Comment from Payne, Todd, US Forest Service

Tree Service, Care and Removal Docket No: OSHA-2008-0012 This information is in response to your request for information on this topic A. Tree Care industries 1. I can only speak to what I personally know. The who that I know is Job Corps, Forest Service, Washington State Parks, and US Park Service. What is: The Job Corps centers in the US have tree maintenance and removal in there programs. The forest service has a few folks who do tree pruning and a nation wide program that does tree removal on a call when needed basis. The state parks and the National Park Service have some regular crews who work year around with tree care. These are groups of people that should be included when you start making regulations. Very few of these people are classified as tree trimmers. 2. Trainings students to climb, prune and remove trees involve all types of hazards so Safety techniques are stressed. The right personal protective equipment, the proper methods like 3 point climbing, ascending and descending, and working with a proper set of core knots to use are all things that should be part of a safety program. The students trees prune, remove trees from top to bottom and fall full length trees as part of there program. Region 6 already has a program in place for teaching people to climb trees their program could provide some good stuff for OSHA to use. As part of the Forest Service employees get certified and remove trees in pieces some times and full length falling. These trees are usually classified as hazard trees before they are removed. In Parks where they have regular crews and equipment for the job, Crews remove hazard trees in campgrounds and in housing areas to protect employees and the public. B. Accidents, injuries and fatalities 1. I was a job corps instructor for 11 years and tree climbing instructor and climber for 15 years and did not have any fatalities or serious injuries. However when students left my program and went to work for private tree companies several of them were seriously injured. In talking with the students they would tell me that people did not wear proper protective equipment or follow three point climbing methods because time is money. These were the main causes of injury reported to me. 2. The highest causes of injuries are falls and chain saw use in trees. D. Tree Removal 10. Removal of trees needs to have: Checked condition of tree if rotten use bucket truck Proper training and experience for the job Proper personnel protective equipment Secure work area Good communication with ground personnel if working in tree 3 points in contact if removing from top down If using chain saw in tree insure proper balance and points of personal contact The right ropes and the right knots If full length falling you need to use a three cut falling method which involves a face cut a back cut and holding wood. Remember to use wedges I. Training To get started in the Forest Service you have 4o hours of basic training in climbing, descending, knots, and rescue. There are many add on to this training like ladders, 4 inch tie in, spurs, ascenders, belaying, and chain saw use in trees. This training does not make you a journeyman it makes you an apprentice. You must have a first aid trained person on in the area and also someone who is trained in rescue cannot climb alone. Rescue is the most important part of the training and is the most difficult. It should be practiced regularly or at least done every three years to maintain proficiency.