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Text from the OSHA Logging Preamble Text from the OSHA Logging Preamble

Section IV: Major Issues

A. Introduction

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4. First aid. The hearing notice raised two issues about first aid: the number of employees who must have first-aid training, and the elements required as part of that training, such as cardiopulmonary resuscitation (CPR).

a. Number of employees trained. The proposed standard specified that all supervisors and all fellers be adequately trained in first aid methods as prescribed by the American Red Cross, the Mine Safety and Health Administration or an equivalent training program. In addition, the proposed rule included a provision that at least one person in the "operating area" have first-aid training.

OSHA received many comments regarding the number of employees who should be trained in first aid in order to provide adequate protection. There was no consensus among those commenters on the appropriate number of employees who must be trained. Their recommendations about the number of employees who should be required to receive first-aid training covered a wide range of options, including the following:

  1. All employees (Ex. 5-7, 5-17, 9-15, 9-20; Tr. W1 175, W2 209, OR 100, 375, 393, 681);
  2. All supervisors and fellers (Ex. 9-3, 9-13);
  3. All supervisors and enough additional personnel so each work site would have a trained employee (Tr. OR 21);
  4. All supervisors and fellers, plus two additional employees on a logging job (Ex. 5-54; Tr. OR 647);
  5. All supervisors, fellers, and one-fifth of remaining crew members (Ex. 9-19, Tr. OR 282);
  6. All supervisors, fellers and one-fourth of remaining crew members (Tr. OR 206); and
  7. All supervisors and some fellers (Ex. 5-36, 5-53, 5-55, 5-63).

Commenters who recommended first aid training for a limited number of employees, said that training all fellers or all other employees was excessive since the proposed rule would also require employees to work within visual or audible contact of another employee (Ex. 5-36, 5-55). Another commenter said that requiring all fellers to be trained would be duplicative since more than one feller may work at a work site (Ex. 5-63).

Other commenters said they already provide first-aid training for each employee:

Everyone -- all the people on our crew are trained [in first aid] on a rotating basis. Now, the fellow that's been with us six months, he has not been to the first-aid class yet. Also, one of the -- I believe it's in with the Nortim Corporation, the Nortim self insured, it is one of the regulations that we do have people on the job that are versed in first aid (Tr. OR 174).

Another hearing participant stated:

Along with overall safety training, I feel that required first aid training for all employees is simply common sense (Tr. OR 393).

Other commenters indicated that they are providing first aid training to a substantial portion of employees, in part because the company's logging operations are in isolated locations in Alaska:

Mr. Lesser: Does your training program include first aid training?

Mr. Bell: We provide first aid training to just about whoever wants it.

Mr. Lesser: Who do you require to have first aid training?

Mr. Bell: We require all supervisors, leadmen, hook tenders, leaders of crews.

Mr. Lesser: Using the voluntary nature offering the first aid, do you get a lot of volunteers? What percentage of the work force is trained in first aid?

Mr. Bell: I'd say 35 percent (Tr. OR 375).

As discussed above, there is no dispute that logging is a hazardous industry. All data sources in the record show that a significant number of accidents occur in the logging industry and that the severity of injuries sustained by loggers is greater than that suffered by employees in other industries. Loggers often work in isolated locations that are far from hospitals or health care providers that sometimes are accessible only by helicopters or vehicles designed to operate on the most rugged terrain (Ex. 9-20; Tr. OR 21). Accordingly, loggers need to be trained and equipped to handle the significant number of severe injuries that might arise. In many instances these trained employees will be the only persons available to render assistance at a critical time.

OSHA believes that first aid training for only a select few individuals, such as supervisors and fellers, is not adequate to ensure that injured loggers receive first aid that is timely and appropriate. First, when only a few selected employees are trained, they may not be close enough to the site of the accident to render assistance in time. The WIR survey indicates that more than one-half of all injuries reported occurred at cutting sites, that in most cases are remote from landings and from medical facilities (Ex. 2-1). The WIR survey is consistent with the OSHA FCI study, that indicated that more than 70 percent of logging employees killed were working at cutting sites (Ex. 4-61). One hearing participant reinforced this problem:

The rigging crew is often 1,000 feet and sometimes 5,000 feet from the landing. The work site is usually on rough, steep ground, and these workers often use hazardous cutting implements such as axes and chain saws. If the first aid trained person and the first aid kit are in the yarder, that can be 15 minutes or more from where the worst exposure is (Tr. OR 21).

In addition, since the final rule allows employees to maintain contact with another employee by visual or audible contact, an employee may be miles from the contact person when radio communication is used. In such cases, the contact person may not be able to provide immediate first aid assistance.

Second, limiting first aid training to all supervisors and some additional personnel may not be adequate when supervisors are not at the work site when an accident occurs. According to the State of Washington, logging supervisors usually have two or more logging crews working directly for them (Ex. 5-34). These logging crews are often dispersed over five square miles or more. In addition, in larger operations, foremen usually see each crew only once a day and rarely for more than one hour of the workshift. Another commenters said in his experience it was not uncommon to find a group of employees working in a location without a supervisor and no other employee in the group has a current first aid certificate (Ex. 91-5).

Third, a logger's injuries may be of such severity that several persons trained in first aid may be needed to stabilize the injured employee and treat the injury. If only one employee is trained, the first aid assistance may not be sufficient.

Fourth, when only one employee in a work site is trained, as the proposed rule contemplates, first aid will obviously be inadequate if the trained person is the one who is injured. (Although first-aid training does include instruction in self-aid, the injuries may be severe enough to incapacitate the trained employee.) For example, in a small working crew that has no supervisor, the feller may be the only employee who is trained in first-aid. If the feller is injured, there may be no other logger in that work crew who is trained to provide first aid. The WIR survey indicates that one-half of all loggers who were injured were performing felling tasks (i.e., felling, limbing, bucking) at the time.

Fifth, when only a few employees receive first-aid training, there is a greater likelihood that there could be crucial gaps in coverage due to sickness, vacations, other leave, or employee turnover of those few who have received training. In addition, an employer may not know from day to day if an employee will be present that is holding a current first aid certificate (Ex. 5-7).

OSHA notes that some commenters opposed requiring every employee to have first-aid training because of the transient nature of the logging industry. OSHA finds that the commenters' argument does not support the position that fewer employees should be trained. If there is high employee turnover, it may be the trained employee who is not employed any longer. If work continues without a fully-trained person while a first-aid replacement is being trained, employees may be at great risk. By contrast, if work has to be stopped until a replacement can be trained, the employer could incur costs which could be prevented by having adequate first aid coverage in advance. If all employees working in the logging industry are required to have first-aid training, a pool of trained employees will always be available to employers for hiring.

Fifth, requiring that each employee be trained eliminates confusion and may be less administratively burdensome than making a daily check and rescheduling of work assignments to assure that supervisors, fellers and some additional number of employees in each operating area hold current first aid training certificates.

To ease the training burden for employers, the final rule does not require that the first-aid training be provided by the employer. Rather, the final rule requires that the employer assure that each employee performing logging operations receives or has received first-aid training and that the first-aid training/certificate is current. For example, as one means of complying with the final rule, the employer could make first-aid training a condition of hiring or continued employment. The employer would be free to hire only those persons who had previously obtained first-aid training and kept their certificate current. In addition, when there is employee turnover, trained employees will be able to bring their first-aid skills from one workplace to another and thus relieve the training burden for the new employer.

OSHA is aware that some employers currently provide first-aid training and most likely will continue to provide such training. OSHA is also aware that a number of organizations and schools provide first-aid training that would meet the requirements of Appendix B. For example, the American Red Cross, the Mine Safety and Health Administration, State extension services, community colleges, and adult education programs all provide first-aid training that includes CPR. As such, OSHA does not believe that the requirement of assuring that all employees have received first-aid training that remains current will pose an unreasonable burden on any employer or employee.

b. Elements of first-aid training. In the hearing notice, OSHA requested comment on the specific elements, such as CPR, that should be included in first-aid training. In the proposed rule OSHA did not specify the basic elements in which supervisors and fellers must be trained. Rather, OSHA proposed that first-aid training meet the requirements of courses provided by the American Red Cross, MSHA or an equivalent training program.

Several commenters recommended that OSHA require CPR training as part of required first-aid training (Ex. 5-42, 5-49, 5-50, 9-2, 9-19). Both NIOSH and the U.S. Dept. of Interior supported the CPR training requirement. Because loggers, especially those deep in the woods are not close to medical facilities during the "golden hour" where resuscitation may save a person's life, OSHA agrees with the commenters that it is essential that all loggers be able to perform CPR. Therefore, in the final rule OSHA has included a requirement for annual CPR training.

In addition, OSHA has specified other basic skills and knowledge in Appendix B (mandatory) that are important for providing aid to injured loggers in isolated settings. OSHA is aware that there are many well- recognized first-aid programs that have broad-based curricula which already satisfy OSHA requirements.

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