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Rates of injury or illness resulting in days away from work are higher than the national average among tree trimming & removal and landscaping service workers according to the North American Industry Classification System (NAICS). In Region 1 alone, which encompasses Connecticut, Massachusetts, Maine, New Hampshire, Rhode Island, and Vermont, 25 fatalities “and numerous other serious permanent disabling injuries related to tree and landscape work activities” were reported between 2016 and 2020 (OSHA, 2021). In these industries, fatalities were categorized as struck-by, fall, electrocution, caught-in-between, and other incidents. Another industry that is subject to similar hazards is Site Preparation Contractors. Under the NAICS system, Site Preparation Contractors include workers involved with mine site preparation, construction activities, and construction contracting.

On August 4, 2021, the Occupational Safety and Health Administration (OSHA) implemented a Regional Emphasis Program (REP) for Region 1 regarding scheduling and conducting inspections of specific tree trimming, land clearing operations, and site preparation contractors (OSHA, 2021). The purpose of this REP directive is to provide an inspection scheduling system for OSHA to monitor high-hazard activities for workplaces that are categorized under the NAICS codes 561730 (Tree Trimming & Removal and Landscaping Service Industries) and 238910 (Site Preparation Contractors). This program provides a framework to schedule programmed safety and health inspections of employers engaged in the tree and landscape industry (OSHA, 2021).

Per the REP, during programmed inspections, OSHA Compliance Safety and Health Officers (CSHOs) shall include the following activities in their inspections (OSHA, 2021):

1. Determine the scope of work and applicable OSHA standards,
2. Assess employer’s compliance with OSHA PPE requirements and cite employers if employees are not provided appropriate PPE,
3. Determine if noise levels exceed a 90dBA 8hr-TWA and if a hearing conservation program is necessary,
4. Determine if cranes, slings, and other lifting equipment is operated in accordance with applicable regulations and standards,
5. Evaluate the proximity to overhead energized wires for material handling and hoisting equipment, and the proximity of workers to tree climbing, tools, and equipment, and
6. Evaluate the application of traffic safety where work is performed near moving roadway traffic.

The REP dictates that OSHA will conduct outreach to stakeholders to apprise them of the six points of interest detailed above (OSHA, 2021). Notably, if complaints that allege fall hazards within the tree industry are received at the area office, the REP grants the area director the option to schedule an inspection to investigate the complaint.

In addition to having a safety strategy in place for operations specific to their work practices, employers impacted by this REP directive should be aware of OSHA’s REP requirements. Further, all employers in the tree and landscaping industry should be aware of the hazards associated with their work and proactively develop safety strategies to mitigate these hazards.

Cardno ChemRisk is experienced at developing and assisting with workplace health and safety strategies and support. To learn more about the ways Cardno ChemRisk can support occupational safety-related matters, please contact Rachel Zisook, or visit our company website, and Practice Area webpage on Occupational and Environmental Health and Safety.