Text from
the OSHA Logging PreambleSection V: Summary and
Explanation of the Final Standard
Paragraph (d) General Requirements
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First-Aid Kits
At paragraph (d)(2) of the final rule, OSHA is requiring that employers provide
first-aid kits. The proposed standard contained this provision. First aid kits are also
required by every State Plan State logging standard. OSHA did not receive any comments
opposing this requirement in general.
Paragraph (d)(2)(i) of the final rule requires that first-aid kits be at each work site
when felling is being conducted, at each landing and on each employee transport vehicle.
The proposed rule stated that first-aid kits be provided "at the work site."
Several commenters said that OSHA should define the term "work site" (Ex. 5-39,
5-53, 5-55, 5-63) in the final rule. They also said that having kits available at the
landing should provide adequate protection. However, another commenter said chain-saw
operators working away from the landing need first-aid kits and should each be required to
carry a small first-aid kit that contains supplies to stop bleeding (Ex. 5-28).
In the final rule, OSHA has clarified its intention regarding having first-aid kits at
each work site. First, the records shows that first-aid kits are necessary at each work
site when felling is being conducted and not just at landings. According to the WIR
survey, more than one-half of all injuries occurred at the cutting site, while only
one-fifth of the injuries were at landings (Ex. 2-1). OSHA believes that immediate
assistance must be provided for injured cutters. As discussed above in the Major Issues
section, many logging establishments have central offices, but their crews are performing
operations miles from that central location. OSHA has received testimony that cutting
crews are often spread out and in remote locations (Ex. 5-34; Tr. OR 21). These commenters
said crews are often located more than one-half hour away from a central office or spread
across five square miles. First-aid kits that require that much time to access are of
limited value to an injured employee. When an injury is severe, the lack of immediately
accessible first-aid materials and trained personnel could result in permanent disability
or death. Therefore, OSHA is requiring that first-aid kits be provided at each work site
where trees are being felled.
Second, OSHA is also requiring first-aid kits to be provided at each landing. As
discussed above, one-fifth of all injuries reported in the WIR survey occurred at landings
(Ex. 2-1). First-aid kits at landings are also necessary to provide assistance to other
injured employees, such as those on skid trails. According to the WIR survey, nearly
one-fifth of employees injured were on skid trails.
Third, OSHA is retaining the requirement from the proposed rule that first-aid kits be
provided on each crew vehicle. The WIR survey indicates that employees are injured on
employer-built roads while enroute to and from work sites (Ex. 2-1). One commenter stated
that requiring first-aid kits on each employee transport vehicle could result in several
kits being at each work site (Ex. 5-35). Nothing in the standard prohibits an employer
from using the employee transport vehicle kits by a felling crew during the workshift,
provided they are returned to the crew vehicle when it is moved at the end of the
workshift.
Paragraph (d)(2)(i) of the final rule also requires that the employer, in determining
the appropriate number and contents of first-aid kits, to consider the degree of isolation
of the work site, the number of employees at the work site and the hazards reasonably
anticipated at that work site. The further a crew is from a central landing, the more
crucial a first-aid kit is for that remote crew. For example, large and well-supplied
first-aid kits are needed where crews are so remotely located that rescue units (either
vehicles or helicopters) cannot get to the injured person or not get there quickly. When
crews are very small and located close to central landings smaller kits may be adequate,
when supplemented by kits at central landing areas that contain a more comprehensive
supply of first-aid materials.
Paragraphs (d)(2)(ii), (iii) and (iv) all deal with the adequacy of the contents of
first-aid kits. At paragraph (d)(2)(ii) of the final rule, OSHA has specified that each
first-aid kit must meet certain minimum content requirements. Those minimum content
requirements are delineated in mandatory Appendix A. OSHA received comments urging OSHA to
specify the contents needed for an "adequately supplied" first-aid kit (Ex.
5-21, 5-28, 5-50, 30). These commenters also pointed out that several State logging
standards specify minimum first-aid content requirements (Ex. 2-18, 2-21, 2-22, 2-23, 38J,
38K). In addition, one commenter also provided a list of minimum contents needed for
logging first-aid kits. Based on these comments and OSHA's expert judgment, the items
listed in Appendix A are the type necessary for dealing with injured persons in remote
areas of varying climatic conditions. OSHA points out that the specified contents are
minimally adequate for a small logging crew of two to three employees. Where crews are
larger, additional kits or kits with more supplies may be needed. In formulating this
final rule, OSHA included Appendix A (First-aid supplies) and Appendix B (First-aid
training) to provide the employer with a definitive means of determining the adequacy of
the first-aid kits and the training that employees must receive.
OSHA has deleted from the final paragraph the proposed requirement that first-aid kits
include snake bite kits. OSHA received several comments about this provision (Ex. 5-7,
5-17, 5-29, 5-35, 5-42, 5-50, 5-51, 5-55, 5-67). One commenter said this requirement
should be deleted since there were no poisonous snakes in his area (Ex. 5-7). Other
commenters said that some snake bite kits were not effective in treating bites or that
they are outmoded and can do more damage than good (Ex. 5-17, 5-29, 5-35, 5-42, 5-50,
5-51, 5-55, 5-67). For example, NIOSH said that it is possible more serious injury will
occur to a person by improper use of a snake bite kit (Ex. 5-42). According to the
Regional Snake Bite Control Center at the University Medical Center in Cincinnati, OH,
snake bite kits should not be used when medical treatment is available within one hour of
the bite (Ex. 5-42). OSHA has determined that, given the regional differences in the
logging industry, employers should be allowed to work with their health care provider to
determine whether a snake bite kit is necessary and what kind of kit would be of most
assistance for loggers working in that area. One of the factors the health care provider
should consider is how far particular loggers are from medical facilities and trained
medical personnel.
Paragraph (d)(2)(iii) requires a health care provider to review and approve annually
the first-aid kits the employer provides, both as to the adequacy of the kit's contents
and the number of kits provided. OSHA has added this requirement in the final rule for
several reasons. First, 1910.151(b) already requires that first-aid kits be approved by
consulting physicians. OSHA is aware that health care providers in addition to physicians
are qualified to approve first-aid kits and OSHA wants to provide flexibility for
employers in meeting this requirement. Second, 1910.151(b) only requires initial approval
of first-aid kits rather than periodic approval. However, OSHA believes that a periodic
review of first-aid kits is necessary and appropriate in the logging industry. This
industry is one in which the workplace is often not near medical personnel, infirmaries,
clinics, or hospitals that are best able to treat logging injuries. Therefore, it is
important for a health care provider to assess the contents of first-aid kits to see that
they contain those supplies that will provide effective assistance for an injured worker.
Once the kits are reviewed and approved, paragraph (d)(2)(iv) requires the employer to
maintain the first-aid kits in accordance with the approval conditions. Employers have the
duty to ensure that first-aid kits are adequately supplied and replenished as necessary.
In addition, the employer is responsible for assuring that kit contents are usable, that
is, there is no spoilage or damage due to weather conditions. For example, employers need
to periodically check first-aid supplies to ensure that materials are still in clean and
sterile condition.
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