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

Paragraph (d)(2)(iii) -- First-Aid Kits

Paragraph (d)(2) of the final rule requires that employers provide and maintain first-aid kits. In addition, this paragraph specifies the minimum content requirements for first-aid kits (Appendix A). These provisions became effective February 9, 1995.

OSHA stayed the requirement that the number and contents of first-aid kits be reviewed and approved annually by a health care provider. Some parties told OSHA that annual approval of first-aid kits by health care providers would be burdensome for employers. Because the final rule already contains a list of minimum contents for the first-aid kit, OSHA is persuaded that eliminating the requirement of annual health care provider review will not reduce protection for logging employees.

The minimum first-aid kit and first-aid training requirements provided in the final rule were developed in consultation with the OSHA offices of occupational medicine and occupational health nursing. This careful review of the minimum contents of the required first-aid kits makes it unnecessary for OSHA to require employers to have the kits reviewed annually by a health care provider. Therefore, OSHA is correcting the final rule accordingly.

At the same time, however, OSHA encourages logging employers to conduct an annual review of the contents of first-aid kits, including engaging in consultation with a health care provider regarding approval of those contents. Such review can help to ensure that the contents are adequate for the number of employees and conditions of the particular logging worksite, and that first-aid kits contain the latest first-aid innovations and technologies which would be useful to the logging work environment. Because of the remoteness of logging worksites from professional medical services, OSHA believes that for some logging sites, additional attention should be given to the contents of first-aid kits. Annual health care provider review is clearly permitted in these circumstances, and the final rule provides for such review as a "best practice" recommendation for employers.(3)

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Footnote(3) OSHA notes that the employer does not need to take the actual first-aid kits themselves to the health care provider for review and approval. Rather, the health care provider may review the list of the items contained in the first-aid kits, along with a description of the conditions of the particular worksite.

Paragraph (d)(2)(i) -- Location of First-Aid Kits

In the final rule, OSHA required that employers provide first-aid kits at each landing, on each employee transport vehicle, and at each worksite where felling is being conducted. After the final rule was published, OSHA was requested to clarify whether first-aid kits must be provided at both active and inactive landings. It was not OSHA's intention to require employers to provide first-aid kits at landings which are not currently in use. OSHA is correcting the final rule to clarify that the provision of first-aid kits at landings refers to only "active" landings.

OSHA was also requested to clarify at what point a felling work site is considered separate or remote from another work site, thus triggering the requirement for an additional first-aid kit. In the revised compliance directive, OSHA has indicated that where employees are cutting trees more than one-half mile from an active landing or an employee transport vehicle, a first-aid kit also must be provided at that work site. In these situations, the first-aid kits which are at the landing or on the vehicle are too distant to be considered immediately accessible.

The compliance directive also indicates that where conditions are not optimal, such as steep or mountainous terrain, very muddy terrain, heavy brush, or snowy and icy conditions, first-aid kits cannot be as far as one-half mile from a cutting area and still be considered immediately accessible. Traveling under such conditions is likely to take far longer than under optimal conditions, thus rendering the first-aid kit too isolated to be of any prompt use. Where such conditions exist or are reasonably anticipated, the employer will have to evaluate their severity in determining whether cutting operations need first-aid kits to be located closer to the worksite.

Finally, OSHA is also correcting the final rule to clarify which felling work sites need first-aid kits. In the final rule, OSHA stated that first-aid kits must be provided "at each work site where felling is being conducted." It was OSHA's intention that felling work sites include any work site where trees are being cut; that includes limbing, bucking, and trimming as well as felling. The rulemaking record clearly shows there are a significant number of injuries wherever trees are being cut. For example, the WIR survey indicated that 23 percent of employees reporting injuries were felling trees and 27 percent were limbing and bucking felled trees (Ex. 2-1). Injuries to these employees are primarily due to chain saws or being hit by a falling or rolling tree. Because of the significant risk of injury, employees performing all of these logging operations need to have immediate access to a first-aid kit.

A further review of the record indicates that in many situations limbing and bucking are not done at the landing, but rather, at the place where the tree is felled (e.g., Ex. 4-63, 4-64, 26A). In addition, in-forest limbing and bucking is not always done near felling operations. For example, felling operations may be far from limbing and bucking crews. To the extent that a limbing or bucking work site is more than one-half mile from the nearest first-aid kit (i.e., felling area, active landing, or employee transport vehicle), OSHA is clarifying that a first-aid kit must also be provided for that limbing or bucking work site.

Appendix A to Section 1910.266 -- First-Aid Kits (Mandatory)

The final rule specifies the minimum contents of first-aid kits that employers must provide. The minimum content list was developed in conjunction with OSHA's offices of occupational medicine and occupational health nursing.

After publication of the final rule, OSHA was requested by some parties to drop tourniquets from the required list of items in first-aid kits. They told OSHA that current first-aid training courses teach people to use direct pressure to stop bleeding and to avoid the use of tourniquets in all but the most severe cases or when no other method will work. They were concerned that if tourniquets were included in logging first-aid kits, their use would be encouraged rather than discouraged. While OSHA is confident that employees trained and certified in proper first-aid techniques will use tourniquets properly, OSHA is also aware that other items commonly present at logging sites could be used as tourniquets (e.g., belts, ropes) if the need arose. Therefore, OSHA is correcting the final rule to delete tourniquets from the mandatory appendix specifying required first-aid contents.

OSHA is also deleting recordkeeping forms from the list of mandatory first-aid kit contents. The recordkeeping forms referred to here were not OSHA 200 accident logs; rather, they were forms that would provide information for the health care provider about the employee's injury and condition if medical attention is necessary and the employee is unable to communicate. Nonetheless, OSHA is removing this requirement to avoid confusion with recordkeeping that is required in accidents and injuries in general. At the same time, OSHA emphasizes that employers should establish a method for communicating to health care providers information concerning injured employees.

OSHA is also deleting the requirement that first-aid kits contain diphenhydramine hydrochloride elixir or capsules (i.e., Benadryl). Even though this over-the-counter medicinal product is frequently used in the logging industry to reduce the effects of insect bites and bee stings, prescribing its use is beyond the scope of first-aid training in this standard.

The requirement that each first-aid kit contain blankets is being revised to indicate that each kit must, at a minimum, contain at least one blanket. OSHA intended the term blankets to be used generically and not to set forth a required number of blankets which must be present.

Finally, OSHA is correcting the splint requirement in Appendix A. In the final rule OSHA had specified that first-aid kits be equipped with wire splints. However, the rulemaking record indicates that other types of splints would be as effective as wire splints and OSHA did not intend to preclude their use. These include, for example, inflatable or air splints. This correction will provide more flexibility for employers in providing first-aid kits that incorporate the latest medical technology and innovations.

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