Tree-Trimming Demand is High – So is the Need for Better Safety

Extreme weather – a threat to property and tree trimmer safety

Extreme weather events in 2023, with damages of $1 billion or more, are blowing away weather records since 1980. As of September 11, there have been 23 extreme weather events, including two floods, 18 severe storms, one winter storm, one tropical cyclone, and one wildfire. From 1980 to 2022, there was an average of only 8.1 extreme weather events per year. The average has been rising over recent years.¹ Extreme weather means higher demand for the services of tree trimmers and pruners who use sophisticated climbing and rigging techniques to cut away dead or damaged tree branches to maintain right-of-way for roads, sidewalks, and utilities.² Even before the latest round of extreme weather, the Occupational Safety and Health Administration (OSHA) observed that tree trimmers and pruners, as a recognized job classification, had a fatality rate 30 times higher than the national average for all workers.³

“The fatality and injury rates for tree trimmers and pruners are extraordinarily high, much higher than the rate in most industries,” OSHA acknowledged in early 2020.⁴ The agency said the major risks are:

• Falls to lower levels, e.g., from trees, aerial lifts, boom trucks, and ladders
• Being struck by falling objects, such as tree branches or tools and equipment
• Exposure to electrical hazards
• Transportation incidents
• Contact with equipment, e.g., a chain saw, woodchipper, or stump grinder
• Damaged hearing or eyes

In April, the Tree Care Industry Association reported on U.S. Bureau of Labor Statistics’ data for about 63,700 tree trimmers and pruners nationwide. The preliminary estimated fatality rate for the industry was 110 per 100,000 and the nonfatal injury rate was 239 injuries per 10,000 workers (10,000 is used for injuries, 100,000 for fatalities).⁵

Does tree trimming need a national standard?

OSHA does not have a standard for tree trimming safety currently; however, the wheels have been turning for 15 years. In 2008, OSHA published a Notice of Proposed Rulemaking, a first step in the process of creating a new standard. Currently, national safety requirements for tree trimmers and pruners exist largely in what OSHA calls a “patchwork of regulations” and the Occupational Safety and Health Act’s General Duty Clause.^6,7

A national standard potentially would give field compliance officers better guidance in their work and business owners more clarity about safety requirements, OSHA said.⁸ OSHA updated enforcement guidelines for safety inspections in the tree care industry in the summer of 2021, provided additional information for interested parties, and reaffirmed that a new national standard is still being considered.^9,10,11,12

Assessing the local impact of a standard

As part of the rulemaking process, OSHA convened a Small Business Advisory Review (SBAR) panel, as required by the Small Business Regulatory Enforcement Fairness Act (SBREFA). The goal of such panels is to collect input from small government entities (city, county, villages, school districts, etc.) and small businesses on how a rule might affect them. The sessions were held as teleconferences in the spring of 2020.¹³ The panel’s report contains extensive comments.¹⁴

Small entity representatives (SERs) supporting the standard said it would help employers by streamlining today’s “patchwork of regulations.” They also saw a new standard as a way to “legitimize”  proper training and the use of personal protective equipment (PPE), while discouraging untrained people from doing tree care work.

SERs who opposed the standard said it was unnecessary because OSHA’s general industry standard for electric power generation, transmission, and distribution (29 CFR §1910.269) already covers requirements for training, job hazard analyses, PPE, and environmental hazards. They said tree trimmers tend to comply with the existing regulations’ provisions, even when they do not come under its jurisdiction. When problems arise, it’s because of accidents that no standard could prevent, they said.

The panel recommended that OSHA proceed with a standard but make sure its scope is precisely targeted so low-hazard, low-risk activities are excluded.

Line-clearance tree trimmer requirements

Much of the tree trimming that’s done involves line clearance to remove tree branches from within 10 feet of energized power lines. Line-clearance tree trimmers who have received specialized training to work this close to energized power lines and equipment are called “qualified” workers. OSHA says they are knowledgeable in the construction and operation of electric power generation, transmission, or distribution equipment and associated hazards.

Line-clearance tree trimmers don’t work in hazardous conditions (high winds, icing, thunder and lightning) but may work in the aftermath of a storm if they have been trained in the relevant special hazards involved.¹⁵

Workers without the specialized training of qualified line-clearance tree trimmers are called “unqualified” workers, meaning that they are not qualified to do this higher risk work within 10 feet of energized power lines, not that they are substandard workers. Unqualified workers must maintain minimum approach distances (MAD) that start at a minimum of 10 feet and increase four inches for every additional 10 kilovolts of voltage in the line.¹⁶

Smaller distribution power lines that deliver electricity to homes and neighborhoods are subject to state and local requirements and laws, applicable safety codes, and any limitations or obligations specified in property rights-of-way agreements.¹⁷

Line-clearance tree trimming is a popular practice to help reduce the risk of wildfires caused by tree limbs coming into contact with energized power lines, so it’s notable when a large utility decides to go a different direction. Pacific Gas and Electric Co. in northern California has decided to cut back its $2.5 billion tree-trimming program. Instead, the utility is burying power lines underground and setting above-ground power lines to shut off within a tenth of a second of a tree branch or other object touching them.¹⁸

Tips for employers, supervisors, and employees

Through an internet search, employers may be able to locate helpful resources on tree-trimming safety by state. One example is a TDI Safety@Work newsletter produced by the Texas Department of Insurance. It provides tree trimming tips for employers, supervisors, and employees.¹⁹

Selected tips are shown below.

Tips for employers

• Provide employees free PPE in good condition, such as hardhats, climbing spurs, harnesses, saddles and climbing lines
• Design and conduct training
• Survey job sites to make sure rules are being followed

Tips for supervisors

• Assess the job site for hazards and risk before work begins
• Decide between climbing and an aerial lift
• Make sure climbing gear is suitable for the type of tree and in good condition
• Ensure employees can communicate, ground-to-elevation
• Secure and mark a drop zone that is at least two times the height of the tree
• Work at least 10 feet from power lines and assume all power lines are live

Tips for employees

• Use the safety equipment provided
• Mark a drop zone so nothing falls outside it
• Identify and avoid power lines
• Know the capabilities of equipment and workers
• Keep chainsaws sharp
• Guard against the effects of temperature extremes

Safety begins before the first tree branch is cut

Employers of tree trimmers and pruners can enhance their injury prevention and safety efforts from Day 1 of bringing a new hire on board. Concentra® provides pre-employment screenings and examinations, such as drug testing, human performance evaluations, and return-to-work evaluations (for existing employees who have been gone for an extended period) to help ensure the employee can meet the job’s physical demands without undue risk of injury. Contact Concentra for pre-employment tests and screenings to promote safety and help reduce musculoskeletal injury, lost workdays, and employee turnover.

---

NOTES

1. “Billion-Dollar Weather and Climate Disasters.” National Oceanic and Atmospheric Administration. National Centers for Environmental Information. September 11, 2023
2. “Occupational Employment and Wage Statistics. Occupational Employment and Wages, May 2022. 37-3013 Tree Trimmers and Pruners.” U.S. Bureau of Labor Statistics. Updated: April 25, 2023. Accessed: September 13, 2023.
3. “Report of the Small Business Advocacy Review Panel on OSHA’s Potential Tree Care Operations Standard.” Regulations.gov (download document). Posted by the Occupational Safety and Health Administration on June 10, 2020. Accessed: September 13, 2023.
4. “Tree Care Operations Fact Sheet.” Occupational Safety and Health Administration. February 21, 2020. Accessed September 13, 2023.
5. “Tree-Work Safety by the Numbers.” TCI Magazine. The Tree Care Industry. April 1, 2023. Accessed: September 13, 2023.
6. “Tree Care Operations Rulemaking and OSHA Standards.” Occupational Safety and Health Administration. Accessed: September 13, 2023.
7. “Preventing Falls and Electrocutions During Tree Trimming.” Centers for Disease Control and Prevention. The National Institute for Occupational Safety and Health. August 1992. Accessed: September 13, 2023.
8. “Report of the Small Business Advocacy Review Panel on OSHA’s Potential Tree Care Operations Standard.” Regulations.gov (download document). Posted by the Occupational Safety and Health Administration on June 10, 2020. Accessed: September 13, 2023.
9. “OSHA issues updated enforcement guidance for inspections in the tree care industry.” OSHA Trade Release. July 13, 2021. Occupational Safety and Health Administration. July 13, 2021. Accessed: September 13, 2023.
10. “Tree Care Industry.” Occupational Safety and Health Administration. Accessed: September 13, 2023.
11. “OSHA issues updated enforcement guidance for inspections in the tree care industry.” OSHA Trade Release. July 13, 2021. Occupational Safety and Health Administration. July 13, 2021. Accessed: September 13, 2023.
12. “Tree Care Operations Small Business Regulatory Enforcement Fairness Act. About a Potential Tree Care Operations Standard.” Occupational Safety and Health Administration. Accessed: September 13, 2023.
13. “Tree Care Operations Small Business Regulatory Enforcement Fairness Act. About a Potential Tree Care Operations Standard.” Occupational Safety and Health Administration. Accessed: September 13, 2023.
14. “Report of the Small Business Advocacy Review Panel on OSHA’s Potential Tree Care Operations Standard.” Regulations.gov (download document). Posted by the Occupational Safety and Health Administration on June 10, 2020. Accessed: September 13, 2023.
15. “Electric Power Generation, Transmission, and Distribution eTool. Overhead Line Work. Line-Clearance Tree Trimming Operations.” Occupational Safety and Health Administration. Accessed: September 13, 2023.
16. “Electric Power Generation, Transmission, and Distribution eTool. Overhead Line Work. Line-Clearance Tree Trimming Operations.” Occupational Safety and Health Administration. Accessed: September 13, 2023.
17. “Frequently Asked Questions. Tree Trimming and Vegetation Management.” Federal Energy Regulatory Commission. Updated: August 4, 2020. Accessed: September 13, 2023.
18. “PG&E Scraps Tree-Trimming Program Once Seen as Key to Fire Prevention,” by Katherine Blunt. The Wall Street Journal. August 2, 2023.
19. “Tree Trimming & Removal Safety Fact Sheet.” TDI Safety@Work Newsletter. Texas Department of Insurance, Division of Workers’ Compensation.