Chainsaw PPE: what a saw operator wears, and where each item is specified
A chain saw operator owes head, eye, face, foot, hand and hearing protection, specified in Article 10 of California's General Industry Safety Orders and in 29 CFR 1910 Subpart I. Leg protection is the exception: only the logging standards require chaps, so a tree crew's duty is built from a hazard assessment and ANSI Z133-2026 section 3.3.8.
A three-person crew pulls up to a 40-foot silver maple over a 12 kV primary at 7:40 in the morning. The climber puts on a helmet, glasses, muffs, gloves and boots, ties in, and takes a top-handle saw up.
The groundman stays down, runs a rear-handle saw through the brush, and feeds the chipper. The groundman is the one wearing chaps. Ask which safety order put them there and the honest answer is none of them, and the reason is worth knowing before a prime asks for the specification in writing.
What a saw operator wears, and where each item is written
California's tree work article leaves every item of protective equipment to be named somewhere else. The items come from four documents at once, and three of those four are enforceable.
Six of the seven rows are ordinary. The leg protection row is the one that generates argument on a bid walk, in a contractor audit and at an inspection, and it takes four sections of this page to answer properly.
Article 12 governs the saw and never dresses the operator
Section 3425 is California's power saw section, and its twelve numbered provisions all govern the machine and the body position.
Operation and maintenance per the manufacturer's instructions, at (a)(1).
How the saw is started, at (a)(2).
The 15-pound threshold above which a saw used in a tree gets its own line, at (a)(3).
The constant pressure control and the clutch adjustment, at (a)(4) and (a)(7).
Everyone else clear of the saw before it starts, at (a)(5).
A stopped engine while the saw is carried up into a tree, at (a)(6), and a chain brake engaged past 10 feet on the ground, at (a)(8).
A stopped saw for cleaning, refueling, adjustment and repair, at (a)(9).
The second point of attachment while cutting in a tree, at (a)(10).
The 10-foot exclusion around a running pole saw or brush saw, at (a)(11).
The quick shutoff switch, at (a)(12).
Read all twelve and the subject stays the machine. A helmet, a glove, a boot and a pair of chaps are absent from every line. Article 12 handles protective equipment three other ways instead. Section 3421(c)(2) puts the proper and safe use of personal protective equipment into the required training.
Section 3421(f) puts "the appropriate personal protective equipment needed" into the job briefing a qualified tree worker gives before each work assignment. And section 3428(b), the stump cutter section, is the one place in the whole article that says where the equipment itself is specified:
Each employee in the immediate area of stump grinding operations (including the stump cutter operator) shall wear personal protective equipment as required by Article 10 of the General Industry Safety Orders.
That sentence appears under stump cutters and points everywhere. What the rest of Article 12 owns is a separate page; the address it gives is the subject of this one.
Article 10, and the certificate that has to name four things
Article 10 runs from section 3380 to the end of the personal protective device orders, and five sections in it carry the items a saw operator wears.
Section 3380 is the gate. Subsection (f)(1) requires the employer to assess the workplace for hazards that necessitate PPE, then select it, communicate the selection, and select PPE that properly fits each affected employee. Subsection (f)(2) turns that assessment into a document:
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.
Four fields, and a compliance officer can check all four in under a minute. Subsection (f)(7) requires a second certification for the training, carrying the name of each employee trained, the dates, and the subject. Note the limit the article sets on itself at (f)(8): subsections (f)(1), (f)(2) and (f)(4) through (f)(7) apply only to sections 3381, 3382, 3384 and 3385. The body protection section is outside that list, which matters in a moment.
Section 3381 sets head protection, and it is the section that carries the conductor. Subsection (b) incorporates ANSI/ISEA Z89.1-2009, Z89.1-2003 or Z89.1-1997. Subsection (c)(2) then sorts helmets by exposure.
Exposure | Permitted class |
Flying or falling objects alone | Class C, E or G |
Contact with conductors less than 600 volts | Class E or G |
Contact with conductors greater than 600 volts | Class E |
Over the 12 kV primary on that maple, the answer is Class E, and subsection (c)(3) adds that a helmet for an employee exposed to high-voltage shock and burns also has to meet Section 9.7, Electrical Insulation, of whichever ANSI edition it was approved under.
Section 3382 sets eye and face protection, and California's incorporated specification is old. Subsection (d)(1) requires devices purchased after January 12, 1995 to conform to ANSI Z87.1-1989, with an allowance for integral lens and frame designs that match it. Federal 1910.133(b)(1) accepts ANSI/ISEA Z87.1-2010 as well. A crew buying current-production safety glasses is clear either way, and a spec writer copying the California citation should know it names a 1989 document.
Section 3383 is body protection, and all three of its subsections stay general. It says body protection "may be required," requires clothing appropriate for the work, and bans loose sleeves, tails, ties, lapels and cuffs that can entangle in moving machinery. It stops short of a specification or a test standard. This is the section a chaps requirement would have to be read into, and "may be required" is not a requirement.
Section 3384 is hand protection, and it carries an exception a saw crew should read twice. Hand protection for cuts, lacerations and abrasions becomes optional where the employer's own section 3380(f) hazard assessment determines that the risk to the hands is infrequent and superficial.
Subsection (b) then bans gloves where there is a danger of entanglement in moving machinery, which is the reason gauntlet gloves come off at the chipper. Section 3385 is foot protection, and footwear purchased after January 26, 2007 has to meet ASTM F 2412-05 and F 2413-05.
California does require chaps, in a safety order a tree crew never opens
The rule exists. It is section 6283(a):
Employees, such as fallers, buckers, limbers, choppers, landing chasers, and others performing similar operations, who operate chain saws, shall use leg protection such as chaps, pads, inserts, or other protective garments or devices that are labeled as meeting the specifications of ASTM F 1897-98, Standard Specification for Leg Protection for Chain Saw Users. Exceptions: 1) High climbers described in Section 6287. 2) Employees, with employer's concurrence, who use a chain saw incidental to their normal assigned tasks.
That is a real mandate with a named test standard and a labeling requirement. It sits in Subchapter 13, the Logging and Sawmill Safety Orders, and section 6248 says who those orders reach:
These Orders establish minimum standards and apply to all places of employment in California where logging and sawmill operations as defined below are conducted. ... Logging Operations. Cultivation and harvesting of timber, including access, falling and bucking, yarding, loading, and transportation of logs.
Cultivation and harvesting of timber. A crew clearing a maple off a 12 kV primary is not cultivating or harvesting timber, and the brush is going into a chipper rather than to a point of delivery. Section 6248 adds the note that closes the loop, sending equipment and processes outside its reach to whichever other safety orders govern them.
Cal/OSHA's own Tree Work Safety Guide confirms the reading by omission. Its list of other commonly applicable Title 8 sections runs to nine entries, among them 2940.2, 2951, 3203, 3328, 3380, 3395 and Article 105. Section 6283 is absent from it, and so are sections 3381 through 3385.
The federal leg protection rule lives in the logging standard too
Section 1910.266(d)(1)(iv) is the one federal rule that describes chain saw leg protection down to the garment:
The employer shall provide, at no cost to the employee, and assure that each employee who operates a chain saw wears leg protection constructed with cut-resistant material, such as ballistic nylon. The leg protection shall cover the full length of the thigh to the top of the boot on each leg to protect against contact with a moving chain saw. Exception: This requirement does not apply when an employee is working as a climber if the employer demonstrates that a greater hazard is posed by wearing leg protection in the particular situation, or when an employee is working from a vehicular mounted elevating and rotating work platform meeting the requirements of 29 CFR 1910.67.
The next subparagraph, (d)(1)(v), goes further than anything in Article 10 and requires a chain saw operator's foot protection to be constructed with cut-resistant material.
Both live inside a standard scoped to logging. Paragraph (b)(1) covers "all types of logging, regardless of the end use of the wood," and paragraph (c) defines logging operations as those "associated with felling and moving trees and logs from the stump to the point of delivery." OSHA once published a directive with criteria for deciding when a tree removal was large enough to be logging, and cancelled it.
The June 30, 2021 enforcement guidance opens by recording that CPL 02-01-045 was cancelled on June 24, 2021. The replacement guidance drops the scale criteria, and it leaves 1910.266(d)(1)(iv) out of its treatment of tree care employers entirely.
Paragraph (r)(5) opens one door into that standard, and PPE is not behind it
There is exactly one route by which the logging standard reaches a line clearance crew, and it is worth tracing because it is easy to over-read. Section 1910.269(r)(5) reads:
Gasoline-engine power saws. Gasoline-engine power saw operations shall meet the requirements of § 1910.266(e) and the following:
Paragraph 1910.266(e) is titled Hand and portable powered tools. It is where the chain brake requirement lives at (e)(2)(i), the drop-start prohibition at (e)(2)(vi), the start-with-the-chain-brake-engaged rule at (e)(2)(vii), the thumbs-and-fingers-encircling rule at (e)(2)(viii), and the shift-start inspection of chains, mufflers, brakes and nose shielding at (e)(1)(ii). Every one of those crosses into line clearance work.
The leg protection rule is not in paragraph (e). It sits in paragraph (d), the general requirements paragraph, which (r)(5) leaves out. The omission reads as deliberate, because 1910.269(r) knows how to require PPE when it wants to. Paragraph (r)(2)(v) requires each employee in the immediate area of an operating chipper feed table to wear PPE as required by Subpart I. Paragraph (r)(4)(ii) requires the same of each employee in the immediate area of stump grinding, the stump cutter operator included. The paragraph on gasoline-engine power saws stays silent.
What does reach a line clearance trimmer federally is 1910.269(g)(1), which requires personal protective equipment to meet the requirements of Subpart I. Subpart I holds head protection at 1910.135, eye and face protection at 1910.133, foot protection at 1910.136 and hand protection at 1910.138. Leg protection appears in it nowhere at all.
One further consequence of the tier structure belongs here, because it is a clothing question. Section 1910.269(a)(1)(i)(E)(2) applies only paragraphs (a)(2), (a)(3), (b), (c), (g), (k), (p) and (r) to line clearance tree trimming performed by trimmers who are not qualified employees. Paragraph (l) is absent from that list, so the flame-resistant and arc-rated clothing requirements at 1910.269(l)(8) stop short of them.
A trimmer who is a qualified employee gets the entire section except (r)(1), and (l)(8) comes with it. Which tier a name sits in is therefore also the question of whether that name owes arc-rated clothing, and the answer changes with the crew rather than with the tree.
So who owes chaps on a California line clearance job
The duty is real. It is built rather than quoted, and it comes from three places that stack.
First, the hazard assessment. Section 3380(f)(1) and 29 CFR 1910.132(d)(1) both require an employer to assess the workplace and select PPE that protects against the hazards identified. An employer whose assessment identifies chain saw laceration to the leg and then leaves the leg unequipped carries a defect on the face of its own certificate.
Cal/OSHA's Tree Work Safety Guide names chain saw lacerations among the most commonly reported tree work accidents and lists "cut-resistant pants or protective leg chaps" in its own chain saw PPE list. That guide sits outside Title 8. It is the Division's published view of what the hazard is, which is the first half of any hazard assessment argument.
Second, OSHA's enforcement guidance says so directly. The June 30, 2021 memo instructs compliance officers to assess whether employers provide and ensure use of required PPE for hazards other than falls, "(for example, the provision and use of cut-resistant leg protection while operating chain saws)." The route it contemplates runs through 1910.132 rather than 1910.266.
Third, the General Duty Clause, which takes over wherever the standards fall silent. The same memo sends compliance officers weighing a General Duty Clause citation over hand and portable powered tools to two consensus standards, ANSI B175.1-2012 and ANSI Z133-2017, and what that sentence does to Z133 is set out separately. A consensus standard that says chaps is the evidence that abatement is feasible.
Who decides, then. In California, the compliance officer writes it, the employer appeals it, and the Occupational Safety and Health Appeals Board decides whether the hazard assessment supported the selection. The whole question is settled after the fact, which is why the practical move for a prime evaluating a contractor is to ask for the section 3380(f)(2) certificate and read what it identified, rather than to ask whether the crew wears chaps.
ANSI Z133-2026, clause by clause
Section 3.3 of ANSI Z133-2026 is the only document in this article that treats a saw operator's protective equipment as one subject. It has ten clauses.
Clause | What it requires |
3.3.1 | Employer provides and requires PPE where there is a reasonable probability of preventable injury |
3.3.2 | Employer assesses the workplace and completes a PPE hazard assessment certification |
3.3.3 | Employer trains in use, inspection, care, fit, maintenance and replacement |
3.3.4 | Head protection conforming to ANSI Z89.1; Class E near electric supply lines |
3.3.5 | Hearing protection above an 8-hour TWA of 85 dBA |
3.3.6 | Eye protection conforming to ANSI Z87.1 |
3.3.7 | Footwear appropriate to known hazards, approved by the employer |
3.3.8 | Cut-resistant leg protection to ASTM F1414 and F1897, during ground operations |
3.3.9 | Face protection conforming to federal regulations and ANSI Z87.1 |
3.3.10 | Respiratory protection conforming to federal regulations and ANSI Z88.2 |
Clause 3.3.8 is the sentence every specification quotes:
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 the manufacturer's recommendations.
Two standards, both named. F1897-20 is the product specification for leg protection for chain saw users; F1414-19 is the test method for measuring cut resistance in lower-body protective clothing. A garment labeled to F1897 alone meets the citation most specifications print, and 3.3.8 asks for both. The glossary at the back of the 2026 edition defines leg protection by pointing at 3.3.8, so the clause supplies its own definition.
Two absences in that list are worth noting. Section 3.3 leaves hand protection out entirely, so gloves on a Z133 job come from the employer's own assessment under 3.3.2 and from the chipper rule at 9.6.4 that bans gauntlet-type gloves. And 3.3.7 puts nonspecialty footwear outside the employer's obligation to provide, which is a payment allocation inside a consensus standard rather than a specification.
If your contract or training deck cites Z133 by clause number, check it against the current edition before relying on it. The 2026 edition moved a great deal, including section numbers that older specifications quote by heart.
Aloft, three rules agree, and one of them for a different reason
The climber in the maple has bare legs under the saddle, and all three documents are fine with that.
Section 1910.266(d)(1)(iv) excepts an employee working as a climber, on the condition that the employer demonstrates a greater hazard in the particular situation, and separately excepts an employee working from a vehicle-mounted elevating and rotating work platform meeting 29 CFR 1910.67. The first exception carries a burden the employer has to discharge, and the second stands on its own.
Z133-2026 section 3.3.8 reaches the same result by drafting, because its rule was drawn at ground operations from the start. Section 6283(a) excepts high climbers described in section 6287, which is a logging term of art for a worker topping a spar tree rather than a general permission for anyone aloft.
The practical consequence is a boundary that moves with the worker rather than the job. The climber descends at 10:15, takes the rear-handle saw and starts bucking the wood on the driveway. That is a ground operation, and every rule above is back in force. So is the second point of attachment rule at 8 CCR 3425(a)(10) the moment the climber goes back up, and the fall protection rules for the bucket if the job finishes from a lift.
Hearing protection: the subsection that prints no number
Section 3421(n) hands the whole question to Article 105 and leaves every number to it:
When employees are required to work in areas in which the noise levels exceed the allowable standards for occupational noise, the employer shall provide hearing protection and training as required in Article 105 of these Orders.
Article 105 supplies the numbers. Table N-1 of section 5096 permits eight hours at 90 dBA, one hour at 105 dBA, and thirty minutes at 110 dBA. Section 5097(a) requires a hearing conservation program at an 8-hour TWA of 85 dBA, and section 5098(a)(1) requires hearing protectors to be made available at no cost at the same level. Federal 1910.95(c)(1) and 1910.95(i)(1) set both at 85 dBA as well, and Z133-2026 section 3.3.5 repeats the figure.
One monitoring provision is written for exactly this crew. Section 5097(b)(2)(B) requires representative personal sampling, rather than area monitoring, where circumstances such as high worker mobility, significant variations in sound level, or a significant component of impulse noise make area monitoring inappropriate.
A groundman who runs a saw for four minutes, feeds a chipper for twenty, and stands in a quiet drop zone for ten is high worker mobility and significant variation in one person. A dosimeter on that collar for a shift is what produces the number that decides whether an audiogram is owed, and that number is the employer's to produce.
Who pays for it
Federally the rule is 1910.132(h)(1): protective equipment used to comply with Part 1910 is provided by the employer at no cost. Three exceptions matter to a saw crew, and chaps fall outside all three.
Exception | Citation | What it releases |
Non-specialty safety-toe footwear and non-specialty prescription eyewear | 1910.132(h)(2) | Only where the employer permits them off the job site |
Shoes or boots with built-in metatarsal protection, at the employee's request | 1910.132(h)(3) | Only where the employer also provides metatarsal guards |
The logging boots required by 1910.266(d)(1)(v) | 1910.132(h)(4)(i) | Logging boots, by name |
The last row is the tell. When OSHA wanted to release an employer from paying for a specific item of chain saw PPE, it named the item and its citation. Leg protection was left off that list. Section 1910.266(d)(1)(iv) says "at no cost to the employee" in its own text.
Article 10 stops short of a payment paragraph anywhere in its text. Section 3380(d) goes the other way and contemplates equipment "whether employer or employee provided," requiring only that it comply with Title 8 and be maintained safely.
The payment duty in California comes from Labor Code section 6401, which requires every employer to furnish and use safety devices and safeguards, and from Labor Code section 2802(a), which requires an employer to indemnify an employee for necessary expenditures incurred in discharging their duties. A crew buying its own chaps to satisfy the employer's own written specification is the fact pattern section 2802 was written for.
Where this is unsettled, and who decides
Four things on this page stay open, and a spec writer should say so rather than invent an answer.
Whether 8 CCR 6283 can ever reach a tree crew. A contractor taking down forty trees on a right-of-way widening, bucking the stems and hauling logs to a landing, is doing something section 6248 describes. Cal/OSHA has left that line undrawn, and the federal criteria that used to draw it went away with CPL 02-01-045 in June 2021. The compliance officer decides on the day, and the Appeals Board decides afterward.
Whether leg protection is owed in a bucket in California. The federal exception at 1910.266(d)(1)(iv) names a 1910.67 platform explicitly. California offers an aerial device exception nowhere, because the only requirement one would release sits in the logging orders. An employer relying on Z133 3.3.8 is relying on a clause whose trigger is "ground operations," which describes the driveway rather than the bucket.
Head protection at exactly 600 volts. Section 3381(c)(2)(B) covers conductors less than 600 volts and (c)(2)(C) covers conductors greater than 600 volts. A 600 volt nominal conductor falls in the gap, and the conservative reading, which is the one an employer should write down, is Class E.
Whether Z133 binds anybody. It is a consensus standard rather than a regulation. It becomes enforceable when an employer adopts it into its own program, when a contract requires it, or when OSHA uses it as feasible-abatement evidence under the General Duty Clause. The June 30, 2021 memo does the third of those by name.
For a prime writing a contractor specification, four citations do the work.
8 CCR 3380(f) and 29 CFR 1910.132(d), for the assessment.
8 CCR 3381 through 3385, for the items that carry a California number.
ANSI Z133-2026 section 3.3.8, for the leg protection specification the safety orders left unwritten.
Labor Code section 6401, for who buys it.
Then ask for the hazard assessment certificate by its four fields. A contractor who can produce that page has answered the question. A photograph of a crew in chaps answers a different one.
Further reading
Article 12 of the General Industry Safety Orders: the nine sections that govern tree work: The article that governs the saw, and the one subsection that says where the clothing is specified.
29 CFR 1910.269(r): the three tiers, and what each one may approach: Which paragraphs of 1910.269 reach a trimmer decides whether the arc-rated clothing rule reaches them too.
ANSI Z133 as a field reference: What the standard is, what it is not, and the section numbers the 2026 edition moved.
Frequently asked questions
Does California require chainsaw chaps?
In logging, yes. Title 8 section 6283(a) of the Logging and Sawmill Safety Orders requires employees who operate chain saws to use leg protection labeled as meeting ASTM F 1897-98. Those orders apply, under section 6248, to logging and sawmill operations, which section 6248 defines as the cultivation and harvesting of timber and the manufacture of lumber, plywood, shake, shingle and lath. Article 12, the tree work article, contains no leg protection requirement, and neither does Article 10, the personal protective equipment article. For a tree crew the duty is built from the hazard assessment required by section 3380(f)(1).
Where is chainsaw PPE written for a California line clearance crew?
In four places at once. Article 10 of the General Industry Safety Orders sets head protection at section 3381, eye and face protection at 3382, body protection at 3383, hand protection at 3384 and foot protection at 3385. Hearing protection comes through section 3421(n) to Article 105. Federally, 29 CFR 1910.269(g)(1) requires personal protective equipment to meet Subpart I of Part 1910. ANSI Z133-2026 section 3.3 sets the consensus specification, which is not law but is what a compliance officer reads when no standard is on point.
Does 29 CFR 1910.266 require leg protection for tree trimmers?
Not for tree trimming. Section 1910.266(d)(1)(iv) requires cut-resistant leg protection from the full length of the thigh to the top of the boot, but 1910.266(b)(1) applies the standard to logging, and 1910.266(c) defines logging operations as felling and moving trees and logs from the stump to the point of delivery. Section 1910.269(r)(5) pulls one part of the logging standard into line clearance work, and that part is 1910.266(e), the hand and portable powered tool paragraph. The personal protective equipment paragraph, 1910.266(d)(1), is not pulled across.
Is leg protection required while running a saw in a tree?
No rule in force requires it aloft. ANSI Z133-2026 section 3.3.8 requires cut-resistant leg protection during ground operations. Section 1910.266(d)(1)(iv) excepts an employee working as a climber where the employer demonstrates a greater hazard, and excepts an employee working from a vehicle-mounted elevating and rotating work platform meeting 29 CFR 1910.67. Title 8 section 6283(a) excepts high climbers described in section 6287. A climber who comes down and starts bucking on the ground is back inside all three.
Who pays for chainsaw PPE?
The employer, in both jurisdictions, with narrow exceptions federally. Section 1910.132(h)(1) requires protective equipment used to comply with Part 1910 to be provided at no cost. Paragraph (h)(2) excepts non-specialty safety-toe footwear and non-specialty prescription eyewear where the employer permits them off the job site, and paragraph (h)(4)(i) excepts the logging boots required by 1910.266(d)(1)(v). Leg protection, head protection and hearing protection are not excepted. California's Article 10 contains no payment paragraph; the duty runs through Labor Code section 6401 and, for reimbursement, Labor Code section 2802.
