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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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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.

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