Home
Standards
Glossary
User Guide
Logging Advisor
Text from the OSHA Logging Preamble Text from the OSHA Logging Preamble

Section IV: Major Issues

A. Introduction

*   *   *

8. Riders. In the hearing notice OSHA requested comment on whether trainers should be permitted to ride on machines to observe operator performance. The pulpwood logging standard prohibited riders or observers from riding on machines unless seating and other protection were provided. The proposed standard continued that prohibition.

Many commenters supported the current and proposed prohibition of riders on machines (Ex. 5-7, 5-22, 5-42, 9-3, 9-13, 9-18; Tr. W1 202, 205, 235, W2 227, OR 155, 169). These commenters said riders should be prohibited, unless protection is provided since they are exposed to the same hazards as machine operators, for whom seating, seat belts and other protection is required. NIOSH, for example, supported the prohibition for the following reasons:

Many logging operations occur on rough terrain which would expose any rider to a high risk of injury or death. Serious errors made by a trainer or trainee under these conditions endangers both people; it must be recognized that logging equipment is not designed for training purposes (i.e., the trainer cannot take control of the equipment from the trainee in a safe, orderly fashion) (Ex. 5-42).

NIOSH therefore recommended that training be conducted and completed in pre-worksite training where the environment can be "controlled" instead of the employer conducting "on-the-job" training with machines that are not designed to carry passengers safely. Another commenter agreed that the necessary operator training should be given, and the operator should be afforded the opportunity to practice on level ground, before the operator moves into work areas. This training and practice would allow operators to become proficient without requiring trainers to ride on the machines (Tr. OR 155).

Two commenters, including one who supported the exemption for trainers, stated that it was not absolutely necessary to have the trainer riding on the machine in order to maintain communication with the machine operator (Ex. 5-27; Tr. W2 227). They said communication could be accomplished through radio contact (one-way or two-way radios), thus allowing the trainer to remain in a safe location on the ground. One of the commenters pointed out that this method is currently used in logging operations in Scandinavian countries (Tr. W2 227).

Many commenters supported an exception permitting trainers to ride on machines (Ex. 5-12, 5-22, 5-28, 5-36, 5-45, 5-49, 5-53, 5-54, 5-55, 5-63, 5-74 through 5-92, 9-2, 9-5, 9-10, 9-13, 9-19; Tr. OR 32, 201, 206, 337). These commenters said that an exemption be allowed because trainers were not as great since they ride for only short periods and, therefore, they are not exposed to hazards to the same extent as machine operators. However, several commenters said that if instructors were permitted to ride on machines that at least seat belts should be required and training should be conducted on level terrain (Ex. 5-27, 9-3, 9-13; Tr. OR 169). Another commenter said that trainers should not be permitted to ride on machines during actual production because "such conditions may not be conducive to rider safety" (Ex. 5-54).

Other commenters said the exemption should include other employees in addition to training (Ex. 5-27, 9-2; Tr. OR 206). One commenter supported expanding the exception to allow mechanics to ride on machines (Tr. OR 206). Another commenter said that the exception should be permitted for large multi-purpose logging equipment where there is sufficient room in the enclosed operator cab to permit another person to ride safely, even though there is not a second seat (Ex. 5-27). One commenter said fellers should be permitted to ride back to the landing at the end of the workshift (Ex. 9-2). However, none of these commenters provided any evidence that these riders were not exposed to the same hazards as the machine operator.

OSHA has carefully considered all comments and data in the record. OSHA agrees with the commenters that riders face the same hazards as machine operators on moving equipment and that they need protection equivalent to that of the operator. According to logging fatalities reported to OSHA between 1985-90, there were reports of riders killed when machines roll over (Ex. 4-65). The OSHA FCI report also indicated that loggers have been killed riding on unauthorized parts of machines (Ex. 4-61). Even those who opposed the prohibition on riders recognized that such an activity is hazardous due to conditions of the work environment, such as unlevel terrain. In addition, the record indicates that an exemption for trainers is unnecessary because other methods of communication between the trainee and trainer are available and in use in the logging industry. As such, OSHA has retained the requirement in the final standard that machines must have passenger protection equivalent to operator protection if the employer allows riders on machines.

*   *   *


Back Back

tracking image