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Freeman Reservoir tree felling fatality, 72-hour report & OSHA citation — June, 2009
Andrew Palmer Fatality, Dutch Creek Incident, — June, 2008
OSHA citations
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Findings:
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Tree 1 was a class C tree. The stump measured 36.7” in diameter at the point the cut was made.
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The highest saw qualification of any of the crew members present was that of a faller B.
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The undercut of Tree 1 was not cleaned sufficiently as to provide an adequate “hinge” to direct Tree 1 during the felling process.
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The undercut of Tree 1 exhibits two distinct horizontal (gunning) cuts and two sloping cuts. Multiple Dutchmen that would have altered the holding wood were also present. (See photo 2)
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Tree 1 fell away from its intended lay due to lean, possible limb weight, and an inadequately cleaned undercut.
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Tree 1 appeared to have been a sound, green tree with no readily apparent defects that would have required it to be felled as a hazard tree.
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FC1 had not completed First Aid/CPR training. First Aid/CPR training is a prerequisite for S-212 (Wildland Power Saws).
- The JHA for tree felling provided by EM after the accident was not adequate for the activity of tree felling, additionally no evidence could be found to indicate the JHA had been reviewed by EM or a line supervisor.
Recommendations:
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Fallers must only fall trees that are within their qualification level, unless being directly supervised by a faller of appropriate qualifications.
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Fallers must survey the cutting area for hazards and identify escape routes/safety zones before the felling operation can commence.
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Fallers must retain control of the cutting area. (S-212 identifies the cutting area as two times the height of the tree being cut; OSHA Logging Standards 1910.266(h)(1)(iv) states: “No employee shall approach a feller closer than two tree lengths of trees being felled until the feller has acknowledged that it is safe to do so, unless the employer demonstrates that a team of employees is necessary to manually fell a particular tree.”)
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Undercuts must be completely cleaned.
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Techniques such as boring back cuts and quarter wedging should be considered on leaning trees.
Policy:
The following references are the Forest Service and National Park Service policies that address wildland fire training and qualifications for chainsaw use. The Forest Service and National Park Service chainsaw policies differ in many aspects. However, as per the Interagency Standards for Fire & Aviation Operations (Redbook), “Employees engaged in fire management activities will continue to comply with all agency specific health and safety policy documents.”
Forest Service:
FSM 5130.3 – POLICY
1. Wildland Fire Suppression Planning and Operations.
Line officers shall conduct wildland fire suppression planning and operations in compliance with Servicewide and interagency wildland fire suppression principles and practices established in the Fireline Handbook; the Firefighters Guide; Interagency Standards for Fire and Aviation Operations; the Incident Response Pocket Guide; the Health and Safety Code Handbook; and the Annual Fire and Aviation Management Operations Plan.
FSM 5126 – PREPAREDNESS TRAINING AND QUALIFICATIONS
5126.1 - Minimum Training Requirements
3. Forest Service Employees must meet the minimum standards for training, experience, and physical qualifications listed in FSH 5109.17 prior to being certified for positions.
FSH 6709.11 - HEALTH AND SAFETY CODE HANDBOOK
22.48- Chainsaw Operations
OSHA REGULATIONS (STANDARDS - 29 CFR)
Logging operations. - 1910.266
National Park Service:
DOI 620 DEPARTMENTAL MANUAL
1.10 Training and Qualifications.
All personnel will meet minimum wildland fire qualification requirements which are equal to or exceed those recommended by the NWCG.
REFERENCE MANUAL 18: WILDLAND FIRE MANAGEMENT
3.1 Program Administration
Individuals will not be assigned to duties for which they lack training and/or certified experience. NPS wildland fire management training is based on criteria specified within the training curriculum approved by National Wildfire Coordinating Group (NWCG). This curriculum is supportive of positions described in the Wildland Fire Qualification System Guide (PMS 310-1) Agency-specific position qualification requirements and training are identified in the Interagency Standards for Fire and Fire Aviation Operations.
INTERAGENCY STANDARDS FOR FIRE & AVIATION OPERATIONS (REDBOOK)
Chapter 13 Firefighter Training & Qualifications – Chainsaw Operators and Fallers BLM/FWS/NPS – Utilize BLM Faller A/B/C Taskbook
NPS DIRECTOR’S ORDER #50B: OCCUPATIONAL SAFETY AND HEALTH PROGRAM.
NATIONAL WILDFIRE COORDINATING GROUP (NWCG)
All agencies must meet training standards of S-212-Wildfire Power saws
INTERAGENCY STANDARDS FOR FIRE & AVIATION OPERATIONS (REDBOOK)
“Employees engaged in fire management activities will continue to comply with all agency specific health and safety policy documents.”
Employees engaged in fire suppression and other fire management activities will comply with standards stated in the NWGC Incident Response Pocket Guide (PMS 461, NFES 1077) and the NWCG Fireline Handbook (PMS 410-1, NFES 0065).
FIRELINE HANDBOOK (NWCG HANDBOOK 3, PMS 410-1, NFES 0065)
States on page 59 under felling that:
“Felling of snags or large Trees (over 20 inches DBH) shall be done by a qualified Class B or C faller. Personnel felling trees less than 20 inches DBH shall be supervised by certified personnel.
Tree/snag falling shall meet specific agency faller qualification requirements.”
INCIDENT RESPONSE POCKET GUIDE (IRPG) (PMS #461, NFES #1077)
On page 80 the IRPG refers to hazard tree safety, page 81 contains information about procedural chain saw operations. Both these pages outline general guidelines to be followed while conducting operations around hazard trees and while conducting chainsaw operations. Specifically the guide states on page 81: “Procedural approach to cutting operations begins with assessing the situation, completing a hazard analysis, and establishing cutting area control.”
Wildland Fire Chainsaws (S-212)
For specific references to Agency manuals refer to the following:
USFS Students. Refer to the USFS Health and Safety Code Handbook, Chapter 20, Section 22.48B.
BIA Students. Refer to Wildland Fire and Aviation Program Management and Operations Guide, Chapter 11.
USFWS Students. Refer to service manual 241FW7.38 (7) and (7.4C).
BLM and NPS Student. Refer to Interagency Standards for Fire & Aviation Operations (Redbook), the Fireline Handbook and the Incident Response Pocket Guide.
OSHA REGULATIONS (STANDARDS - 29 CFR)
Logging standards 1910.266(h)(1)(iv)
No employee shall approach a feller closer than two tree lengths of trees being felled until the feller has acknowledged that it is safe to do so, unless the employer demonstrates that a team of employees is necessary to manually fell a particular tree.
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