TCIA submits comments to Cal/OSHA: presence-sensing devices on brush chippers


On January 29, 2019, a coalition of TCIA members participated in a Cal/OSHA Advisory Committee meeting concerning presence-sensing (passive sensing) devices on brush chippers. Peter Gerstenberger, TCIA’s senior advisor for safety, compliance & standards, helped organize the coalition and participated in the meeting.

Briefly, Cal/OSHA had been petitioned to change its rules, mandating that all mechanical infeed brush chippers used by affected employers be equipped with presence-sensing devices.

Currently in the U.S., the only commercially available presence-sensing device is the ChipSafe device, which Morbark offers as an option. Significantly, Morbark and the other leading brush-chipper manufacturers took a position against a mandatory requirement for a proprietary safety device on all chippers.

The TCIA coalition, including the petitioner, met the afternoon before the committee meeting. They had a fruitful discussion, and many watched and were duly impressed by a demonstration of the petitioner’s working presence-sensing device, retrofitted to a Bandit chipper.

Nevertheless, the strong consensus of the group was that the petitioner’s proposal should not be adopted by Cal/OSHA. One safety director conveyed the group’s sentiment when he said, “If this is implemented, there’s no way I can manage it.” He meant that from an operational standpoint, it would be impossible to ensure the company’s fleet of chippers all had functional, properly calibrated devices at any given moment; and also from a human behavioral standpoint that every crew member would remember to wear the needed protection on both wrists and ankles at all times.

After a full day of discussion, the Advisory Committee facilitator asked each member in turn for their recommendation to the Occupational Safety & Health Standards Board (the rule-making body within Cal/OSHA). Their unanimous response was that Cal/OSHA should adopt the recommendations made in TCIA’s written comment:

Cal/OSHA regulatory language should be revised to reflect what is currently required in the industry’s consensus standard, ANSI Z133. Going forward, all mechanical-infeed chippers shall be required to have an 85-inch infeed chute, a quick-stop-and-reversing device, and at least one other device capable of stopping the infeed rollers. The implementation date should be decided through ongoing discussion of the committee.

All these protections have been required by the Z133 standard for at least 20 years, and all brush chippers manufactured for commercial use already comply. Significantly, this recommendation allows for a presence-sensing device to be the “one other device” on the chipper, at the discretion of the employer.

View the full comments submitted by TCIA.