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Training workers to recognize and avoid hazards, as well as providing and requiring the use of personal protective equipment (PPE) to further protect against recognized hazards, are foundational elements of any safety program. This article covers the requirements and recommendations any tree care employer should follow.

The sources for this information are federal OSHA regulations for “general industry” and soon-to-be-published, revised standards from ANSI Z133 – 2026, the American National Standard for Arboricultural Operations – Safety Requirements.

We can summarize compliance with OSHA’s performance-based standards with these overarching outcomes: If you’re going to expose an employee to any significant hazard, you have to make sure the employee knows how to recognize and avoid the hazard, and you have to be sure the employee uses PPE, including personal fall protection equipment (PFPE), if doing so will help protect against the hazard.

ANSI Z133 (the Z), the industry’s consensus safety standard, aligns with OSHA on these overarching requirements.

OSHA compliance can be summarized in four words: policy, training, enforcement, inspection. When there’s an obvious hazard to employees, you need a policy that directs them on how to avoid it, you need to convey what that policy is through training, you need to enforce the policy to ensure employees follow the policy, and, of course, somebody in authority needs to inspect the crews in action to know whether they’re following policy.

OSHA & the Z on training

Most OSHA standard references to training tend to be vague, and the need to train is generalized or even implied. An example is the general industry standard addressing crew first-aid training:

In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first-aid supplies shall be readily available.

What does OSHA mean by “adequate” in the above requirement? You will find out if what you do is judged to be inadequate! Bear in mind that OSHA can levy fines if you misinterpret or ignore their standards.

By contrast, the Z tends to be more explicit and prescriptive about training, but at the same time, compliance with the standard is “voluntary” – it is stated right in the purpose statement that the Z is intended as a guide for federal, state and local authorities that may have the jurisdiction to enforce it.

The following is “training” language, pulled together from various parts of the Z, which was present in previous revisions:

All personnel engaged in arboricultural operations shall be instructed in the correct procedures for emergency response, including making 911 calls and calls to other applicable emergency phone numbers.

The employer shall provide and maintain a first-aid kit that meets the requirements of ANSI Z308.1, with contents appropriate for the type of job and number of workers.

Instruction shall be provided in the identification of, preventive measures against, and first-aid treatment for recognized poisonous plants, stinging and biting insects, and other pests found in the area in which work is to be performed.

Employees who may be faced with a rescue decision shall receive training in emergency response and rescue procedures appropriate and applicable to the work to be performed, as well as training to recognize the hazards inherent in rescue efforts.
For field crews involving two or more workers at a work location, at least two workers trained in first aid/CPR shall be available. Exception: Only one trained person need be available if all new employees are trained in first aid/CPR within three months of their hiring dates.

Here is the Z language on training and education, introduced in the 2026 revision:

The employer shall require the employee to demonstrate competency before performing any safety-sensitive task without direct supervision.

Competency: Having the knowledge and skill with the demonstrated ability to perform specific tasks safely, as determined by the employer.

Safety-sensitive task: A task that if performed incorrectly could cause injury, damage property or disrupt activities.

Direct supervision: Oversight by a qualified arborist or a qualified arborist supervisor who is physically present on the jobsite.

The employer shall ensure that each employee has demonstrated competency in the work practices involved. Employees who cannot demonstrate competency shall be trained in, and made familiar with, the safety-related work practices, safety procedures, and other safety requirements pertaining to their job assignments.

Note: On-the-job training with direct supervision may be used to develop competency.

Takeaway

On-the-job training (OJT) is a legitimate way to receive training, but if you determine that Employee A is not fully competent and you want them to learn a safety-sensitive task by performing the task, they need a competent person looking over their shoulder.

Learning objectives should be established at the beginning of training.

Employee training and retraining should be documented.

The employer shall determine, through regular supervision and on-the-job assessments conducted on at least an annual basis, that each employee is complying with the safety-related work practices required by their job assignments. On-the-job assessments should be documented.

The employer shall provide additional training or retraining for an employee under any one or more of the following conditions:

• It is determined that the employee has performed a safety-sensitive task incorrectly.
• New technology, new types of equipment and/or changes in procedures necessitate the use of safety-related work practices that are different from those which the employee would normally use.
• It is otherwise determined as needed by the employer.

Takeaway

The Z places new emphasis on documentation. Not only will documentation help employers hold employees accountable, but the paper trail can also be very helpful when appealing an OSHA citation.

OSHA & the Z on PPE

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You will find consistency between OSHA regulations and the Z language when it comes to the employer’s overall obligations for PPE/PFPE. In fact, the Z Committee chose to parrot certain OSHA language to help bring broader recognition of the requirements to employers.

OSHA and Z share this statement:

The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE).

When such hazards are present, or likely to be present, OSHA language stipulates that the employer shall:

Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;

Communicate selection decisions to each affected employee; and,

Select PPE that properly fits each affected employee.

Takeaway 1

For OSHA field compliance personnel, PPE violations are a slam dunk, particularly for PPE as obviously needed and as visible as a helmet. A missing helmet can be spotted from a block away and can pull the OSHA compliance person in for a closer inspection of the operation.

Takeaway 2

Any time OSHA finds employees not using PPE when they should be, they’re going to ask, “Why aren’t they?” and assume the employer is to blame because they didn’t assess hazards at the worksite and tell the employees to wear whatever PPE would have offered protection.

The OSHA “certification of hazard assessment for PPE” requirement, stated in the next paragraph and replicated in the Z, is essentially a paperwork requirement, but unless you document the process, it’s next to impossible to prove to OSHA that you followed the process in a citation situation.

Currently, this is the second-most frequently cited violation for tree care employers.

OSHA: The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.

OSHA on PPE/PFPE

Beyond employer obligation language, and with few exceptions, OSHA takes a broad-brush approach to PPE use:

Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.

On walking-working surfaces: …the employer must ensure that each employee on a walking-working surface with an unprotected side or edge that is 4 feet (1.2 m) or more above a lower level is protected from falling. This could be with guardrails, safety nets, or PFPE, depending on the specific circumstances.

In aerial lifts, OSHA is more specific: A personal fall arrest or travel restraint system … shall be worn and attached to the boom or basket when working from an aerial lift.

The Z on PPE/PFPE

The Z applies narrowly to the “business, trade or performance of arboriculture for pay,” so unlike OSHA general-industry standards that apply to a broad spectrum of occupations, the Z can be explicit when it comes to PPE/PFPE use:

Workers engaged in arboricultural operations shall wear head protection (helmet) that conforms to ANSI Z89.1. Class E helmets shall be worn when working in proximity to electrical conductors, in accordance with ANSI Z89.1.

The employer shall provide employees with protection against the effects of noise exposure when sound levels exceed an 8-hour, time-weighted average (TWA) of 85 decibels (dB). Hearing protection provided by the employer shall be worn when it is not practical to decrease or isolate noise levels that exceed acceptable standards.

Arborists engaged in arboricultural operations shall wear eye protection that conforms to ANSI Z87.1.

Cut-resistant leg protection that meets or exceeds ASTM F1414 and ASTM F1897 shall be worn while operating a chain saw during ground operations. Cut-resistant leg protection shall be maintained in accordance with manufacturers’ recommendations.

Face protection shall conform to applicable federal regulations and ANSI Z87.1. Respiratory protection shall conform to applicable federal regulations and ANSI Z88.2.

Aerial devices shall be provided with fall-protection anchor(s) …on which to secure an approved system of personal fall protection which shall be worn by the operator(s) whenever aloft.

The arborist shall be secured at all times while ascending the tree.

While climbing, the arborist shall have on their person at all times a climbing line and at least one other means of being secured (e.g., an arborist climbing line and a work-positioning lanyard). Two means of being secured shall be used when the arborist determines that it is advantageous or [while operating a chain saw aloft].

Conclusion

For our industry, a discussion about OSHA compliance wouldn’t be complete without mentioning OSHA’s General Duty Clause. When OSHA inspectors find what they deem to be an unsafe situation but cannot find an OSHA regulation that speaks to it, they can look at an industry’s own standard, the Z in our case, to cite the employer for what they should have known about or should have done that would have mitigated a hazard or prevented an accident. In effect, a consensus safety standard becomes an enforceable regulation. OSHA obviously finds tons of value in the Z, because they issue General Duty citations to tree care employers more frequently than any other.

Peter Gerstenberger is TCIA’s senior vice president for industry support. He has served on the Accredited Standards Committee for Z133 through several revision cycles (30 years), and has worked with OSHA at the State and Federal level for that same length of time.

Gerstenberger and Bob Mead, CTSP, of Mead Tree & Turf Care in Woodbine, Maryland, will be presenting “OSHA/DOT Compliance Made Simple: Weaving the Rules Into your Day-to Day” at TCIA’s Business Growth Workshop, which will be held from April 30 to May 1, 2026, at the Arborwear Headquarters in Chagrin Falls, Ohio. Click this TCIA link for more information.