TCIA assists its members with regulatory compliance in three main ways: Long before regulations are passed into law, they must go through a period of development with input from the people they affect. TCIA acts as the voice of the commercial arborist by providing information and guidance in the development of responsible, realistic new standards.Once promulgated, new standards must be followed, but understanding them can be difficult and confusing. TCIA simplifies the process by developing compliance guidelines that are relevant and easy to understand for the arborist/manager.
Occasionally, there are regulations that are misapplied to arborists, or laws that are unjust or unworkable. The TCIA works with the industry and the various regulatory agencies to try to straighten out issues such as these.
Click here for the standards that were most frequently cited by Federal OSHA for tree service businesses during the last fiscal year.
To help your firm with compliance, TCIA’s Model Company Safety Program contains a detailed summary of MUTCD requirements, along with illustrations. To learn more about MCSP, click here.
For Members Only: TCIA provides consultation with members of its staff for free. If you have questions relevant to the content matter of this part of our web site, please click here.
Proposed rulemaking on Hazard Communication
On September 12, OSHA published an advanced notice of proposed rulemaking seeking comments on its intention to adopt provisions of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). As part of adopting GHS, OSHA would have to amend the hazard communication standard to change the criteria for classifying hazards and meet standardized requirements for labeling and material safety data sheets.
Three other agencies are also considering adopting GHS provisions: Department of Transportation regarding transportation of chemicals; the Consumer Products Safety Commission regarding consumer products with hazardous chemicals; and the Environmental Protection Agency with respect to pesticides and chemical labeling under the Toxic Substances Control Act.
Proponents say adopting GHS will bring consistency across international borders making compliance easier for
chemical manufacturers, distributors and transporters.
Critics of GHS, however, say adopting the standard and changing how certain chemicals are classified will have significant consequences on business and household operations.
More details on the notice of proposed rulemaking and GHS are available at www.osha.gov/dsg/hazcom/ghs.html.
EPA Changes will affect pesticide application
The Environmental Protection Agency (EPA) has begun a very broad and long-term initiative aimed at stronger protections for pesticide workers.
The Agency is issuing a series of position papers, 24 in all, that will frame the intent of the EPA to establish regulation and guidance documents that will affect all applicator industries, including TCIA members. The issues will be discussed on a series of conference calls taking place through late October between the EPA, environmental groups, industry members, and state officials.
This initiative could have enormous effect on our industry. The two main issues in contention for us are the scope of competency for all applicators of all products nationwide, and the definition of direct supervision.
For example, the scope question addresses the complete training and licensing requirement for all applicators touching the gun. The direct supervision question will affect how many applicators a certified person can supervise, how far away the supervisor can be, at what distance, and the amount of applications allowed in a day under one license.
In order to respond appropriately to EPA, TCIA needs to find out where our members are on pesticide issues. We need to know what percentage of our members use or apply pesticides, the level of training accorded their pesticide applicators, how their applicators are supervised, etc. TCIA will continue to monitor the emerging issues from EPA and participate in the conversations as needed.
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