The tree care and removal industry has long been recognized as a high hazard industry and represents approximately 10% of all fatalities investigated by MOSH within the last five years. It is believed that through a local emphasis program, that increases awareness and accelerates enforcement activity, injuries can be reduced. It is also recognized that a tracking mechanism for these types of inspections would prove beneficial in monitoring the area of tree care and removal. In the past, many un-programmed inspections have been conducted through CSHO self-referrals, imminent danger complaints, or accident and fatality investigations. This LEP is designed to increase industry awareness, provide tracking, and formalize procedures.
MOSH compliance personnel shall ensure that the procedures contained in this Instruction are followed when conducting this LEP. The Regional Offices will implement the procedures described in this Instruction in response to imminent dangers or serious hazards that are identified as related to tree care and removal. The Regional Supervisors shall use this LEP as a basis for scheduling and conducting safety inspections of tree care and removal operations. This LEP is intended to be used on any site where potential hazards related to tree care and removal operations have been alleged and/or identified to initiate safety inspections.
- An inspection targeting system which encompasses identification of sites at the beginning of the quarter and the random selection of sites is not practical. Hazards related to tree care and removal operations are normally transient and of limited duration. This limits the practicality of targeting the site in advance. Therefore, inspections conducted under this LEP would be initiated by several means: Compliance Officer observance, non-formal complaints, and referrals from other outside sources.
- Work sites where potential hazards related to tree care and removal operations are observed by Compliance Officers will be selected for inspection under this LEP. Employee exposure to related hazards does not have be observed, only the presence of potential hazards while performing tree care and removal operations (i.e. use of chippers, chain saws, cranes, and aerial lifts; lack of proper personal protective equipment such as chaps, head protection, fall protection, eye protection and hearing protection; and/or lack of appropriate traffic control measures on public roadways) need to be observed to conduct an inspection.
- A large number of hazards related to tree care removal and operations are reported via referrals and complaints, both of a formal and a non-formal nature. Formal complaints of hazards related to tree care removal and operations will continue to be scheduled before programmed inspections.
- The IMIS identifier code to be used in item 25c on the OSHA-1
will be "TREE".
cc: J. Ronald DeJuliis, Commissioner, Division of Labor and Industry
Jonathan Krasnoff, Assistant Attorney General
Office of Administrative Hearings
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