The Forest Service, working with other agencies, partners and the public, established a policy for training and use of cross-cut and chain saws. Sawyers covered by those policies often maintain trails on national forests and grasslands, help fight wildfires, and work in wilderness where crosscut saws are required. The national saw directive standardizes training, evaluation, certification, and safety procedures for sawyers operating on lands managed by the agency.
Saw Operations Guide
FS Saw Operations Guide (.doc)
Federal Register notice
Issuance of FSM 2350 (.doc)
National Saw Policy Webinar Documents August 23, 2016
Saw Policy Webinar (recorded August 23, 2016)
Closed Captioning Transcript (.doc)
Chat Transcript (.doc)
Poll Results (.doc)
National Saw Program Policy Frequently Asked Questions
Q1. What is the purpose of a national saw policy?
A: The National Forest Saw Policy will facilitate the safe use of chain saws and crosscut saws. The intent of the policy is to optimize critical skills and cooperative opportunities for trail maintenance and other projects on NFS lands. The policy enables the development of standalone cooperator and volunteer training and certification programs, instructors and evaluators, and ensures nationally consistent training, evaluation and certification requirements for all.
Q2. To whom does the new policy apply?
A: It applies to employees, volunteers, participants, training consultants, and cooperators (other than those working under interagency fire management cooperative agreements) operating chainsaws and crosscut saws on National Forest System lands.
Q3. Why are Cooperators who are working under interagency fire management cooperative agreements excluded and what does this mean for my Incident Qualification Card (red card)?
A. This only applies to Wildland Fire Incidents. Interagency fire management cooperative agreements adhere to Interagency Standards outlined in the National Wildland Fire Coordinating Group (NWCG) publication PMS 310-1, (National Interagency Incident Management System Wildland Fire Qualifications System Guide). Forest Service Wildland Fire Saw Operators must meet the certification requirements of the FS National Saw Policy as well as the NWCG qualifications required for Saw Operators. Once a Forest Service Wildland Fire Saw Operator meets these requirements they will be qualified at the appropriate level (A,B or C); however, for purposes of mobilization in the Resources Ordering and Status System (ROSS) the qualification will be cross walked in the Incident Qualifications and Certification System (IQCS) as FAL 3/2/1.
Q4. Who are cooperators?
A: Cooperator. An individual or entity that voluntarily enters into a challenge cost share, participating, collection, or other agreement with the Forest Service to work on a project under FSM 1580.5 and FSH 1509.11, section 91.2, other than another agency working with the Forest Service on fire management activities (FSH 1509.11, ch. 50).
Members of The Corps Network like the Student Conservation Association and other youth corps organizations, and partners like the Southern Appalachian Wilderness Stewards and Pacific Crest Trail Association are examples of cooperators working with the Forest Service.
Q5. How will agreements be modified to reflect the new national saw policy requirements?
A: Appropriate provisions regarding use of saws must be inserted in challenge cost-share, participating, collection, or other mutually beneficial agreements. See FSM 1580 and FSH 1509.11, for direction on agreements generally and FSM 1833.11, for direction on use of challenge cost share agreements used in tandem with Forest Service volunteer agreements. See FSH 1509.11, chapter 50, for direction on interagency fire management agreements.
There will be a transition period for amending existing agreements, per language in the Federal Register notice. For new agreements, the forms will be amended to include the new language. When modification is necessary for existing agreements (e.g., to add funding or extend the expiration date), this provision must be added at the time when that modification is processed and be noted in the ‘other’ area in Box 8 and routed for bilateral signature. Provisions will be available shortly after publication of the new policy in the Federal Register and will be as follows:
1509.11, Section 91.2–TRAINING, EVALUATION, AND CERTIFICATION OF SAWYERS USED BY COOPERATORS. Any of the cooperator’s employees, and any participants and volunteers engaged on behalf of the cooperator and Forest Service, who will use chain saws or crosscut saws on National Forest System lands to conduct the program of work contained in this agreement must be trained, evaluated, and certified in accordance with Forest Service Manual 2358 and Forest Service Handbook 6709.11, section 22.48b. The cooperator is responsible for providing this training, evaluation, and certification, unless the Forest Service and the cooperator determine it is not in the best interest of the partnership. In these circumstances, the Forest Service, upon request and based on availability of Agency funding and personnel, may assist with developing and conducting training, evaluation, and certification of the cooperator’s employees, and any volunteers and participants engaged on behalf of the cooperator and the Forest Service, who will use chain saws or cross cut saws on National Forest System lands.
(APPLICABILITY: This provision is mandatory for new collection, challenge cost-share, participating, and stewardship agreements where the cooperator anticipates that its employees or participants and volunteers engaged on behalf of the cooperator and Forest Service will use chain saws or crosscut saws to conduct the program of work contained within the agreement. This provision is also mandatory when modifications to existing agreements of this type are necessary, e.g., for additional funding or extensions. Where mandatory, this provision must be inserted in the agreement and will become effective [insert date 1 year from the date of publication of the national saw directive in the Federal Register].)
Note: Contractors working under a cooperating partner are not considered “participants” as it pertains to grants and agreement instruments.
Q6. Will there be a phase-in period for cooperators who currently do not have their employees, volunteers or participants trained and certified?
A: Yes, as stated in the Federal Register Notice, there will be a transition period for partners, volunteers and cooperators. The compliance date of July23, 2017is the date when a cooperating partner’s employees, volunteers and participants who use saws on National Forest Systems lands and who are not currently trained and certified in accordance with the new policy, must be in compliance with the new policy. During the Transition Period from the date of the policy’s publication until the compliance date, cooperating partners subject to this policy may continue operations in accordance with their current agreements.
Q7. Are contractors exempt from this policy?
A. Yes, contractors with paid employees are exempt from this policy as they are required to abide by OSHA regulations in 29 CFR 1910.266.
Q8. Is the saw policy applicable to a cooperators’ contractors?
A. No, a contractor of a partnering organization is not subject to the agency compliance requirements for saw use. This includes contractors working under a cooperator through a stewardship agreement. As noted above, contractors are required to abide by OSHA regulations in 29 CFR 1910.266.
Q9. Are brush saws covered in this policy?
A. No, bow saws, pruning saws, brush saws, and pole saws are not covered in this policy unless they are used for felling trees as defined in FSM 2358.05-Definitions. These tools do require appropriate training (FSH 6709.11, ch. 41).
Q10. When will the new policy take effect and is my saw certification card still valid?
A. The policy is in effect the date of publication in the federal register. Saw certification cards will remain valid until their date of expiration.
Q11. How long will my saw certification card be valid under the new policy?
A. Under the new Saw Policy certifications are valid for three years from date of issuance. This standard 3 year re-evaluation ensures that sawyers are evaluated consistently throughout the nation. It is intended to function similarly to a driver’s license and is valid on all National Forest System (NFS) lands.
Q12. Is first aid and CPR required for all sawyers?
A. Yes, except for crosscut saw trainees who are operating under the supervision of another sawyer.
Q13. What is the minimum age for sawyers?
A. Chain saw sawyers must be at least 18 years of age (29 CFR Part 570, Subpart E). Crosscut sawyers must be at least 16 years of age. The agency recognizes the opportunity to foster a new generation of trail stewards and crosscut saw use is essential to trail maintenance. The final policy is consistent with Department of Labor policy pertaining to youth and crosscut saw use.
Q14. Will other federal land agencies adopt similar policies?
A. The Forest Service is one of the few land managers that require training, evaluation and certification of sawyers. Interagency coordination is ongoing and the problem is recognized. A key function of the national saw program manager will be collaborating with other agencies on policy and training needs.
Q15. How are cooperator training programs approved?
A. All new and existing cooperator programs will require review to determine if they comply with the new directive. The process for review has been established in the Forest Service Saw Operations Guide (FSSOG) which will be issued at the same time as the directive.
- How Partners, Cooperators, or Volunteers submit training programs for consideration as Nationally Recognized Sawyer Training Courses (NRSTCs):
- Volunteers operating under Forest Service volunteer agreements (OF-301a) will follow the same requirements as agency employees (this includes challenge cost share agreements where Forest Service volunteer agreements are being used in tandem).
- Volunteer partner organizations that operate under Forest Service volunteer agreements may also submit training, evaluation and certification programs for consideration as NRSTCs.
- For cooperators and partners, including cooperators and partners who use their own participants and their own volunteers, revise, align or review existing cooperative agreement(s) to meet standards in FSM 2358.03 (3).
- For cooperators and partners, including cooperators and partners who use their own participants and volunteers, develop a training package and/or certification standards to meet the standards identified in FSM 2358.
- Develop a table listing the authorities and any delegations necessary similar to FSM 2358.04 Exhibit 01. These authorities must align with language found in the FSM 1580 agreement (FSM 1509.11 sec. 91.2).
- Describe the responsibility of each position within the organization’s saw program similar to FSM 2358.04a-2358.04m.
- All Partners, Cooperators, or Volunteer organizations who receive approval for new training courses/programs will be required to use the National Sawyer Certification Database when it becomes available.
- Definitions for critical terms must be developed if they differ from those found in FSM 2358.05.
- Follow or develop similar qualification standards identified in FSM 2358.06, 2358.1 Exhibit 02 and 2358.3 Exhibit 06.
- Follow or develop similar responsibilities and limitations, training, knowledge and skills to meet each skill level identified in FSM 2358.1.
- Follow or develop similar sawyer training and field proficiency evaluation standards identified in FSM 2358.2.
- Follow or develop similar revocation procedure identified in FSM 2358.22.
- Follow or develop similar program monitoring and evaluation procedures identified in FSM 2358.3.
- Follow or develop similar sawyer evaluation forms identified in FSM 23358.3 Exhibit 03 and 04.
- Develop an incident and accident tracking and notification system.
- Volunteers operating under Forest Service volunteer agreements (OF-301a) will follow the same requirements as agency employees (this includes challenge cost share agreements where Forest Service volunteer agreements are being used in tandem).
- How the Technical Advisory Group (TAG) reviews submitted NRSTCs
- The National Saw Program Manager is the main contact for partners’, cooperators ‘and volunteer organizations’ submission of NRSTCs for review by the TAG.
- The TAG will select a subcommittee to review each submittal and make recommendations to the National Saw Program Manager.
- The National Saw Program Manager is the responsible authority who will approve each NRSTC that meets the qualifications in FSM 2358.
- Cooperators who have training programs in place will receive priority review over new requests.
Q16. Can a volunteer c-evaluator be delegated and authorized to sign Forest Service certifications?
A. When a volunteer or cooperator is certified as a Forest Service c-level evaluator and they are implementing the Forest Service’s program; they can recommend for certification, but are not delegated the authority to sign certifications. Only a delegated Agency official can certify sawyers. However, when a volunteer group or cooperating partner implements a saw training, evaluation and certification program that meets Forest Service requirements and is approved by the Forest Service, the volunteer group or cooperating partner certifies participants that go through their program. In partner created programs, there is no “transfer of delegation” by the Agency; instead there is a parallel authority since they are meeting the requirements and responsibilities associated with Agency’s policy.
Q17. Why have Diameter at Breast Height (DBH) restrictions been removed?
A. DBH restrictions were not an adequate way to judge how much risk sawyers would encounter. Larger trees may not be more risky or more complex. Many recent accidents that involve sawyers striking others or being struck themselves are occurring with smaller diameter trees. Protocol to establish key indicators of complexity is currently under development and will be released in a later edition of the FSSOG.
Q18. Is it possible to be certified Bucking only?
A. Yes, sawyers may be certified as B or C Sawyers (Bucking Only).
Q19. Why is a National Database for Sawyers needed?
A. This database will provide a central, accessible repository for sawyer information including name, address and skill level of the sawyer. The development of the database has been delayed to ensure direct access by cooperators but is expected to be available within the next 12 months. Once developed, the system will allow the Forest Service and cooperators to verify that employees, volunteers, training consultants, and cooperators intending to operate saws on NFS lands have been evaluated and certified to meet one or more of the six skill levels.
Q20: How will sawyer certification cards be issued until the National Database is functional?
A. National Sawyer Certification Cards will be issued under processes already in use with the exception that the required, new, national credential form, FS-2300-53, must be used instead of previous editions. The new credential form is available to Agency Sawyer Evaluators through their Regional Saw Program Managers. Evaluators will use the new credential form and follow the issuance process listed on the National Saw Program Technical Advisory Group’s SharePoint site. Once the National Sawyer Database is available the use of the interim form and issuance process will be prohibited. Sawyers issued credentials during this interim period will not be required to be issued a credential from the National Sawyer Database until their interim credential expires.
Cooperators with approved programs (see Q14) will continue to manage evaluation records, credential records and credentials (sawyer certification cards) per their previous process until such time the database becomes available. Cooperators who are seeking to establish approved programs will coordinate with their Regional Volunteer & Service contacts to determine the next steps, which will include coordination with the Regional Saw Program Manager. Cooperators who neither have, nor wish to have, their own approved programs will continue to coordinate with their local or Regional Volunteer & Service Coordinator.
Q21. Does this policy affect use of chain saws and cross cut saws in wilderness?
A. All cross cut (non-motorized) saw use in wilderness is directly tied to the Wilderness Act which prohibits motorized use in wilderness (Sec. 4c) and only allows administrative use of motorized (chain saw) if it is determined to be the minimum tool necessary for the administration of the area as wilderness.
Q22. Is the Forest Service going to establish a new position to oversee implementation of the National Saw Policy?
A. Yes. Pete Duncan has been selected as the Forest Service National Saw Program Manager.
Q23. For those Forests that have been certifying BLM employees, how are they going to be affected?
A. The changes in Forest Service policy should not affect BLM employees. BLM employees that are that are trained and evaluated by Forest Service employees will receive a recommendation based on that evaluation that they can submit to their supervisor.
Q24. How will this policy affect current and future agreements with various groups and or outside entities utilizing saws on federal lands? What language needs to be included in these agreements?
A. Agreements with cooperators will require new boilerplate language are available on the National Saw Program Technical Advisory Group’s SharePoint site. Cooperators have until July 19, 2017 to comply with the new directive. New agreements and modifications to existing agreements with volunteers and cooperators will be required to also contain the new boilerplate and will be subject to compliance July 19, 2017 as well.
Q25. What if FS employees who have been carded for years and performing saw related activities can’t produce documentation of past training in a NRSTC? Do they have to retake and meet initial training hour requirements/hours?
A. No. We are accepting sawyers currently credentialed (carded). When their credential expires they will be expected to meet the requirements of the new policy. Evidence indicating past training by an NRSTC is not required but is to the sawyer’s best benefit if a saw related accident were to occur. Sawyer evaluation is the last opportunity for a determination of whether a sawyer has all the knowledge and skills to meet the standards in policy. Emphasis on evaluating the basic knowledge that is taught in the NRSTCs must be made by evaluators to determine if the student can be qualified. If during this evaluation it becomes apparent that the student lacks basic knowledge the evaluation should be terminated and the student referred to a NRSTC for remedial instruction. Evaluators should document this process on the appropriate sawyer evaluation form FSM2358.3 Exhibit 04 or 05. Course hours listed in FSM 2358.1 exhibit 02 are for planning purposes and are based on the experience of seasoned sawyer trainers and evaluators.
Q26. Does the National Policy supplant all other policies?
A. Yes, all regional FSH supplements pertaining to chain saw or crosscut saw use are now void. No previous national policy or regional supplements to the FSM exist. Regions are responsible for managing these supplements and eliminating them from their directives system as the WO ORMS does not provide that service. Additionally, national guidance in FSH6709.11 chap. 22.48 was also revised when FSM 2358 was released which will supplant previous guidance in the ubiquitous “Green Book.”
Q27. Will we still be able to have regional or forest policies that are more restrictive than the National Policy?
A. Although permissible by the directives system it is not preferred or advised. The goal of FSM 2358 is to unify the saw program nationally and eliminate different policies that caused confusion and lack of consistency in practices on the ground which were becoming safety issues and lack of consistency regarding cooperating partner and volunteer training, evaluation and certification. A great deal of work and compromise was undertaken throughout the last 4 years this policy was developed. If regional or forest supplemental policies are being considered they must be brought to the Saw Program TAG for discussion to determine impact on the program as a whole.
Q28. Can we certify electric chain saw under the new policy?
A. Yes. Electric chain saws are considered chain saws and therefore their use must comply with this policy.
Q29. What exactly do we need from our volunteer and cooperating partners to prove they are in compliance with national policy?
A: Volunteer and cooperator sawyers must meet the standards in FSM 2358.1 Exhibit 02, evaluated successfully and be issued the credential in FSM 2358.3 Exhibit 6. In order to comply with these standards their sawyers can be trained, evaluated and certified by the Forest Service under the same standards. Alternately, cooperators can train, evaluate and certify their own sawyers if they have met the standards in FSM 2358.1 Exhibit 02, and have followed the approval process in section 1.6 of the FSSOG. Cooperator evaluators must be approved by the Regional Saw Program Manager as identified in FSM2358.04g while meeting the standards in FSM 2358.1 Exhibit 02.
Per agreement clauses, it is up to the cooperating partner to ensure that its employees, participants and volunteers are in compliance with any required Forest Service policies. The Forest Service does not need to see or require written documentation or copies of saw certifications, as that is the responsibility of the cooperating partner to ensure. When the national database is operational, names of individuals who have been certified will be required to be entered into the database at that time.
Volunteers operating under a Forest Service volunteer agreement (Form OF-301a) must be currently certified to operate saws on National Forest System Lands. Local volunteer agreement administrators or Agency contacts can request validation of certification if needed, and/or check names in the National Database when it is operational. When the national database is operational, names of those individuals who have been certified will be required to be entered into the database.
Q30. Will there be fillable templates for field evaluations created? Current templates are print only.
A. Current evaluation forms are PDF format and agency computers with Adobe Acrobat DC can be used to fill the form in before leaving the office.
Q31. Will there be a fillable saw certification card template that allows Saw Coordinators to fill out more than one card at a time?
A. Yes, it is available on the Saw TAG SharePoint site.
Q32. Will there be official templates created for Regional Saw Program Managers to recommend/ approve professional training consultants, volunteer cooperator saw instructors and evaluators?
A. Yes, a work aid has been developed and is available on the Saw TAG SharePoint site to assist Regional Program Managers with cooperator developed program review. This aid was developed to provide consistency of submittals and streamline the review process. Final recommendations for approval of cooperator programs should be official and trackable and it is advised that the Mercury Correspondence Database be used for this task. Regional Saw Program managers should retain copies of all correspondence for recommended/approved non-Forest Service instructors, evaluators and certifiers, for a minimum of three years.
Q33. Why was the National Policy released during the peak of field season FY16?
A. Although regulatory timing associated with the change of the presidential administration played a major role in timing of the release, the biggest delay was caused by consultation with DOL on the minimum age of crosscut sawyers.
Q34. Were there PPE requirements and recommended features for crosscut saws prior to the National Policy/FSH updates?
A. Yes, All PPE requirements were described in the FSH 6709.11 chap. 22.48h (1) Crosscut Saws.
Q35. How do we guarantee Forest Supervisors/local management will provide cutting areas and/or opportunities to maintain proficiency? What is line officer responsibility for providing cutting areas?
A. Forest Supervisors and District Rangers (if delegated) have the authority and responsibility of providing cutting areas to meet training requirements and maintain sawyer proficiency (FSM 2358.04e (4)). If cutting areas are not provided sawyers can’t be trained and no saw program will exist.
Q36. What are the issues surrounding liability of Forest Service sawyers removing danger trees at Forest Service developed sites under concession?
A. Concessionaire permits require concessionaires and/or permit holders to identify and remove dangerous conditions and hazards, including danger trees. The responsibility is that of the concessionaire, not the Forest Service. If Agency employees are removing danger trees from developed sites that are operated by the Forest Service, they should be currently certified. As long as the Agency employee is operating within the scope of their certification and the scope of their duties, liability is the same as it is when conducting saw operations in other Forest Service sites.
Q37. How do employees get a copy of the FSM? Most simply have copies at the districts of the FSH.
Q38. Define the prohibited practice of “Domino Falling”?
A. "Domino felling” is the partial cutting of multiple trees which are left standing and then pushed over with a pusher tree (29CFR1910.266). This does not represent the complex practice of notching and felling more than one tree with intertwined limbs.
Q39. To assure standardization across the nation and that important issues are being addressed will annual training materials be offered to assist Regional Saw Program Managers during annual training events?
A. Great idea! The mission of the TAG is to support the needs of the saw program and provide a consistent approach to management of the program. Development of training topics or materials can be very beneficial to meeting this goal.
Q40. Will there be a one page instruction sheet we could give to partnership groups outlining what they need to do to develop their own training and certification program within the guidelines of our new policy.
A. Requirements exist on page 6 and 7 of the FSSOG however the development of a more user friendly “How To” is a good idea.
Q41. Does this policy apply to concessionaires and other special use permittees?
A. No. They, and the contractors they hire to conduct saw operations, are required to follow OSHA regulations in 29 CFR 1910.266.