Text from
the OSHA Logging PreambleSection IV: Major Issues
A. Introduction
* * *
7. Operator manuals or instructions. In the hearing notice
OSHA raised two issues regarding operator manuals or instructions (referred to
collectively as instructions) for machines: the location of instructions, and the
experience of employers in obtaining manuals from manufacturers.
a. Location of operator manuals or instructions. Both the
existing pulpwood standard and the proposed standard contained provisions requiring either
an operator's manual or set of instructions be kept with each machine. In addition, both
stated that the instructions, at a minimum, must describe the operation, maintenance and
safe practices for the machine. The proposed standard added a provision requiring each
operator and maintenance employee to comply with the manual.
All commenters generally agreed with the need to have instructions available to
operators and maintenance personnel. Several hearing participants supported OSHA's
proposal to require instructions to be kept with machines (Tr. W1 201, OR 168, 194). For
example, one participant stated:
We urge OSHA to require that operator manuals be kept on the machine. Operator manuals
contain important personal safety and machine operational information which must be
utilized during training and must be available for reference to assure safety for all
different operating conditions.
Efficient and productive logging operations go hand in hand with safe work practices
and proper machine maintenance and operation. Ready and immediate access to safety and
operational information is essential to minimize downtime caused by accidents (Tr. OR
168).
Another commenter added that once instructions are placed back at the office, they are
not used:
Ms. Schuster: I just have one question. Do you have any idea of the percentage of
equipment out there in the woods that does not currently have operator's manuals
available?
Mr. Carr: I'm afraid I'd have to agree, most of them probably do not. This is our
concern as manufacturers that most of them do not. Most of the time they have taken them
and put them in the office and that's the last they see of them.
Mr. Schuster: You say most of them would have put them in the office. Would you say
that many of them do have them available though somewhere, if not on the equipment?
Mr. Carr: If somebody can find it (Tr. OR 194).
Many commenters, however, stated that for several reasons instructions should not be
kept with machines or instead should be distributed as part of the training program (Ex.
5-12, 5-34, 5-35, 5-67, 9-2, 9-3, 9-4, 9-5, 9-19, 9-22; Tr. W1 66, 134, 185, 235, W2 225,
OR 31, 59, 263, 378, 629). First, these commenters said instructions kept with machines
would be damaged or destroyed. They stated that instructions would be subject to vandalism
or would disappear if kept with machines or vehicles. They also said instructions would
become dirty or be destroyed due to adverse weather in which machines and vehicles are
operated. As a result, these commenters stated that they store operator instructions at
the company office, in the crew transport vehicles or at the work site.
Second, several commenters said that it was not necessary to keep instructions with
machines because they have limited utility (Ex. 9-4; Tr. W1 134, 186, OR 80, 117, 378,
430, 629). Some of these commenters said instructions pertain primarily to maintenance of
machines and scheduling of maintenance and, therefore, should be kept where the
maintenance will be conducted. Other commenters said that instructions contain such
general information about machine operation that their only utility is for someone who is
unfamiliar with the operation of the machine. Instead, these and other participants said
the manuals should be used in operator training sessions.
Third, some participants said that instructions are currently given to new employees to
read as part of their orientation sessions (Tr. W1 66; OR 31, 263, 629). These
participants also said that if operators need to refer routinely to instructions at the
work site, they should not be allowed to operate the machine and should receive additional
training rather than being allowed to rely on the instructions.
After reviewing the comments and testimony received, OSHA has decided in the final rule
to require that operating and maintenance instructions be available on the machine or in
the area where the machine is being operated, such as at the landing or in a crew
transport vehicle located in the area where the machine is being operated. OSHA believes
ready access to instructions is important for several reasons. As OSHA explained in the
preamble to the proposed rule, instructions are necessary not only for maintenance
personnel but also for operators who are unsure or unaware of safe operating procedures
pose hazards to themselves and co-workers. Maintaining these materials in the immediate
work area of the machine assures their availability and increases the likelihood of their
use when needed by the operator.
OSHA also believes that instructions have utility for operators in specific
circumstances. Instructions give the operator a ready reference source when a new or
unique situation is encountered (e.g., operations on terrain where a combination of
hazards are present, such as swampy, rocky or loose ground). If unusual problems or
emergencies requiring prompt correction arise during operation, the instructions provide
the operator with correct information to resolve the problem rather than guessing about a
solution. In addition, some machine operators perform their own maintenance. By keeping
instructions on the machine or in the immediate work area, these operators can quickly
deal with maintenance issues as they arise. Therefore, OSHA believes that instructions are
useful for the operator only when they can be immediately accessed rather than being
housed at an office that may be miles from the work area or maintenance area.
OSHA also agrees with commenters who said that if instructions are not kept in the work
area of the machine they will not be used. OSHA is concerned that if instructions are not
in the area where the machine is being operated, operators will be discouraged from
stopping production to go get the instructions. Instead, employees will decide to
"take their chances" in dealing with unusual problems or emergencies, which
could result in serious injury.
With regard to the issue of weather damage to instructions which are kept on the
machine or in the machine work area, OSHA notes that a hearing participant pointed out
that in recent years, manufacturers have been providing weather-resistant instructions
which may be kept with machines (Tr. OR 205). Moreover, it should not be overly difficult
for an employer to place the instructions in a weather-proof bag to keep them with the
machine.
OSHA does agree with commenters' position that if an operator must routinely refer to
instructions in order to operate a machine or vehicle, additional training or supervision
is necessary. The final rule does provide such additional training for that operator.
However, there may well be instances in which the employee may need to consult the manual
in order to deal with a problem that arises during the use of the equipment. For that
reason, the instructions should be immediately available to employees. Therefore, OSHA is
requiring in this final rule that instructions be maintained in the immediate work area of
the machine so they will be available both to the machine operator and to maintenance
personnel.
b. Obtaining operator manuals or instructions. In the hearing
notice OSHA also requested employers to discuss their experience with trying to obtain
operating instructions or replacement instructions from dealers and manufacturers. OSHA
wanted to gather information on the number of machines that come with instructions and on
the degree of ease in obtaining replacement instructions. Very few participants commented
in this issue.
One hearing participant said that manufacturers do provide instructions with new
equipment, but used machines that are sold may have no instructions (Tr. OR 31). However,
two hearing participants said that replacement instructions are available either from the
manufacturer or the dealer, and therefore, they have had no more difficulty in obtaining
instructions than in acquiring any machine replacement part (Tr. W1 201, OR 197).
OSHA therefore believes that the requirement that instructions for machine be
maintained will not be burdensome for employers, even where employers must obtain
replacement copies from the manufacturer.
* * *
Back