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