We are excited that the Occupational Safety and Health Administration (OSHA) has taken the next step toward issuing a federal safety standard for tree care operations. For over 20 years, TCIA has urged the U.S. Department of Labor to promulgate a tree care safety standard, and we are asking for your support now to encourage OSHA to build upon the significant progress OSHA has made over the past year.
Why We Need a Standard
Tree care is inherently hazardous work and, sadly, the fatality rate for tree care workers is about 30 times higher than the fatality rate for private sector workers overall. Yet, OSHA has historically relied on a patchwork of standards intended for other industries to regulate tree care work. Equipped with standards that only peripherally address tree care issues, OSHA inspectors, small businesses, and tree care workers run the risk of overlooking serious worksite hazards or misidentifying the practices and procedures that are best for mitigating risk of work-related illnesses or injuries. This dysfunctional approach to compliance and enforcement wastes government and industry resources, leads to unnecessary litigation, and fails to provide any clear guidance to employers, workers, and OSHA officers as to what are the most effective safety measures for the industry. This is why for over two decades, TCIA has urged OSHA to move forward with tree care specific standard.
OSHA Moves Forward on Industry-Specific Standard
On March 22, 2020, OSHA formally convened a Small Business Advocacy Review and during the month of April, small businesses provided OSHA and the panel with their thoughts and concerns regarding OSHA’s draft regulatory framework for a potential Tree Care Operations standard. On May 22, 2020, the panel submitted their Final Report
to OSHA, which includes the panel’s findings and recommendations (pgs. 30-41 of the report) and addresses issues and concerns raised by small businesses. Importantly, the report stated that, “in light of the significant risks preliminary identified. . . , the Panel recommends that OSHA proceed with a tree care operations rulemaking,” and “that any specific provision in a proposed OSHA standard not substantially deviate from any corollary ANSI Z133 standard to the extent practicable.”
We Need Your Help! Please Comment!
Now that the panel has concluded and their report has been published, the public has an opportunity to provide comments on the potential Tree Care Operations Standard. This is where we need your help! Just because OSHA convened a SBREFA panel on Tree Care Operations does not mean that they will move forward with the rulemaking process. We need our members collective voice to encourage OSHA to move forward with this standard.
We need you to submit comments and have drafted this letter
for you to send to OSHA. Of course, this is just a template, so please feel free to edit the letter any way you see fit.
Click here to submit your comment!
This link takes you to the Tree Care Operations comment page on the Federal Rulemaking Portal. For more information, visit http://www.regulations.gov, and search for the Tree Care Operations docket by typing the following Docket number into the search bar: (OSHA-2008-0012).
Please reach out to Aiden O’Brien (firstname.lastname@example.org) if you have any questions. Thank you for your help!