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Text from the OSHA Logging Standard Amendment issued September 8, 1995 in the Federal Register Text from the OSHA Logging Standard Amendment issued September 8, 1995 in the Federal Register

Paragraph (i)(7)(i) -- First-Aid Training

The final logging rule requires the employer to assure that each employee receives or has received first-aid training, including CPR, which meets the minimum requirements set forth in mandatory Appendix B. OSHA was requested by some parties to clarify whether the provision requires employers to provide new employees with first-aid training before they are allowed to begin work, and if so, to permit employers to have a 90-day training phase-in period for new employees.

The final rule does not require employers to provide the first-aid training to their employees. Employers are only required to assure that every employee performing logging operations has a first-aid training certificate which is current. Employers are free to require, as a condition of employment, that new employees have or obtain a first-aid training certificate. As the rulemaking record indicates, there are many organizations, schools, extension services, and others throughout the country which provide first-aid training on a continuous basis.

At the same time, OSHA is aware that some employers do provide first-aid certificate training for new employees who do not have a current first-aid training certificate. Where employers elect to provide such training, the general training requirements of paragraph (i) require that it be provided prior to the employee's initial assignment. It is vital that new and untrained employees not be allowed to begin work until they have been trained.

Remote and isolated locations are typical of logging operations. If employees working in these locations do not have the necessary first-aid training, they would not be able to help themselves or others if an accident were to occur. For example, one fatality report submitted by APA involved a feller being sent to work alone in an isolated area (Ex. 26A). The feller suffered a cut to the upper leg and did not perform any first-aid on himself. Instead, he attempted to walk out of the woods but bled to death before he was found. Teaming an untrained employee with a trained logger would not solve the problem. In case of emergency, the untrained employee would not be able to provide first-aid assistance if it were his trained partner that was injured. Many crews work in pairs in remote areas and each crew member needs to be trained to help his partner.

Therefore, OSHA is not allowing a phase-in period for first-aid training. The employer is responsible for assuring that untrained employees have had first-aid training prior to initial assignment or, in the case of current employees, by the effective date of the final rule. OSHA believes that the logging rule can best reduce the number and severity of logging injuries if employees have a current first-aid training certificate before they begin logging operations.

Paragraph (i)(7)(ii) and (iii) -- Frequency of First-Aid Training

The final rule requires employers to assure that each logging employee receives first-aid training at least every three years and CPR training at least annually. The final rule also requires the employer to assure that each employee's first-aid and CPR training certificate remain current. It has been suggested to OSHA that CPR training is only necessary every three years. For the following reasons, OSHA believes that the record does not support such a change.

As OSHA explained in the preamble to the final rule, the American Red Cross first-aid training program, which is the most widely used program in the country, requires first-aid training every three years and annual CPR training in order to maintain a current certificate (Ex. 5-42). The American Heart Association follows the same requirements for maintaining current certification. The American Medical Association also recommends following the training procedures established by the American Red Cross and the American Heart Association. In addition, States have established minimum requirements for first-aid training certification.

While OSHA is aware that some States only require CPR training every two years to maintain a current certificate (e.g., Idaho), there are no States which permit CPR certificates to remain current for three years. OSHA is correcting the final rule to conform its retraining requirements to the requirements established by State regulations and organizations that provide first-aid and CPR certificate training programs. Therefore, as long as the employer assures that each employee has a current first-aid and CPR training certificate which meet State requirements or the requirements of certifying organizations, the employer is in compliance with the final rule. To reflect this clarification, OSHA is deleting paragraph (i)(7)(ii) and re-designating paragraph (i)(7)(iii) as paragraph (i)(7)(ii).

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