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OSHA 1910.265

Sawmill safety requirements

Subpart R

50 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.265(a), what operations in a facility are covered by the Sawmills standard?

The Sawmills standard applies to most sawmill activities such as log and lumber handling, sawing, trimming, planing, waste disposal, dry kilns, finishing, shipping, storage, yard work, and power tools used for those operations. See 1910.265(a) for the full scope and exclusions.

Under 1910.265(b)(6), what does the term "bunk" mean and why does it matter for sawmill safety inspections?

A bunk means a cross support for a load, and you should inspect bunks because damaged or improperly installed bunks can let loads shift or fall during handling. The definition is in 1910.265(b)(6), which helps you identify parts of log and lumber handling systems to maintain and inspect.

Under 1910.265(b)(24) and 1910.265(c)(18)(ii), are spiked live rolls allowed and how must they be guarded?

Spiked live rolls are permitted but must be guarded to prevent worker contact with the spikes. The term "live rolls" is defined in 1910.265(b)(23) and the guarding requirement for spiked live rolls is in 1910.265(c)(18)(ii). Guards should block access to the rotating or spiked surfaces while still allowing safe material handling.

Under 1910.265(c)(4)(iv), when must elevated walks, runways, or platforms have railings and toe boards in a sawmill?

All elevated walks, runways, or platforms 4 feet or more above floor level must have a standard railing, and if they exceed 6 feet in height they must also have a standard toe board. See the requirement at 1910.265(c)(4)(iv).

  • Use standard railings to protect people from falling when the elevation is 4 feet or higher.
  • Add toe boards when the elevation is more than 6 feet to stop materials from rolling or falling off the edge.

Under 1910.265(c)(4)(v) and subpart D, when must elevated platforms used daily have stairways or fixed ladders that comply with subpart D?

Elevated platforms that are used routinely on a daily basis must be equipped with stairways or fixed ladders that comply with OSHA's stairway and ladder rules in subpart D. See 1910.265(c)(4)(v) and the general ladder/stairway standards in subpart D at 1910. For design details of mobile ladder platforms, see OSHA's interpretation on mobile ladder stand requirements at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-0.

Under 1910.265(c)(5)(ii), how many handrails are required on stairways in sawmill buildings?

Stairways must have a standard handrail on at least one side; if the stairway is over 4 feet wide there must be a handrail on each side, and if it's over 8 feet wide a third handrail is required in the center. The requirement is in 1910.265(c)(5)(ii).

This follows the subpart D construction principles referenced in 1910.265(c)(5)(i).

Under 1910.265(c)(9), what lighting levels and quality must be provided around sawmill machinery and work areas?

Lighting must provide adequate general and local illumination for the work being done and be free from glare, with correct direction, diffusion, and distribution so shadows and extreme contrasts are minimized. See 1910.265(c)(9) and the effectiveness factors in 1910.265(c)(9)(ii).

  • Ensure foot-candle levels match the tasks.
  • Reduce glare and harsh shadows that could hide hazards.

Under 1910.265(c)(3)(iii), what must an employer do if a floor or passageway develops a hazardous condition that cannot be immediately repaired?

If a floor, ramp, or walkway develops a hazardous condition that cannot be promptly fixed, the employer must guard the area until adequate repairs are made. This is required by 1910.265(c)(3)(iii).

  • Guarding can include barricades, warning signs, or other physical barriers to prevent access.
  • Keep the guarded area clearly marked and restrict access until repaired.

Under 1910.265(c)(3)(ii), how should areas beneath floor openings be controlled in a sawmill?

Areas beneath floor openings should be fenced off when practical; if fencing is not practical they must be plainly marked and have telltales hanging over the openings as a warning. See 1910.265(c)(3)(ii).

  • Use fencing where possible to physically prevent entry.
  • If you can't fence, install clear markings and telltales to warn workers of the overhead hazard.

Under 1910.265(c)(4)(iii), what protection is required on docks and runways used for lift trucks and other vehicles?

Docks and runways used by lift trucks and other vehicles must have a substantial guard or shear timber except where loading and unloading are actively being performed. See 1910.265(c)(4)(iii).

  • Install substantial guards or timbers to stop vehicles from rolling off docks when not actively loading/unloading.
  • Ensure guards are maintained and used consistently to prevent falls and equipment runoffs.

Under 1910.265(c)(13), what must employers do before performing maintenance on equipment supported by hydraulic pressure?

Employers must provide means (like blocks, chains, or other secure devices) to hold equipment that is normally supported by hydraulic pressure so it cannot drop during maintenance. This is required by 1910.265(c)(13).

  • Use mechanical supports or locks to prevent unintended movement.
  • Make sure the supporting devices are rated for the load and inspected before use.

Under 1910.265(c)(6)(i)–(iv), what are the sawmill requirements for doors used as emergency exits and for doors opening onto vehicle areas?

Exit doors must swing in the direction of exit travel and be located and identified to provide ready exit from work areas; swinging doors must have windows of shatterproof or protected glass, and where a doorway opens onto a railroad, tramway, or dock used by vehicles, a barrier or other warning device must be provided. See 1910.265(c)(6) and the swinging door window rule at 1910.265(c)(6).

  • Make exit doors swing the correct way and be clearly identified.
  • Fit windows in swinging doors with shatterproof glass or protect them.
  • Put barriers or warnings where doors open into vehicle routes to prevent stepping into traffic.

Under 1910.265(c)(11), what hazard marking system must be used in sawmills?

Physical hazard marking in sawmills must follow the color and marking rules specified in 1910.144, as required by 1910.265(c)(11).

  • Use the color conventions and labeling guidance in 1910.144 for marking physical hazards (e.g., warning signs, barricade colors).
  • Keep markings visible and maintained so workers can quickly recognize hazards.

Under 1910.265(c)(18)(i), what standard governs the construction, operation, and maintenance of conveyors in sawmills?

Construction, operation, and maintenance of conveyors must follow American National Standard B20.1—1957, as referenced in 1910.265(c)(18)(i).

  • Use B20.1 guidance for safe conveyor guards, emergency stops, and inspection procedures.
  • Follow that consensus standard along with the guarding rule for spiked live rolls in 1910.265(c)(18)(ii).

Under 1910.265(c)(8), how must open vats and tanks be protected in sawmill operations?

All open vats and tanks into which workers could fall must be guarded to prevent falls into the vat or tank, per 1910.265(c)(8).

  • Guarding can include covers, railings, or barriers around the opening.
  • Ensure guards are strong, securely attached, and cannot be easily removed by untrained personnel.

Under 1910.265(b)(9) and 1910.265(b)(22), what is the difference between a "carrier" and a "lift truck" in a sawmill context?

A "carrier" is an industrial truck designed to straddle the load with mechanisms to pick up and support it, while a "lift truck" is an industrial truck equipped with a power-operated lifting device (forks) for piling or unpiling lumber; both are defined in 1910.265(b)(9) and 1910.265(b)(22).

  • Treat each type differently when setting operating procedures, training, and inspection programs because design and hazards differ.
  • Ensure operators are trained for the specific vehicle they will use.

Under 1910.265(b)(23) and 1910.265(c)(18)(ii), what hazards do live rolls create and how should they be addressed in your sawmill safety plan?

Live rolls are rotating cylinders used to convey slabs and lumber and they present entanglement, pinch-point, and struck-by hazards; they must be guarded and included in training, inspection, and lockout/tagout procedures. The definition is in 1910.265(b)(23) and the guarding requirement is in 1910.265(c)(18)(ii).

  • Install fixed guards to prevent access to moving rolls.
  • Provide training on hazards and safe work procedures and use lockout/tagout during maintenance (see OSHA LOTO guidance at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21).

How does OSHA interpret the need for head protection when crane operators work around lifting operations in sawmills? (cite interpretation)

If a crane operator or other employee is exposed to potential overhead falling objects during lifting operations, the employer must provide and require wearing protective helmets that meet OSHA-accepted consensus standards. OSHA explains this in its interpretation on head protection for crane operators at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2 and the general head protection requirement appears at 1910.

  • Use ANSI Z89.1-compliant helmets as noted in the interpretation.
  • Assess work areas for overhead hazards and enforce helmet use when exposure exists.

When maintenance requires energizing a sawmill machine for testing or positioning, is there a permitted alternative to continuous lockout/tagout? (cite interpretation)

Yes — OSHA allows temporary removal of lockout/tagout devices and re-energizing when necessary for testing or positioning, but only after following a strict sequence to protect employees (clear tools, remove employees from danger area, remove devices as specified, re-energize for testing with protections in place, then re-isolate if further servicing is needed). See OSHA's LOTO interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21 and the Lockout/Tagout standard 1910.147 for the full procedures.

  • Implement written procedures and temporary protective measures when re-energizing for testing.

Under 1910.265(c)(19)(ii), what vertical clearance is required for stationary tramways and trestles over railroad rails and roads?

Stationary tramways and trestles must provide 22 feet of vertical clearance over railroad rails and at least 12 feet above roadways, or 6 feet above the driver's foot rest where constructed over carrier docks or roads, with alternatives (telltales, signals, signs) allowed where impractical to achieve clearance. See 1910.265(c)(19)(ii).

  • If you cannot provide the required clearance in an existing operation, install telltales, electric signals, signs, or other precautionary measures as stated in the same provision.

Under 1910.265(c), what must I provide when vehicles operate on tramways or trestles that are also used for foot passage?

You must control traffic or provide a walkway with standard handrails at the outer edge and shear timber on the inner edge, with the walkway wide enough to give adequate clearance to vehicles and fenced to 42 inches where it crosses thoroughfares. See 1910.265(c).

  • The walkway must allow safe pedestrian passage and must be solidly fenced to 42 inches over other thoroughfares where walkways cross them.

Under 1910.265(c)(20)(i), what design and construction standards apply to blower, collecting, and exhaust systems in sawmills?

Blower, collecting, and exhaust systems should be designed, constructed, and maintained in accordance with the incorporated ANSI standards Z33.1—1961 and Z12.2—1962 (R1969). See 1910.265(c)(20)(i) and the incorporation authority in 1910.6.

  • Following these consensus standards helps ensure proper dust, stock, and vapor removal and reduces dust explosion risks.

Under 1910.265(c)(20)(ii), when is a mill required to have a dust collecting system?

Any mill with one or more machines that create dust, shavings, chips, or slivers for one-quarter or more of the working day must be equipped with a collecting system of sufficient strength and capacity. See 1910.265(c)(20)(ii).

  • The system may be continuous or automatic, and must remove refuse from points of operation and immediate vicinities of machines.

Under 1910.265(c)(20)(iii), what exhaust or conveyor requirements apply to individual woodworking machines?

Each woodworking machine that generates dust, shavings, chips, or slivers must be equipped with an exhaust or conveyor system positioned and adjusted to remove the maximum amount of refuse from the point of operation and immediate vicinity. See 1910.265(c)(20)(iii).

  • Ensure hoods, intakes, and ducting are located and sized to capture material at the source for best effectiveness.

Under 1910.265(c)(20)(v), can exhaust pipes discharge into an unconfined outside pile?

Exhaust pipes must not discharge into an unconfined outside pile if doing so would create uncontrolled fire or explosion hazards. See 1910.265(c)(20)(v).

  • If discharge to an outside pile is unavoidable, you must control the risk (for example, by routing to a confined settling chamber or using spark arrestors) to prevent fire or explosion hazards.

Under 1910.265(c)(20)(vi), what are the requirements for settling or dust chambers that collect exhausted refuse?

Dust or settling chambers used to receive exhausted refuse must be constructed and operated to prevent dust or refuse from entering work areas and to minimize the danger of fire or dust explosion. See 1910.265(c)(20)(vi).

  • Design chambers to contain dust, provide appropriate housekeeping, and include explosion mitigation measures (e.g., vents, suppression) where necessary.

Under 1910.265(c)(20)(vi), when is hand removal of refuse allowed instead of an exhaust system?

Daily hand removal of refuse is required for operations not mandated to have an exhaust system or when material is too heavy, bulky, or otherwise unsuitable for the exhaust system. See 1910.265(c)(20)(vi).

  • If hand removal is used, ensure safe procedures, PPE, and housekeeping schedules are in place to control dust and fire hazards.

Under 1910.265(c)(21)(i), how must whole-log chippers be guarded and how should operators position themselves?

The feed system to whole-log chippers must be arranged so the operator does not stand in direct line with the chipper spout; the spout must be enclosed to at least 36 inches from the floor or operator platform, and workers near the spout must use a safety belt and a short lifeline unless the spout is guarded. See 1910.265(c)(21)(i).

  • The lifeline must be short enough to prevent falling into the chipper; if the spout is fully guarded, belts and lifelines may not be required.

Under 1910.265(c)(21)(ii), what safeguards apply to hog mills, feed chutes, and employees who feed them?

Hog mills must be arranged so no position on the rim of the chute is closer than 40 inches to the cutter knives; feed chutes must have suitable baffles to minimize thrown material; and employees feeding hog mills must be provided safety belts and lifelines unless the equipment is guarded. See 1910.265(c)(21)(ii)(a), 1910.265(c)(21)(ii)(b), and 1910.265(c)(21)(ii)(c).

  • Where guarding is provided, personal fall/restraint gear may not be required; where it is not, provide belts and lifelines sized to prevent entry into danger zones.

Under 1910.265(c)(23)(i), what guarding is required for open bins, bunkers, and hoppers whose upper edges are less than 3 feet above working level?

Open bins, bunkers, and hoppers with upper edges less than 3 feet above working level must have standard handrails and toe boards, or be covered by a substantial grill or grating with openings small enough to prevent a person from falling through. See 1910.265(c)(23)(i).

  • Use covers or grills where appropriate to prevent falls into storage openings.

Under 1910.265(c)(23)(ii), what protections are required when wheeled equipment loads materials into bins, bunkers, or hoppers?

When automotive or other wheeled equipment moves materials into bins, bunkers, or hoppers, adequate guard rails must be installed along each side of the runway and a substantial bumper stop provided where necessary. See 1910.265(c)(23)(ii).

  • Ensure runways are constructed to prevent vehicles from running off into bins and that bumper stops are installed to protect employees and equipment.

Under 1910.265(c)(23)(iii)-(iv), what must fuel houses and bins provide for employees entering them?

Fuel houses and bins must provide adequate exits, lighting, and all necessary safety devices, and must have a standard railed platform or walkway near the top where needed. See 1910.265(c)(23)(iii) and 1910.265(c)(23)(iv).

  • Provide and require use of safety devices (e.g., harness points, ladders, lighting) whenever employees enter these structures.

Under 1910.265(c)(24)(i), how should ropes, cables, slings, and chains be used in sawmill operations?

Ropes, cables, slings, and chains must be used in accordance with safe use practices recommended by the manufacturer or within the safe limits recommended by the equipment manufacturer when used with that equipment. See 1910.265(c)(24)(i).

  • Follow manufacturer instructions for load limits, inspection, storage, and compatible fittings; train qualified personnel for installation and maintenance.

Under 1910.265(c)(24)(v)(a), how often must wire rope or cable be inspected and when must it be removed from service?

Wire rope or cable must be inspected when installed and at least once each week when in use, and it must be removed from hoisting or load-carrying service when specific wire break criteria, kinks, or marked corrosion are found. See 1910.265(c)(24)(v)(a).

  • Removal thresholds include: three broken wires in one lay for 6x6 rope; six broken wires in one lay for 6x19 rope; nine for 6x37; eight for 8x19; marked corrosion; or 4% broken wires in one lay for other rope types as specified.

Under 1910.265(c)(24)(v)(b), what must be done with wire rope removed from service due to defects?

Wire rope removed from service because of defects must be plainly marked or identified as unfit for further use on cranes, hoists, and other load-carrying devices. See 1910.265(c)(24)(v)(b).

  • Tag or physically separate defective rope so it cannot be mistakenly returned to service.

Under 1910.265(c)(24)(viii)(g), how many wraps of hoisting cable must remain on a drum during crane or hoist operation?

There must be at least two full wraps of hoisting cable on the drum of cranes and hoists at all times during operation. See 1910.265(c)(24)(viii)(g).

  • Maintain drum capacity and reeving to ensure safe operation and to prevent cable loss over the drum flanges.

Under 1910.265(c)(24)(viii)(f), what protections are required for running lines of hoisting equipment located within 6 feet 6 inches of the ground or working level?

Running lines of hoisting equipment within 6 feet 6 inches of the ground or working level must be boxed off or otherwise guarded, or the operating area must be restricted to prevent worker contact. See 1910.265(c)(24)(viii)(f).

  • Use guards, barriers, or controlled access to keep workers out of the hazard zone while lines are in motion.

Under 1910.265(c)(24)(viii)(h)-(i), what requirements exist for drums and sheaves to prevent cable failures?

Drums must have a flange at each end to prevent the cable from slipping off, and sheaves (and sheave guards) must be provided consistent with safe reeving practices to keep cables on track. See 1910.265(c)(24)(viii)(h) and 1910.265(c)(24)(viii)(i).

  • Inspect flanges and sheaves regularly and remove damaged components (cracked hubs, flanges) from service to avoid cable jumping or wear.

Under 1910.265(c)(24)(ix), what inspection and discard criteria apply to chains used in load-carrying service?

Chains used for load-carrying service must be inspected before first use and weekly thereafter; discard any 3-foot length of chain that has stretched by one-third the length of a link. See 1910.265(c)(24)(ix)(a) and 1910.265(c)(24)(ix)(c).

  • Do not shorten or join chains by inserting bolts or nails between links; remove broken or damaged chains from service.

Under 1910.265(c)(24)(x), when is fiber rope prohibited from load-carrying service?

Fiber rope must not be used in load-carrying service when it is frozen, has been subjected to acid, or has been exposed to excessive heat. See 1910.265(c)(24)(x)(a) and 1910.265(c)(24)(x)(b).

  • Protect fiber rope from abrasion and chemical exposure where it is fastened or passes over edges as required by 1910.265(c)(24)(x)(c).

Under 1910.265(c)(26), what controls and safeguards are required for mechanical stackers and unstackers?

Mechanical stackers and unstackers must have lumber lifting devices designed to minimize falling lumber, means to positively block the hoisting platform when employees go beneath it, properly identified and accessible manual controls, lockable main control switches, and guarded hoistway openings and lower landing areas. See 1910.265(c)(26)(ii), 1910.265(c)(26)(iii), 1910.265(c)(26)(iv), 1910.265(c)(26)(v), 1910.265(c)(26)(vi), and 1910.265(c)(26)(vii).

  • Where the employer determines overhead hazards exist (for example during lifting), require head protection consistent with 29 CFR 1910.135 as explained in OSHA's Head Protection LoI.

Under 1910.265(c)(26)(ix)-(xi), what inspection, cleaning, and access controls are required for stackers and unstackers?

Every stacker and unstacker must be inspected frequently with defective parts immediately repaired or replaced; safe means of entrance and exit must be provided for cleaning pits; and signs, warning devices, or barriers must prevent entry into hazardous areas where trucks return by power or gravity. See 1910.265(c)(26)(ix), 1910.265(c)(26)(x), and 1910.265(c)(26)(xi).

  • Use electrically interlocked gates where appropriate so opening disconnects power and sets hoist brakes, as recommended in 1910.265(c)(26)(viii).

Under 1910.265(c)(27)(iii), what must you do if lumber piles become unstable?

If a lumber pile becomes unstable, you must immediately make it safe or fence/barricade the area into which it might fall and prohibit employee entry. See 1910.265(c)(27)(iii).

  • Post warnings and restrict access until the pile is stabilized to prevent crush or entrapment hazards.

Under 1910.265(c)(27)(i), how should pile foundations and unit package piles be arranged?

Pile foundations must be designed and arranged to support maximum loads without sinking, sagging, or permitting piles to topple, and unit package piles must have substantial bolsters or unit separators placed between each package directly over the stickers. See 1910.265(c)(27)(i).

  • Ensure stickers and bolsters are aligned and adequate to prevent pile instability under expected loads.

Under 1910.265(c)(27)(ii), can long units of lumber be stacked on shorter packages?

Long units of lumber should not be stacked upon shorter packages except where a stable pile can be made using package separators. See 1910.265(c)(27)(ii).

  • If you must mix lengths, use suitable separators to create a safe, stable stacking profile and prevent tipping.

Under 1910.265(c)(24)(viii)(c)-(d), what are proper practices for wire rope clips and wedge sockets?

When wire rope clips are used, the U-bolts must be on the dead or short end of the rope and the nuts retightened after initial load-carrying and at frequent intervals; when wedge-socket fastenings are used, the dead end must be clipped with a U-bolt or otherwise secured against loosening. See 1910.265(c)(24)(viii)(c) and 1910.265(c)(24)(viii)(d).

  • Follow manufacturer torque and inspection schedules; recheck U-bolt nuts after initial load and periodically thereafter to prevent slippage.

Under 1910.265(c)(24)(viii)(e), what must be done with fittings (hooks, shackles, rings, pad eyes) that show damage?

Fittings that show excessive wear, bending, twisting, or other damage must be removed from service. See 1910.265(c)(24)(viii)(e).

  • Tag and segregate damaged fittings to prevent accidental reuse and replace them per manufacturer specifications.

Under 1910.265(c)(24)(v)(c), how must the ratio between rope diameter and drum/sheave diameter be handled?

The ratio between rope diameter and the drum, block, sheave, or pulley tread diameter must allow the rope to bend without excessive wear or deformation, and replacing drums/sheaves must not reduce their safe value unless compensating changes are made for the rope and safe load limits. See 1910.265(c)(24)(v)(c).

  • Consult rope and equipment manufacturers when changing drums or sheaves to ensure compatibility and maintain safe ratings.

Under 1910.265(c)(24)(viii)(b), how should eye splices be made in wire rope and when are thimbles required?

All eye splices must be made in an approved manner and wire rope thimbles of proper size must be fitted in the eye, except that thimbles are optional in slings. See 1910.265(c)(24)(viii)(b).

  • Use approved splice techniques and sized thimbles to protect the rope from chafing at the eye, unless the use is in a sling where the thimble is optional.

Under 1910.265(c)(30) Vehicles — what equipment and safety features are required for vehicles used in sawmill, planing mill, storage, shipping, and yard operations (warning signals, lights, overhead guards, load limits, brakes, and carrier features)?

Yes — vehicles in sawmill and related yard operations must be equipped and operated with specific safety features: audible warnings and spark arrestors where practicable; lights when operated in the dark or poorly lighted areas; approved overhead guards where overhead hazards exist; operation within rated load limits; brakes able to hold the vehicle and its load on grades; and carrier design features that preserve the operator’s vision and provide safe access.

  • Audible warning signals and, when practicable, spark arrestors are required on all vehicles (1910.265(c)(30)(ii)).
  • Vehicles operated in the dark or in poorly lighted areas must have head and tail lights (1910.265(c)(30)(iii)).
  • Where overhead hazards exist, vehicles must be fitted with an approved overhead guard; see the incorporated reference to the powered industrial truck safety code (1910.265(c)(30)(iv)).
  • Do not operate a vehicle with loads exceeding its safe load capacity; observe the vehicle’s rated capacity and secure loads properly (1910.265(c)(30)(viii)).
  • Brakes must be capable of holding and controlling the vehicle and its capacity load on any incline or grade where they operate (1910.265(c)(30)(ix)).
  • Carriers must not unnecessarily restrict the operator’s field of vision and must provide safe access (for example, an access ladder) (1910.265(c)(30)(xi)(a), 1910.265(c)(30)(xi)(b)).
  • For lumber-hauling trucks there are added requirements such as a substantial bulkhead behind the operator on trucks where load movement on stopping would endanger the operator, adequate means to secure loads, and locking rollers when rollers support loads during transit (1910.265(c)(30)(xii)(a), 1910.265(c)(30)(xii)(b), 1910.265(c)(30)(xii)(c)).

Practical employer actions:

  • Inspect vehicles daily for lights, brakes, warning devices, and spark arrestors; tag out any vehicle with defective brakes or lights until repaired.
  • Post and enforce published load capacities; train operators on load-securement best practices for lumber.
  • Fit overhead guards where overhead hazards exist and evaluate whether operators also need head protection per OSHA guidance on head protection in lifting operations (see OSHA letter on head protection for crane operators).

Cited requirements: see 1910.265(c)(30) and the specific subsections above for each feature.