Here are some comments from my father, Steve.
I would like to write to clarify the reasoning for my opposition to two areas of the proposed ANSI Z133.1 revision. First, let me say that I mean no disparagement or to make light of the different areas of professional arboriculture. I began my career in 1967 as a utility arborist as well as a commercial arborist. I also spent some years as a municipal arborist. I am familiar with those areas of arboriculture. I also have been an instructor for Rutgers University in both the Basic Tree Climbing and Advanced Tree Climbing courses, 1982-1988, that have now been continued with sponsorship by the Committee for the Advancement of Arboriculture since 1990. These courses are held for two weeks in the spring and two weeks in the fall. I apologize for the lengthy introduction, but just wanted to give some background.
Now, let me present my concerns. The first one in the proposed revisions is section 8.1.17. Under work procedures it states: “Arborists shall be tied-in while ascending the tree. The arborist shall remain tied until the work is completed and he or she has returned to the ground.” The exception in the 2000 edition, 9.1.2 (2) “While ascending a tree where the density of branches growing from the stem prevents the arborist from crotching the arborist climbing line or work positioning lanyard through the branches, then, and only then is the three point climbing technique acceptable”, has been removed.
I believe the exception should remain because it is reasonable and because the previous editions of the standard in 1982, 1988, 1994 and 2000 all have exceptions for the professional, trained arborist to perform the required tasks. Let me give one example, although you could list many. I will use American Holly at the Jersey Shore. Climbing that densely branched tree is already an arduous task, and by necessitating the use of a lanyard in every move you have made it more so, and in my opinion, more dangerous. There was a comment at the April meeting saying that we needed a lanyard in the situation in case of bees. Three years ago at the New Jersey shore I entered an American Holly to crown shape and crown raise it. I decided to lanyard in and remove the lower branches first. I disturbed a hornets nest which none of the crew were able to see. I can’t tell you how many times I was stung before I could detach my lanyard and make the 4’ jump to the ground. Like I previously stated, you could choose many other trees that are safe to climb using the three point climbing technique.
Any arborist who is not trained or skilled enough to perform this technique should not! Any employer may have a company policy that does not allow the practice, but to “outlaw” a technique that a trained and skilled arborist can safely perform is wrong.
My next concern is a little more troubling. At our October meeting we discussed drop-starting a chain saw, section 6.3.4 of the proposed revision, and removing the exception in section 6.3.6 of the proposed revision. I had made a request for the sub group to review the possibility of harmonization with the HSE and ISO standards and possibly coming up with some reasonable compatibility. I am disappointed that my request was not acted upon and also because I did not get a courtesy response. You should be aware that chain saw manufacturers are in disagreement with harmonization between the standards. Some favor and some do not. The Z133.1 Committee should review the ISO and HSE thoroughly before the final revision is sent to the printer. If harmonization is not to be considered after that review, I would request that the exception remain as in the 2000 edition.
In review of the 1982, 1988, 1994 and 2000 editions there have always been reasonable exceptions for the professional, skilled and trained arborist.
I have some questions:
1. Section 6.3.4 of the proposed revision states: “When starting a chain saw, the saw shall be firmly in place on the ground or otherwise held in a manner that does not allow movement of the saw when pulling the starter handle. The chain saw shall be started with the chain brake engaged, on saws so equipped. Drop-starting a chain saw is prohibited.” How will the professional arborist start a large chain saw while standing in his spurs or while working in an aerial lift without some movement of the saw? And if the chain brake is on, what difference does it make?
2. Section 6.3.6 of the proposed revision states: “When operating a chain saw,
the arborist and the other worker shall hold the saw firmly with both hands,
keeping the thumb and fingers wrapped around the front handle.”
The 2000 edition, 7.2.7 exception stated: “This requirement does not apply when an employer can demonstrate that a greater hazard is posed by keeping both hands on the chain saw in a particular situation”. This exception has been removed. I think this is a mistake. It is neither realistic nor reasonable. By not allowing a professional, trained, competent arborist to use one hand on a chain saw, a practice that has existed since the advent of climbing saws, we will be placing an economic burden on commercial tree care companies. By requiring their climbers to rope down every small limb that cannot be allowed to drop freely, a limb that could be safely held and tossed to the drop zone, will increase costs. Certainly one-handed chain saw use should not be done haphazardly and neither should an untrained, incompetent person perform such a task.
If you read the next section, 6.3.7 of the proposed revision, it states: “Arborists shall use a second point of attachment, (work positioning lanyard or double crotched climbing line) when operating a chain saw in a tree, unless the employer demonstrates that a greater hazard is posed by using a second point of attachment while operating a chain saw in that particular situation.”
This is reasonable, but isn’t it likely that this same situation might require the existing exception in 7.2.7 of the 2000 edition? I believe it would, and therefore request the exception in 7.2.7 remain.
Also, 7.2.11 of the 2000 Z133 which states: “Because of the many specialized chain saw operations utilized during arboricultural operations, it must be emphasized that operational exceptions to provisions of ANSI B175 are acceptable and may require a flexible and/or applicability judgment decision for a prescribed operation” should remain in the standard.
I think some consideration needs to be made for commercial arboriculture. Generally, the commercial arborist faces tasks and offers more services for trees in a wider range of conditions and locations than other areas of arboriculture.
I think it is a mistake to restrict time honored practices that can be safely performed by a well trained professional. Accidents will always happen to those individuals that are new to the industry, poorly trained, or non-trained, those that may have 5, 10 or 15 years experience with poor on the job training or to those that take short cuts or use poor operational procedures. I would ask that those well trained professionals be given some consideration in the standard. I am concerned that we are boxing in our field people and subjecting them to fines.
Arboriculture can be dangerous work, especially for the untrained, unskilled person. Improper operating techniques and short cuts lead to injuries or fatalities. A properly trained, competent individual, who adheres to good work practices, is more likely to avoid injury. If I might offer an analogy: using seatbelts and airbags are good safety measures, but if you drive unsafely or haphazardly, running into a semi, the seat belt and airbag won’t be much help.
Thank you for your consideration in this matter.
Steve Chisholm
President, New Jersey Board of Certified Tree Experts
Vice Chairman, NJ Community Forestry Council
Treasurer, Committee for the Advancement of Arboriculture
Member, International Society of Arboriculture
Member, International Society of Commercial Arborists
Member, Tree Care Industry Association
Member, ANSI Z 133.1 Committee, Chair of the Crane Sub group
Chairman, Jackson Township Shade Tree Commission
Member, Jackson Township Environmental Commission
Member, NJ Shade Tree Federation
Member, NJ Society of Certified Tree Experts
Member, NJ Arborists, Chapter International Society of Arboriculture
