Oscar Santacruz
ArboristSite Lurker
(I am sorry, the big picture is not good in the front, I can`t read too).jmack said:
Jmack ANSI Z133.1-2000 ANSI Z133.1 676 "A Qualified Arborist", Crane safe work practices in arboricultural(TCIA). We are professional and a qualified tree trimmers. Mr. Tim Wash thank you so much by this comments, this arborist site have the best professionals like you jmack, Tim Wash is a arborist-site member that`s great. I found below Tim Wash comments in http://www.dir.ca.gov/oshsb/treeclimbinggandaccessFSOR.doc
FINAL STATEMENT OF REASONS
Title 8: Chapter 4, Subchapter 7, Article 12, Section 3427
of the General Industry Safety Orders (GISO).
Tree Climbing and Access
MODIFICATIONS AND RESPONSE TO COMMENTS RESULTING FROM
THE 15-DAY NOTICE OF PROPOSED MODIFICATIONS
No further modifications to the information contained in the Initial Statement of Reasons are proposed as a result of the 15-Day Notice of Proposed Modifications mailed on November 2, 2004, and Board staff evaluation.
Summary and Response to Written Comments:
Mr. Tim Walsh by e-mail received November 19, 2004.
Comment No. 1:
Mr. Walsh expressed concern regarding the potential wear on the climbing line when workers tie directly into the crane hook as permitted by Section 3427(a)(1)(A). He stated that there are several techniques for tying in without using the hook.
Response:
The proposed standard would permit that a qualified tree worker may be hoisted into position by using an approved tree worker saddle secured to a crane’s hook that is equipped with a positive locking device. This provision addresses any potential that a line would roll out of the hook.
The advisory committee discussed at length various methods and means for being secured to the crane line and/or hook. The committee felt that being secured to the crane hook would not create a hazard especially in light of the crane orders that require a daily inspection of the crane hook for any deformation or cracks that might cause wear on the climbing line.
Further, any wear to the climbing line over time would be identified during the inspection that is required prior to the use of all equipment and safety devices as outlined in the general requirements for tree work in Section 3421(e). For added protection, this section also requires an independent line attached above the crane hook. Therefore, the Board does not believe modification to the proposal is necessary as a result of this comment.
Comment No. 2:
In Section 3427(a)(2), the reference to a “taut-line hitch” is too specific and restrictive. There are many other, better friction hitches and devices in use today. Mr. Walsh recommends changing the term to read, “approved friction hitch.”
Response:
See the response to written Comment No. 3, from Ms. Cynthia Mills, The Tree Care Industry Association, submitted during the 45-Day public comment period.
Comment No. 3:
Mr. Walsh stated that one of the most dangerous times for workers while aloft is when they are repositioning. With regard to Section 3427(a)(5), the standard allows for a worker to not be tied in while they are recrotching. Mr. Walsh stated that it is safest when climbers have two means of attachment so they can remain secured while recrotching.
Response:
The comment may have merit; however, this subsection is applicable not only to qualified tree workers involved in crane operations, but also to all provisions contained in Article 12 related to tree maintenance or removal work. The scope of subsection (a)(5) is broad based, and was not included in the amendments noticed for public comment. Therefore, amendments to this subsection are outside the scope of this proposal and could be considered at a later date in a future rulemaking action.
MODIFICATIONS AND RESPONSE TO COMMENTS RESULTING FROM
THE 45-DAY PUBLIC COMMENT PERIOD
There were no modifications to the information contained in the Initial Statement of Reasons except for the following substantive, sufficiently related modifications that are the result of public comments, advisory committee deliberations and Board staff evaluation.
Section 3427. Safe Work Procedures.
Section 3427 is located within Article 12 of the General Industry Safety Orders (GISO) and provides safe work procedures for climbing and accessing trees, pruning and trimming, and tree removal activities.
Subsection (a)(1)
Proposed subsection (a)(1) requires that prior to climbing the tree, the tree shall be visually inspected by a qualified tree worker who shall determine and ensure a safe method of entry into the tree. Federal OSHA contacted Board staff and requested that the subsection be clarified to ensure that the employer is responsible for ensuring that the tree is inspected. Consequently, a modification is proposed which requires the employer to ensure that the tree be visually inspected by a qualified tree worker. The modification is necessary to address federal OSHA’s concerns and to provide clarity to the standard.
Subsection (a)(1)(A)
Proposed subsection (a)(1)(A) states that only when a tree cannot be safely accessed by climbing or using aerial devices, a qualified tree worker may be hoisted into position by using an approved tree worker’s saddle suspended from a crane’s closed safety type hook that is equipped with a device or locking means to prevent the load from becoming disengaged.
It is proposed to modify subsection (a)(1)(A) to read, “Only when a tree cannot be safely accessed by climbing or the use of aerial devices, a qualified tree worker may be hoisted into position by using an approved tree worker’s saddle secured to a crane’s hook that shall be closed with a positive locking device.” The proposed modifications are based on advisory committee consensus and are necessary to provide clarity.
Proposed subsections (a)(1)(A)1. through (a)(1)(A)8. provide requirements to ensure that safe procedures, climbing equipment and crane operations are provided when a crane is used to position personnel. A modification is proposed to add two additional subsections, which (1) would require that cranes used for tree work be equipped with a functional load indicating device, and (2) the crane operator be familiar with the potential hazards and operational techniques encountered in tree work. The required load indicating device measures the weight of a load and is necessary to prevent the crane from becoming overloaded. Representatives of tree removal companies and contractors have stated that cranes used for tree maintenance or removal purposes on their job sites are already equipped with this device. The requirement that crane operators be familiar with the potential hazards and operational techniques encountered in tree work is necessary as some operators may be unfamiliar with those hazards and operational techniques that are unique to tree work. Editorial changes renumber the remaining items in this subsection.
Proposed New Subsection (a)(1)(B)
The Board received comments and concerns that the proposal should include training requirements for qualified tree workers involved in tree work utilizing a crane to position personnel. With the assistance and consensus of the advisory committee members, modifications to the proposal were developed to add special training requirements. The training provisions require the qualified tree worker to receive instruction, training, and be competent in: (1) safe work procedures and knowledge of the hazards applicable to tree work involving the use of cranes, (2) the use of personal protective equipment required for tree work, (3) the inspection and safe use of all climbing equipment, lines and rigging, (4) crane signals and communication requirements with the crane operator as provided in Section 5001, (5) instructions regarding electrical hazards as described in Section 3423, (6) the safe use of chain saws in tree work, (7) the conditions and criteria necessary to permit the use of a crane to provide access into a tree,
(8) the handling of loads as described in Section 4999 and rigging techniques for tree work, and (9) effective means for controlling pedestrian and vehicular traffic. The modification is necessary to address the expressed concerns that qualified tree workers be instructed, trained and competent in safe work procedures related to crane use for tree work.
Proposed New Subsection (a)(1)(C)
A modification is proposed to add new subsection (a)(1)(C) that would require the documentation of employee training per subsection (a)(1)(B) be maintained as prescribed by Section 3203. The modification is necessary to ensure that employee training is documented, and that these training documents are maintained.
The modification is necessary to address the expressed concerns that qualified tree worker be instructed, trained and competent in safe work procedures related to crane use for tree work, would you please dears members what do you think about this importand matter. Be safe partners. Oscar Santacruz.
