule clarifies what constitutes at least a minimal safe fueling
area. OSHA did not receive any comments opposing this requirement.
At paragraph (e)(2)(v) of the final rule, OSHA is requiring that the chain saw be
started at least 10 feet from any fueling area. This provision also adopts the requirement
contained in the proposed rule.
Only one commenter opposed this provision, saying that in some instances it would be
impossible to move 10 feet from a fueling area to start the chain saw (Ex. 5-7). However,
no substantive evidence was presented.
OSHA believes that when a chain saw is started, there is a potential that spilled fuel
in the area could also become ignited. For example, a faulty spark plug wire can cause an
arc between the wire and metal casing, resulting in the igniting of spilled fuel. In
addition, the record shows that the danger of fire is a major concern in the logging
industry (Ex. 5-20). OSHA believes that this provision will help to reduce the potential
for fires.
At paragraph (e)(2)(vi) of the final rule, OSHA is requiring that the chain saw be
started on the ground or where otherwise firmly supported. The provision is the same as
the requirement contained in the proposal and the pulpwood logging standard. Two
commenters opposed the requirement (Ex. 5-34, 5-35). One commenter stated:
In many instances, there is not any way to comply, i.e., when a cutter is felling while
standing on springboard jacks, it would be a greater hazard for him to climb up carrying a
running saw. This means that the chain saw must be started on the springboard with no
place left to rest the saw. The same situation occurs when limbing and bucking large trees
after they are on the ground. The cutter/ bucker would have to climb up on the trunk while
carrying a running saw. The proposed standard should be amended to read "whenever
possible" chain saws should be started [on the ground] (Ex. 5-34).
The other commenter said starting the chain saw on the ground was not necessarily the
safest way to start it, and, in any event, saws equipped with chain brakes could be drop
started when the chain brake is engaged (5-35). Another commenter said that they had had
no injuries resulting from starting chains saws when standing in an upright position (Ex.
5-45).
For several reasons, OSHA believes that this provision is necessary to protect chain
saw operators. First, the record supports the need for chain saws to be firmly supported
when they are started. The WIR survey indicates that a significant portion of chain saw
injuries were related to the operator not having firm control or grip of the saw (e.g.,
didn't have tight grip on saw, hand slipped into chain, operator fell on saw). While the
survey does not indicate whether these injuries occurred while the operator was starting
the saw, the presence of these injuries does reinforce the need for appropriate work
practices that require proper support for equipment so the operator is able to maintain a
firm grip and control of the saw.
Second, OSHA believes that there is a potential for injury when operators attempt to
drop-start chain saws. There is a potential for the operator to lose his grip when
starting the saw. In addition, especially when the saw is not properly adjusted, the
engine can flood. This can cause the saw to fly upward and hit the operator. When the
chain saw starts there is potential for sudden movement of the chain because of the
increase in rpm. Third, while OSHA believes that starting the chain saw on the ground will
provide the best control and support, OSHA is aware that there may be some circumstances
in which a chain saw cannot be started in this manner. Nonetheless, even in those
circumstances, OSHA believes that it is necessary for operator safety that the saw be
firmly supported. Fourth, even when the chain brake is on, the saw needs to be firmly
supported when it is started. When the chain saw is started, the chain will move until the
engine returns to idle. If the chain saw is not firmly supported when the operator starts
the engine, he could lose control of the saw and the moving chain could strike and injure
him.
At paragraph (e)(2)(vii) of the final rule, OSHA is requiring that chain brakes be
engaged when the saw is started. Although this requirement was not contained in the
proposed rule, OSHA believes it is necessary for chain brakes to be engaged when the
engine is started. As discussed above, when chain saws are started, the chain will run
momentarily. When a chain brake is present, it will hold the chain when the engine returns
to idle. However, when the chain brake is not engaged, the chain may continue to run at
idle, further exposing the operator to the hazard. OSHA believes that the many comments
recommending that the final rule require chain saws to be equipped with chain brakes, also
imply that the chain brakes should be properly engaged during use of the chain saw. In
addition, none of those commenters supporting a chain brake provision indicated that there
were situations in which it would be safe to allow the chain brake not to be engaged
during operation of the saw.
At paragraph (e)(2)(viii) of the final standard, OSHA is requiring that the operator
hold the chain saw with both hands during operation. This requirement does not apply when
the employer can demonstrate that a greater hazard is posed by keeping both hands on the
saw in that particular situation. This provision is the same as the provision contained in
the proposed rule. The 1978 ANSI logging standard also recognized the occasional need for
momentary release of one hand from the saw in some situations.
Some commenters urged OSHA to require that a chain saw must never be operated with only
one hand (Ex. 5-34, 5-50, 5-66). One commenter said:
Regardless of what organization recognizes and sanctions momentary one-handed chain saw
use, it is extremely dangerous. I do not agree it is necessary to operate a saw with one
hand and place a wedge with the other. By so doing, the right hand is on the pistol grip
controlling the throttle, the left handling the wedge. If, during this one-handed process
a kick back should occur, the left hand which has the primary responsibility for
maintaining a distance between the operator and the saw chain is absent. Sufficient time
exists between the initiation of the backcut and its completion for the cutter to
momentarily halt his sawing to insert a wedge (Ex. 5-66).
The U.S. Dept. of Interior also said that chains saws should be held with both hands
unless the motor is at idle (Ex. 5-50). It is not difficult for chain-saw operators to put
the saw in idle before removing one hand from the saw. Before placing a wedge the feller
can stop the chain by simply removing his finger from the throttle, that will idle the
chain saw, thereby reducing the possibility of injury resulting from operating the saw
with only one hand. OSHA agrees that in this situation as well as most other operating
situations, the greater hazard is posed by removing the hand from the chain saw. According
to the WIR survey, 13 percent of chain-saw operators injured reported that their hand
slipped into the chain or they did not have a tight grip on the saw. However, OSHA
believes there are other situations in which the hazard may be greater if the operator
attempts to hold the saw with two hands. For example, when an operator has climbed a tree
to top the tree, the operator may not be able to keep his balance if he tries to operate
the saw with both hands. In that case, the safest method may be to use one hand to control
the saw and the other hand to steady himself.
OSHA notes that the employer bears the burden of demonstrating that a greater hazard
exists by keeping both hands on the saw in a particular situation. OSHA also notes that
the limited exception involves a case-by-case determination by the employer.
At paragraph (e)(2)(ix) of the final rule, OSHA is requiring that the chain saw
operator be certain of his footing before starting to cut. This provision also requires
that the chain saw not be operated in a position or at a distance that could cause the
operator to become off-balance, to have insecure footing, or to relinquish a firm grip on
the saw. This provision adopts requirements contained in the proposed rule. Commenters
supported this provision (Ex. 5-7, 5-21, 5-34, 5-36, 5-55), and there were no comments
opposing this requirement.
OSHA believes this work practice will help to reduce the number of slip and fall
injuries occurring in the logging industry. According to the WIR survey, slips and falls
account for 24 percent of all injuries and 13 percent of all chain saw injuries reported
resulting from operators falling on the saw.
At paragraph (e)(2)(x) of the final rule, OSHA is requiring that prior to felling a
tree the chain saw operator clear away brush or other potential obstacles that might
interfere with cutting or using the retreat path. This provision adopts the requirement
contained in the proposed rule. There were no comments opposing this requirement. OSHA
believes this provision will help to reduce the number of injuries that result from
loggers being hit by trees. According to the WIR survey, 24 percent of all injured loggers
were hit by trees (Ex. 2-1). In addition, of employees reporting injuries, over one-fourth
said that heavy brush, ground cover and hidden wood on the ground had contributed to their
accident.
At paragraph (e)(2)(xi) of the final rule, OSHA is prohibiting cutting directly
overhead with a chain saw. This provision was contained in the proposed rule. Several
commenters supported the proposed provision (Ex. 5-34, 5-42, 9-10) and no comments were
received opposing it.
At paragraph (e)(2)(xii) of the final rule, OSHA is requiring that the chain saw be
carried in a manner that will prevent operator contact with the chain and muffler. The
proposed rule contained the same requirement. Evidence in the record suggests that this
work practice already is being used extensively in the logging industry (Ex. 5-66). Some
commenters said that for many years chain saw operators have carried the saw on their
shoulder and used a felt and/or leather pad to protect their neck and shoulder from being
cut by the chain or burned by the hot engine (Ex. 5-21, 5-36, 5-63). OSHA notes that any
other method of carrying the chain saw that prevents these hazards would also meet this
requirement.
In paragraphs (e)(2)(xiii) and (xiv) of the final rule, OSHA is specifying requirements
for carrying a chain saw. In paragraph (e)(2)(xiii), OSHA is requiring that the chain saw
be shut off or at idle before the operator starts a retreat after cutting a tree. This
provision also clarifies OSHA's intent that these work practices apply not only to
carrying the saw between cuts but also to retreating after a cut has been made. This
provision has been adopted from the proposed rule.
NIOSH supported this provision, and further recommended that OSHA should require the
chain brake to be engaged when an operator is moving from one location to another, except
while working on the same tree or log, regardless of distance traveled (Ex. 5-42). Another
commenter also supported the NIOSH recommendation (Ex. 5-52). However, three other
commenters opposed requiring saws to be at idle or shut off before starting a retreat (Ex.
5-7, 5-50, 5-66). One commenter said:
The cutter may lose precious seconds worrying about compliance with the proposed
standard, meanwhile a life could be in danger. Better to immediately remove the cutter
from the base of the tree than worry about the saw (Ex. 5-50).
OSHA believes that the requirement that chain saws be shut off or at idle before
starting a retreat is necessary and can be accomplished without creating additional
hazards for the operator. First, OSHA believes that carrying a chain saw with the chain
moving may present a great hazard for the operator. The WIR survey indicates that a
significant portion of chain saw injuries result from the operator falling on the saw, the
saw chain contacting the employee, or the operator's hand slipping into the chain (Ex.
2-1).
Second, as OSHA explained in the preamble to the proposed rule, the saw can be at idle
rather than shut off, provided that the chain brake is engaged. OSHA is allowing operators
to comply by either method because it recognizes that idling the saw with the chain brake
engaged is as effective as shutting off the engine in terms of preventing serious
lacerations due to coming into contact with the moving chain.
Third, OSHA does not think that idling the saw will add a significant amount of time to
the operator's retreat. All the operator must do to idle the chain saw and safely carry it
is to release pressure on the throttle and grasp the front handle. Fourth, in any event,
chain saws are designed to be carried by the front handle rather than by the rear
throttle. Carrying the saw by the front handle is easier and there is no risk of the bar
tip contacting the operator's leg or toe. Carrying the saw by the rear throttle guard can
cause the bar tip to swing downward and possibly strike the operator. Therefore, OSHA
believes that the operator should grasp the front handle thereby idling the saw. That way
the operator will both protect himself from a falling tree and from saw lacerations
without undue difficulty.
Paragraph (e)(2)(xiv) of the final rule requires that when the operator must carry the
chain saw further than 50 feet that the chain brake be engaged or, if there is no chain
brake, that the saw be shut off. This provision also requires that the chain brake be
engaged or the saw shut off when carrying a saw for a lesser distance if conditions, such
as but not limited to, the terrain, underbrush and slippery surfaces, may create a hazard
for an employee.
The proposed rule also contained these provisions. The 1978 ANSI logging standard
required that chain saws be shut off when carried for a distance greater than from tree to
tree. In addition the ANSI standard also required that when the terrain and other physical
factors, such as underbrush and slippery surfaces, make the carrying of a running saw for
such short distances, the saw shall be shut off for carrying. Some State logging standards
also require the chain saw to be shut off or at idle when moving from tree to tree (Ex.
2-18, 2-22). For example, the State of Washington logging standard requires that after the
chain-saw operator has felled the tree, the saw must be shut off or at idle while moving
to another tree (Ex. 2-22). This standard also requires the chain saw to be shut off when
moving to the next tree when hazardous conditions are present.
Some commenters supported this provision (Ex. 5-27, 5-42, 5-66). One of these commenter
said that their experience had been that a chain-saw operator could carry a chain saw any
distance without being injured, provided the chain brake was engaged (Ex. 5-27). Another
commenter supported the provision because carrying a running chain saw any distance
promotes additional fatigue that can also contribute to accidents and errors (Ex. 5-66).
The reasoning and explanation for shutting off chain saws before beginning retreat also
applies to carrying chain saws for longer distances. According to the WIR survey, 13
percent of all chain-saw operators were injured when they fell on their saws (Ex. 2-1).
OSHA believes this provision is necessary to reduce exposure to the hazard of a running
chain-saw chain.
* * *
|
Back to Top 
www.osha.gov
