WSCA Calls for Reduction to Danger Tree Red Tape

The WSCA is negotiating with the Wildlife Tree Committe to have treeplanting and related activities reduced to the new catergory of a very low risk activity.

The WSCA is in talks with the Wildlife Tree Committee in an attempt to reduce regulation around the Wildlife/Danger Tree regulations for the silviculture industry. The guidelines the WSCA is proposing are based on some of the new classifications described in today’s offical announcement of recent changes in the Danger Tree Assessors manual.

The following is a copy of our letter sent to the Wildlife Tree Committe following a field trip earlier this month. Comments should be sent to WSCA at hotpulp@netidea.com

Western Silvicultural Contractors’ Association

1 June 2001

Memo to: Todd Manning, WTC Chair Richard Thompson, MELP Dave Rowe, WCB Peter Bradford, MoF

From: John Betts, WSCA

Following our field tour this week and after some reflection and discussions with contractors across the province the WSCA would like to make some proposals regarding the wildlife tree issue and the province’s treeplanting industry. We recommend that these suggestions be considered immediately and, if accepted, implemented as soon as practicable.

1. Make plantation site treeplanting a very low risk activity similar to forest surveys, tree marking, foot travel etc. Standtending activities such as plantation brushing and weeding should also be considered for this category. Planting and the latter post-planting silvicultural activities have low exposure time to risks and involve no disturbances to trees under normal site conditions.

2. Set the above standard for normal soil conditions (not frozen, saturated, or site prep disturbed) and wind conditions below 30 km/hr on the ground. (40 km is very high based on our observations on the tour.)

3. Emphasize and insist that treeplanting camp sites, where the exposure to danger tree risks is much higher, be assessed and proper treatment taken based on relevant standards laid out in the tree assessor’s work book. In camp settings even healthy trees should be scrutinized since history shows they are prone to blowdown in certain situations.

4. Establish a silviculture industry standard in cooperation with the WSCA for creating awareness of danger tree hazards and set some prudent guidelines for training foremen and crews based on the “heads up” principle.

The reason for the above recommendations is that generally the risk level to treeplanting crews working on sites with wildlife trees is very low. We know of no anecdotal or statistical evidence showing treeplanting injuries resulting from overhead hazards. It is likely that the specific danger tree risk is not above the general background hazard level present on the average plantation site. In this context danger trees should not attract any more attention than the general vigilance required for the varying array of safety issues that present themselves regularly on a work site.

This opinion is widely shared by contractors who point out there are far more acute areas of risk on site than danger trees. For instance wildlife attacks have resulted in fatalities and more injuries than trees. If we were to apply a similar management strategy to wildlife as we do to hazardous trees contractors would have to shoot every bear in the vicinity before commencing work.

This overstatement of the risk and subsequent treatment regimes are counter productive in that they encourage the largely unnecessary falling of trees eliminating potential wildlife habitat and stand mix benefit. Likewise the elimination of plantable area contradicts the goal of proper restocking. It is certain that the risks involved in sending a faller out to treat the trees adds up to more hazard than prudently and briefly working beneath them in the course of planting or other related activities.

From the business side the costs of assessing and treating blocks to eliminate a negligible hazard are hard to justify. Forest companies for the most part seem less then enthusiastic in their support for this program. The result has left contractors in the untenable position of being caught between forest company accountants and WCB officers. Worse, the fines for violations of these rules are enough to crush even the largest silviculture firm. Obviously it is not the intent of the WCB or any government agency to put a legitimate company out of business. However, this latter regulatory potential alone should indicate the need for some major adjustments around danger tree and related regulation guidelines and interpretation.

Finally, our recommendations are based on the philosophical tenet of Occum’s Razor; the principle that the best remedy to most problems is generally the simplest. Recently I was shown a forestry consultant’s four page interpretation of the new guidelines we are working on. It was hopelessly elaborate, inaccurate, and bound to confuse any potential client into defeat. It is this kind of misunderstanding that we are trying to avoid since the outcomes do not positively reflect the intent or the work of the Wildlife Tree Committee nor do they work very well in practice in the field.

We hope our proposals are not viewed as an attempt to abandon our employee obligations with regard to safety around danger trees. Within our proposals there is considerable opportunity to ensure diligence and reasonable levels of safe management. Rather, this is an attempt to bring the regulatory framework in line with what we see as a more appropriate and practical approach suited to our industry and its circumstances. We also think our proposals better reflect the broad goals of the Wildlife Tree Committee.

Both Dave Wilson and I are available to discuss this with all of you and we look forward to your collective and individual responses.

Yours truly,

John Betts Executive Director WSCA

— Western Silvicultural Contractors’ Association WSCA Executive Director’s Office, RR#3 S36 C9, Nelson B.C. V1L 5P6 Phone/fax 250-229-4380 e-mail hotpulp@netidea.com