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Shared chemistry, different lenses

Both programs start with the same substances such as solvents, metals, acids, and combustion byproducts. IH focuses on what workers breathe in the workplace. It uses exposure limits such as OSHA permissible exposure limits or more protective guidelines from the National Institute for Occupational Safety and Health (NIOSH) and the American Conference of Governmental Industrial Hygienists (ACGIH). Environmental air programs focus on what leaves the property. They regulate criteria pollutants, hazardous air pollutants (HAPs), and toxics using emission limits, control requirements, and reporting rules.

The data tools look similar. IH uses personal and area sampling, direct-reading instruments, and task-based assessments. Environmental programs use emission factors, mass balance, continuous monitoring, and periodic stack testing. Both require documentation, quality control, and records.

Key differences that matter

The point of exposure is the biggest difference. IH evaluates the breathing zone of a worker during a task or shift. Environmental programs measure emissions at a release point, such as a stack, or estimate them across the site.

The time frame also differs. IH often looks at short-term peaks and full-shift averages to protect health during work. Air permits may set hourly, daily, or annual limits, and they may cap total emissions per year. Control strategies follow these goals. IH may rely on local exhaust ventilation, enclosure, or work practice changes. Air permits may require add-on controls such as thermal oxidizers, scrubbers, or filters.

Practical crossover: Using IH to inform permitting

IH data can reveal which tasks generate the highest concentrations and which compounds dominate exposure. That insight can refine emission estimates. For example, if wipe cleaning with a solvent produces the highest worker exposure, the same solvent may drive facility-wide volatile organic compound (VOC) emissions. The environmental team can use that knowledge to prioritize accurate emission factors, refine mass balance, or plan stack testing during peak operations.

IH data also helps define realistic operating scenarios for compliance testing. Stack tests that occur only at typical loads may miss worst case conditions. Pairing test timing with identified peak tasks can provide a more representative test and reduce the risk of later noncompliance.

Practical crossover: Using permits to inform IH

Air permits define regulated compounds, control devices, and operating limits. These details can guide IH planning. If a permit lists specific HAPs or requires a control device for a process, there is a clear signal that exposure to those compounds is possible near the source. IH can target those areas for baseline sampling, validate control performance, and confirm that capture systems are effective where workers are present.

Permit conditions also flag upset and startup modes. These periods can increase emissions. IH can align monitoring during these windows to assess short term exposures and ensure that work practices and protective measures are adequate.

Aligning controls for dual benefit

Engineering controls can serve both goals when designed as a system. Capture at the source reduces worker exposure and lowers emissions to the stack. Good enclosure and balanced ventilation improve control efficiency and reduce fugitive releases. Preventive maintenance on control devices supports permit limits and keeps workplace air clean.

Administrative controls can align as well. Standard operating procedures can link production rates, control device settings, and ventilation checks. Change management should include both IH review and an air permitting check to see if a modification triggers a permit update.

Communication and workflows

Successful crossover depends on routine communication. Regular meetings between safety and environmental staff help share results, plan sampling, and coordinate testing windows. Shared inventories of chemicals and processes reduce duplication and errors. A common data platform, or at least a consistent file structure, makes it easier to compare IH results with emission estimates and permit limits.

Clear triggers help teams act. Examples include a new chemical introduction, a process change, a spike in IH results, or a deviation in control device performance. Each trigger should prompt both an IH review and an environmental compliance check.

Key to remember: When teams connect their data and plans, they gain a clearer picture of risk. The result is stronger compliance, better worker protection, and more efficient operations.

Use your policies, programs, and people

There’s no quick way to erase workplace stress or ensure that all employees feel their mental health is at its peak, but workplaces can put policies and programs into place that provide a solid foundation of assistance and support. In addition, the actions of managers, supervisors, and coworkers contribute to a culture that helps employees thrive.

During recent “Let’s Talk About Employee Mental Health” webcasts, J. J. Keller opened up the chat to ask attendees what’s working for them. The result was a great list of actionable ideas that support worker mental health:

• Being there: “I tell people that I am in their corner and if they would like to talk, I am here. Also, I end emails with ‘Stay Fabulous!’”
• Notice something good: “Compliment others – it doesn't have to be work-related.”
• Time to recharge: “We give wellness time off, and we have added an unpaid leave of absence for mental health time.”
• Choose your benefit: “We have a wellness credit that employees can use toward mental health apps or gym memberships, etc.”
• Making connections: “We held a ‘get to know one another better’ bingo during a break last week; one-on-one meetings for goals are happening with supervisors/managers and their employees, and we have employee of the month by department, with a lunch with leadership.”
• Checking in: “I try to do employee check-ins every Friday by calling a few employees just to check in on how they're doing work wise and outside of work.”
• Embedded resources: “Our workforce is managing survival-level challenges, not just work-life balances. We introduced work-life coaches that are embedded with our employees.”
• Compassion during times of grief: “When we had an employee death last year, the company brought in a grief counselor. I thought that showed our company cared.”
• Help at your fingertips: “Our company offers a free app … that has stress management exercises and reminders. Our corporate office paid for a group subscription. We agreed to fund the cost as a benefit.”
• Get up and go: Exercise is a great stress-reliever, and attendees mentioned walking, pickleball, and a health/fitness app that offers personalized 5- to 10-minute workouts as well as rewards for reaching a goal. One workplace offers “fresh air Friday walks” during breaks and lunch.
• Fun and food: “One of the best HR initiatives that I did was a Jenga tournament, we do an annual employee appreciation food truck.” Another idea: “We have a truck come quarterly with fresh fruits and vegetables for staff to purchase.”
• Phone detox: “I recently did some research and found that people are coping with stress by doomscrolling. We are doing a little challenge to keep people off their phones.”
• Intranet info: “Our company has a website that has up-to-date mental health, bereavement, and financial help resources, that they can go to anonymously.”
• Multiple methods: “We have quarterly meetings and address mental health concerns when talking about leave. I send out our employee assistance program information after every employee relations talk as well. It's free for the first visits, which is very nice.”
• Wellness challenges: “We have a yearly 6-week Health and Wellness challenge. Employees get to learn about benefits offered and healthy habits.”

What do you do now?

There’s not enough time or energy to implement every possible mental health support program, and doing too much could result in programs not being implemented effectively. To decide which ideas would resonate with your workforce, look at data and gather input. To do this you can use:

• Corporate surveys that provide insights into programs employees would value and what they’d like to change.
• Wellness committee members who can offer ideas as well as generate grassroots support for wellness and mental health programs.
• Aggregate health risk assessment data, often provided by your insurance provider or a health vendor, that can yield statistical information about well-being and areas most in need of support.

Key to remember: Employees are looking for mental health support and there are a variety of ways to embed this into company culture.

Background

A Tree Care Operations proposal has been two decades in the making. On May 10, 2006, the Tree Care Industry Association (TCIA) petitioned OSHA to promulgate a standard specific to the industry. TCIA called tree care work one of the most hazardous occupations. The organization also contended that existing OSHA regulations did not adequately manage the hazards.

TCIA urged OSHA to consider using the American National Standards Institute (ANSI) Z133.1, American National Standard for Arboricultural Operations—Safety Requirements. ANSI Z133.1 has since evolved into today’s ANSI Z133.

The historical record shows that OSHA:

• Issued a preproposal in 2008,
• Held a stakeholder meeting in 2016, and
• Convened a small business panel in 2020.

Despite slating the proposed rule for April 2026 in the last agenda, OSHA has yet to publish it.

A construction connection

The 2008 preproposal notice pegged the Tree Care Operations rulemaking squarely under the general industry regulations at 29 CFR 1910. However, OSHA’s slideshow reveals that the agency is exploring whether its construction safety standards should come into play. Examples include crane operator certification and limited site clearance. Multi-employer worksites are also at issue.

The 2020 small business panel pressed OSHA to evaluate how and whether 29 CFR 1926 Subpart CC should apply to tree care operations. One approach may be to allow the Tree Care standard to reference Part 1926 where appropriate.

What’s driving the rulemaking?

Injury rates in landscaping services exceed most industries. The Bureau of Labor Statistics finds 124 injury and illness cases with days away from work per 10,000 workers from 2023 to 2024. (Compare this rate to just 94.5 per 10,000 for construction and 86.4 per 10,000 for manufacturing.) What’s more, the landscaping services industry records about 240 fatalities on average each year. That represents 4.6 percent of all work-related deaths in the U.S.

According to OSHA, tree trimming and tree removal can expose workers to serious hazards:

• Falling from trees,
• Being struck by falling trees/branches and flying objects,
• Vehicular traffic incidents,
• Cuts from high-speed saws,
• Being pulled into chippers, and
• Contact with energized power lines.

A pieced-together regulatory framework currently speaks to these hazards. This patchwork of standards covers ladders, lifts, cranes, slings, machine guarding, lockout/tagout, and hand and power tools. Other provisions govern noise, personal protective equipment, first aid, telecommunications, electrical safety, and hazardous chemicals. Likewise, the agency cites the General Duty Clause of the Occupational Safety and Health Act.

OSHA believes a comprehensive standard would:

• Help reduce injuries and fatalities,
• Provide clear and consistent guidance to employers,
• Be specific to hazards faced in these operations, and
• Address hazards not currently covered by OSHA standards.

An OSHA official adds that many day laborers, immigrants, and workers who don’t speak English are employed in the sector. OSHA calls these workers “disenfranchised,” making the rule a priority.

Anticipated proposed changes

OSHA is pursuing a regulatory (not deregulatory) proposed rule that would apply to “arboricultural operations and tree and ornamental palm maintenance and removal.” This includes protections for workers that:

• Prune, repair, maintain, or remove trees (not shrubs, hedges, bushes, or lawns);
• Provide any onsite support; or
• Use certain hazardous equipment related to tree care.

Provisions of the proposal would focus on:

• Pre-job preparation to identify hazards,
• Effective hazard controls, and
• Worker training.

The new standard may also set requirements for:

• Worker preparation, such as job hazard analyses, briefings, and communication;
• Worksite controls like traffic control;
• Fall protection; and
• Tools and equipment.

The scope of coverage will consider:

• General industry tree care activities (29 CFR 1910), and
• Construction activities like crane operation and site clearance (29 CFR 1926).

OSHA reports that the standard would be largely consistent with ANSI Z133 and OSHA state-plan state regulations on tree care. At the same time, the agency acknowledges the rulemaking remains a challenge to develop. Foundational questions like how to define tree versus multi-stemmed shrub are “deceptively complex.”

Key takeaway

After two decades, OSHA appears poised to issue a proposed rule for tree care operations. The agency presented a rulemaking summary and received unanimous support from ACCSH. The rule may impact Parts 1910 and 1926.

Can we prohibit loose clothing, long hair, or jewelry for workers operating machinery?

OSHA doesn’t specifically address this in its machine guarding regulation (29 CFR 1910.212). However, agency guidance clearly recognizes these items as hazards around moving machinery:

• Safeguarding Equipment and Protecting Workers from Amputations (OSHA 3170) advises employers to instruct workers not to wear gloves, jewelry, or loose-fitting clothing when operating grinding machines and to secure long hair.
• OSHA’s woodworking eTool similarly states, “Do not allow workers to wear loose clothing or long hair. Loose clothing or long hair can be easily caught up in rotating parts.”

Employers are expected to address recognized hazards in their workplace. As a result, many employers adopt policies restricting loose clothing, long hair, or jewelry when working near machinery. OSHA may issue citations under the General Duty Clause (Section 5(a)(1) of the OSH Act) or the machine guarding standard if workers are exposed to entanglement hazards.

Is there a maximum opening size before a machine guard is required?

OSHA’s machine guarding standard doesn’t specify a maximum opening size before a guard is required. Instead, it requires that the guard be “in conformity with any appropriate standards” and designed and constructed to prevent operators from having any part of their body in the danger zone during the operating cycle.

OSHA refers to the following “appropriate standards”:

• ANSI B11.0, Safety of Machinery
• ANSI B11.19, Performance Requirements for Risk Reduction Measures: Safeguarding and other Means of Reducing Risk
• NFPA 79, Electrical Standards for Industrial Machinery

Additionally, there are several machine-specific ANSI B11 series standards, all of which can be viewed here. These standards provide detailed guidance on guard openings, reach distances, and risk reduction methods.

Must foot pedals used to operate machinery be guarded or have a cover?

If unintentionally pressing on a foot pedal exposes workers to a hazard, OSHA expects employers to implement protective measures, such as guarding or covering the pedal. Although there are no foot pedal requirements in OSHA’s machine guarding standard, its Mechanical Power Presses standard (29 CFR 1910.217) offers some, such as:

• The pedal must be protected against accidental operation (e.g., from falling objects or unintended contact).
• The pedal must have a nonslip contact surface.
• Return springs must be designed to prevent failure.
• Counterweights must have enclosed travel paths.

Key to remember: Even in situations where OSHA does not provide detailed regulatory requirements, recognized hazards like entanglement or unintended machine activation must still be controlled.