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OSHA 1910.265 and WAC 296-78 Safety for Sawmill Conveyors and Decks

A sawmill's conveyors, chains, live rolls, log hauls, and log decks are governed federally by 29 CFR 1910.265 and in Washington by chapter 296-78 WAC, and the two rule books differ in wording, in conditions, and in how much they leave to an old conveyor standard. UTEC Industrial designs, engineers, machines, fabricates, and installs custom material handling systems for aerospace and heavy industry from its Spokane Valley, WA facility, integrating Allen-Bradley PLC and motion control with in-house CNC machining, heat treating, and stress relief. This article states the conveyor and deck rules of both books with their conditions and exceptions, sets the two side by side where they differ, reads three recent OSHA accident records against them, and shows where the rules land in the controls. The rules become hardware and logic at every link of the build chain, design → engineering → parts machining → fabrication → assembly → weld fatigue → stress relief → drives → controls → tuning → monitoring, and a trough sized for a broken chain or a stop reachable from the conveyor is fixed at the design stage.

Which rules govern sawmill conveyors and decks, and where does each apply?​

The two rule books are written with different scopes:

  • Federal. 29 CFR 1910.265(a) includes safety requirements for sawmill operations "including, but not limited to," log and lumber handling, sawing, trimming, and planing; waste disposal; operation of dry kilns; finishing; shipping; storage; yard and yard equipment; and power tools and affiliated equipment used in connection with such operations, but excluding the manufacture of plywood, cooperage, and veneer.
  • Washington. Under WAC 296-78-500(1), the chapter applies to all installations where the primary manufacturing of wood building products takes place, whether a permanent fixed establishment or a portable operation. Its listed operations include, but are not limited to, log and lumber handling, sawing, trimming and planing, plywood or veneer manufacturing, canting operations, waste or residual handling, dry kilns, finishing, shipping, storage, and yard equipment. Under -500(2), the chapter augments Washington's general safety and health standards, and in any conflict with a general-application standard, chapter 296-78 WAC applies. Under -500(3), in exceptional cases where compliance with specific provisions can only be accomplished to the serious detriment and disadvantage of an operation, the director of labor and industries may permit a variance after receiving an application that meets chapter 296-900 WAC.

The lumber-mill industry article compares the two scopes for plywood and veneer plants, and the unscrambler and lug loader article covers Oregon's own sawmill rules at OAR 437-002-0313. Oregon adopts 1910.265 by reference under OAR 437-002-0300(5), but its rule text notes that the federal (a), which excludes plywood, cooperage, and veneer manufacturing, was not adopted, and OAR 437-002-0313(1) allows sections (c) and (d) of 1910.265 to be applied to those industries. This article stays with the conveyor and deck rules (OSHA 29 CFR 1910.265-2016: Sawmills, §1910.265 paragraph a; Washington L&I WAC 296-78-2026, §296-78-500; OAR 437-002 Subdivision R, AO 6-2017).

What does 1910.265 itself require for conveyors, and what does it leave to B20.1-1957?​

The federal conveyor paragraph, 1910.265(c)(18), has two sentences:

  1. Construction, operation, and maintenance of conveyors shall be in accordance with American National Standard B20.1-1957, which is incorporated by reference.
  2. Spiked live rolls shall be guarded.

Within that paragraph, everything beyond spiked live rolls is left to the 1957 standard. ASME's current conveyor safety standard is B20.1-2024, whose publisher page says it applies to the design, construction, installation, maintenance, inspection, and operation of conveyors and conveying systems in relation to hazards, for bulk material, package, or unit handling types, whether the installation is permanent, temporary, or portable, and that it specifically excludes any conveyor designed for, installed for, or used primarily for the movement of human beings. A specification should say which edition it means.

Other federal paragraphs reach conveyors and transfers without being about them:

  • Marking and stops. Under (c)(31)(iii), pickup and unloading points and paths for lumber packages on conveyors and transfers, and other areas where accurate spotting is required, shall be plainly marked, with wheel stops provided where necessary.
  • Elevated walks. Under (c)(4)(iv), elevated walks, runways, or platforms 4 ft or more from the floor level need a standard railing, except on the loading or unloading sides of platforms, and a standard toe board as well where the height exceeds 6 ft.

OSHA's Sawmills eTool describes the conveyor hazard as limbs caught in unguarded shafts, shaft ends, spiked live rolls, or nip points (OSHA 29 CFR 1910.265-2016: Sawmills, §1910.265 paragraphs c.4, c.18, and c.31; ASME B20.1-2024; OSHA eTool: Sawmills, Conveyors).

What does WAC 296-78-84003 add for conveyor troughs, return strands, and crossings?​

Washington also incorporates B20.1-1957, under WAC 296-78-84003(1), and then writes its own conveyor rules. The sawmill material-flow article summarizes three of them; here each is given with its full conditions:

  • (2) Working strands. Conveyor troughs in which the working strands operate must be of ample dimension and strength to carry a broken chain and must afford effective protection to all employees.
  • (3) Low return strands. When the return strand operates within 7 ft of the floor, a trough must be provided of sufficient strength to carry the weight resulting from a broken chain.
  • (4) Return strands overhead. When return strands pass over passageways or work areas, guards must be placed under them that will effectively protect workers.
  • (5) Crossings. When the working strand crosses within 3 ft of the floor level in passageways, the trough must be bridged the full width of the passageway.
  • (6) Burning refuse. Where a conveyor, idler pulleys, or other equipment is over or dangerously near burning refuse, any worker going there must use a safety line securely fastened to the body and tended by a helper.
  • (7) Panic stop. Conveyors must be provided with an emergency panic-type stopping device that can be reached by a person in a sitting position on the conveyor, located near the material entrance to each barker, chipper, hog, saw, or similar equipment. The exception is a conveyor under constant control of an operator who has full view of the material entrance and is located or restrained where he or she cannot possibly fall onto the conveyor. The device must stop the conveyor a sufficient distance away from the hazard to prevent injury or further injury by the hazard.
  • (8) Screw conveyors. Screw or auger conveyor troughs and boxes must have covers, or other equivalent guards where covering is not practical.

In engineering terms, (2) and (3) make the weight of a broken chain a design load for the trough steel, its supports, and its connections, and (7) makes the conveyor's stopping distance a design quantity, tied to its speed and deceleration (Washington L&I WAC 296-78-2026, §296-78-84003).

What do Washington's rules require at sorting chains, green chains, live rolls, and ramps?​

WAC 296-78-84001 carries the green-end rules. The material-flow article covers the roll-case gradient limit, the sorting-chain stop, and end collisions, and the unscrambler article covers debris cleaning; the rest, with their conditions, are:

  • Green chains and sorting tables. (13) The inside of the walkway of all green chains and sorting tables must have a standard toeboard; Oregon's OAR 437-002-0313(5)(b) requires a toeboard not less than 6 in high, of nominal 2 by 6 in material, on the vertical face of all green chain and sorting tables. (14) Rollers or other devices must be provided for removing heavy dimension lumber from the cabin or table. (16) In all permanent installations, green chains and sorting tables must be roofed over against inclement weather, and normal work stations must have a drained, evenly floored, nonslip work surface.
  • Live rolls. (18) The space between live rolls must be filled in on either side of crosswalks with material strong enough to withstand the imposed load with a four-to-one safety factor. (19) The driving mechanism of live rolls must be guarded wherever exposed to contact. (20) Live rolls must be replaced when their surface develops a break or hole. (21) Spiked live rolls must be guarded, as in the federal (c)(18)(ii).
  • Ramps and skidways. (22) Ramps or skidways that transfer lumber from one level to another need all safeguards necessary to protect workers. (23) A lower landing where lumber is discharged over them needs a solid bumper not less than 6 in high at the outer edge. (24) The person putting lumber down must have a clear view of the lower landing, and lumber may not be put down until all workers are in the clear. (25) The under face of every landing must be fenced off, or other positive means provided, to keep people from walking out under dropping timber. (26) Return strands of sorting table ramp chains must be supported by troughs strong enough to support the weight of a broken chain.

The federal (c)(18)(ii) carries the same spiked-live-roll rule as (21) (Washington L&I WAC 296-78-2026, §296-78-84001; OAR 437-002 Subdivision R, AO 6-2017, OAR 437-002-0313 paragraph 5; OSHA 29 CFR 1910.265-2016: Sawmills, §1910.265 paragraph c.18).

Where must walkways and crossovers be provided over conveyors and roll cases?​

Washington's footwalk rule, WAC 296-78-71007, is specific about moving equipment:

  • (2) Over moving parts. Walkways meeting WAC 296-78-71001(7) must be provided over roll casings, transfer tables, conveyors, or other moving parts, except when stepping over such equipment is not in connection with usual and necessary traffic.
  • (3) Sorting tables. Walkways alongside sorting tables must be wide enough to provide a safe working area, evenly floored, kept in good repair at all times, and free from obstructions and debris.
  • (4) Plug-ups. When employees are required to clear plug-ups in veneer trays or lumber sorting trays, adequate walkways with standard guardrails must be provided for access whenever possible; where they are not, safety belts or harnesses with lanyards tied off to substantial anchorages must be provided and used at all times.
  • (5) Oilers. Walkways and stairways with standard handrails must be provided, wherever space will permit, for oilers and other employees whose duties take them consistently to elevated and hazardous locations.

The structures themselves carry a load rule. Under WAC 296-78-71001(2), buildings, docks, tramways, walkways, log dumps, and other structures must be designed, constructed, and maintained for a safety factor of four, meaning all members must support four times the maximum load to be imposed; the provision refers to structures designed and built after the standards took effect, and in all cases to complete or major changes or repairs. The federal counterpart, 1910.265(c)(1), requires a safety factor without giving a number, and Oregon's crossover rule is in the unscrambler article (Washington L&I WAC 296-78-2026, §296-78-71001 and §296-78-71007; OSHA 29 CFR 1910.265-2016: Sawmills, §1910.265 paragraph c.1).

How do the federal and Washington log haul rules differ?​

The material-flow article gives Washington's four-to-one bull-chain factor, the return-strand trough, the positive stop, and the control direction rule. Set side by side, the two books differ in their conditions:

Item29 CFR 1910.265(d)(2)(vi)WAC 296-78-56503
Bull chain or cableDesigned, installed, and maintained to provide adequate safety for the work need, (b)Four-to-one safety factor for the intended load, (3)(a)
Return-strand troughsSubstantial troughs over passageways, (d)Troughs over passageways, (3)(b)
Gear and driveLog haul gear and bull chain drive mechanism guarded, (c)Adequately guarded for the protection of employees, (3)
Control positionOperator at all times in the clear of logs, machinery, lines, and rigging, (e)Same, (4)
Control directionOnly where control is by lever exposed to incoming logs: operate only when moved toward the log slip or the log pond, (e)All such controls: operate the mechanism only when moved toward the log slip or deck, (4)
StopsA positive stop on all log hauls, (f)An automatic stop where possible, and a positive stop in all cases, (5)
WalkwaysStandard handrail on the outer edge, with cleats or other means for footing, (a)At least one walkway with standard railing on every log haul used as a walkway, cleats on sloping walkways, (1)

Both books require overhead protection for employees working below logs being moved to the log deck, and Washington adds under -56503(2) that workers must not stand under or dangerously near logs being hoisted vertically to the deck. As engineering reasoning, a haul designed to Washington's numbers still has to be checked against the federal wording, and the reverse; the direction rules, for example, name the deck in one book and the log pond in the other (OSHA 29 CFR 1910.265-2016: Sawmills, §1910.265 paragraph d.2; Washington L&I WAC 296-78-2026, §296-78-56503).

What must a log deck have to keep logs from rolling onto the carriage or onto people?​

The deck rules in both books address the same failure, an uncontrolled log, in slightly different words:

  • Stops. 1910.265(d)(3)(ii) requires adequate stops, chains, or other safeguards to prevent logs from rolling down the deck onto the carriage or its runway; WAC 296-78-56507(5) requires effective means to prevent logs from accidentally rolling down the deck onto the carriage or its runway.
  • Overhead chains. Under (d)(3)(iv), loose chains from overhead canting devices or other equipment shall not hang over the log deck in such manner as to strike employees; WAC -56507(7) says in such manner as to endanger workers.
  • Moving parts. WAC -56507(9) requires moving parts or equipment on or about log decks to be guarded. The federal (d)(3) paragraph has no general guarding item of its own.
  • Working below logs. WAC -56507(11) forbids workers to go below logs on decks that are likely to roll or be rolled, and requires means of access to the head rig that do not subject employees to the hazard of moving logs or equipment; the federal (d)(3)(i) requires safe access to the head rig.
  • Log wells. WAC -56507(3) requires log wells to be safeguarded to prevent logs from rolling back into the well off the deck; the federal (d)(2)(vi)(h) asks for safeguards that minimize the possibility.

The material-flow article covers the sawyer's barricade, jump skids, and canting-gear lever direction. In engineering terms, a powered deck stop or loader, hydraulic or chain-driven, is also an energy source for lockout, and the note to WAC 296-78-71503 lists hydraulic energy and gravity among those sources (OSHA 29 CFR 1910.265-2016: Sawmills, §1910.265 paragraphs d.2 and d.3; Washington L&I WAC 296-78-2026, §296-78-56507 and §296-78-71503).

Does 1910.265's chain-discard rule apply to conveyor and transfer chain?​

Not by its own terms. 29 CFR 1910.265(c)(24)(ix) sits under "Ropes, cables, slings, and chains", among rules for rigging, wire rope, and fiber rope, and its first item names chains used in load carrying service:

  • (a) chains used in load-carrying service shall be inspected before initial use and weekly thereafter;
  • (b) chain shall be normalized or annealed periodically as recommended by the manufacturer;
  • (c) if at any time any 3 ft length of chain is found to have stretched one-third the length of a link, it shall be discarded;
  • (d) and (e) forbid shortening, joining, or splicing chain with bolts or nails between links.

The paragraph does not mention conveyor, transfer, or sorting chain, and the lumber-mill industry article presents it as a rule for load-carrying chain. For conveyor chain, the rules that apply are the conveyor rules: B20.1-1957 through 1910.265(c)(18)(i) or WAC 296-78-84003(1), Washington's troughs for broken working and return strands, and WAC 296-78-71505(7), which requires baffles where necessary to protect employees from breaking belts, chains, ropes, or cables. A maintenance plan that borrows the one-third-link discard figure for a conveyor chain is borrowing it from a paragraph whose first item names load-carrying service; as engineering practice, the chain maker's wear and replacement guidance is the basis for conveyor chain (OSHA 29 CFR 1910.265-2016: Sawmills, §1910.265 paragraphs c.18 and c.24; Washington L&I WAC 296-78-2026, §296-78-71505 and §296-78-84003).

What do three recent OSHA accident records show about sawmill chain conveyors?​

The unscrambler article covers a 1998 Washington trim-line fatality and a 2023 unscrambler drive-chain death. Three more OSHA accident summaries from sawmills involve chain conveyors directly. They are cited by record title and number, and their keywords are OSHA index terms, not findings:

  • Restart with a worker on the conveyor (No. 127637.015, July 2020). An employee placing sticks on lumber stacks built by a stacker machine stayed behind when the machine was stopped for rain. After the others left, he climbed down under an unscrambler through an opening by the electrical disconnect panel and sat on a chain conveyor. A returning worker restarted the machine, and the conveyor pulled him against the back of the machine; he died of multiple fractures.
  • Chain and tail spool (No. 123199.015, January 2020). An employee working in the chipper location of a sawmill near a vibrating chain conveyor line caught his leg between the chain and the tail spool of the conveyor, and the injury caused an amputation of his right leg and required hospitalization.
  • Part of the line left running (No. 157679.015, June–July 2023). A 16-year-old employee working alone was removing dried boards from the end of a chain conveyor in a planer building. The system included a stick stacker, a stick conveyor that carried kiln sticks removed by a tilt hoist and dropped them into carts, and photosensors that advanced the carts. He turned off the tilt hoist conveyor lines, but the stick conveyor was not turned off; he went to address an issue on it and was caught between the machine frame and the top of a cart, and died of crushing injuries.

Read against the rules, the first case is a restart while a person was on the conveyor, the second is a tail-end nip point, and the third is a line in which stopping one section left another running (OSHA Accident Summary No. 127637.015; OSHA Accident Summary No. 123199.015; OSHA Accident Summary No. 157679.015).

Why is stopping one conveyor not the same as isolating it?​

The Washington rules separate a stop from an isolation:

  • Standstill. WAC 296-78-71501(10) requires all power-driven machinery to be stopped and brought to a complete standstill before any repairs or adjustments are made or pieces of material or refuse removed, except where motion is necessary to make adjustments.
  • Lockout. WAC 296-78-71503 requires the lockout/tagout rules of chapter 296-803 WAC to be followed while performing service and maintenance on machines or equipment, including piping systems, where employees could be injured by the unexpected energization or startup of the machine or equipment, or the release of stored energy. Its note lists energy sources as mechanical, hydraulic, pneumatic, chemical, thermal, or other energy, including gravity.
  • Federal. 29 CFR 1910.147(a)(1)(i) covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could cause injury to employees. The unscrambler article sets out when servicing during normal production is covered, the isolation requirement, and who may remove a lock.

The 2023 stick-conveyor record is the plain case. Turning off the tilt hoist conveyor lines did not stop the stick conveyor, and the employee went to that conveyor while it was still turned on. In engineering terms, a conveyor line with several drives needs its isolation points drawn and labeled per section, and a stop command that covers only part of a line has to be visible as such to the person who gives it (Washington L&I WAC 296-78-2026, §296-78-71501 and §296-78-71503; OSHA 29 CFR 1910.147-1989, §1910.147 paragraph a.1; OSHA Accident Summary No. 157679.015).

What sensing, PLC logic, and interlocks carry these rules into the controls?​

Several of the rules are control requirements in plain words, and the rest imply one:

  • Panic stops. WAC 296-78-84003(7) sets the reach (from a sitting position on the conveyor), the location (near the material entrance to each barker, chipper, hog, saw, or similar machine), and the performance (stop a sufficient distance from the hazard). As engineering practice, meeting the performance clause means measuring the conveyor's stopping distance at full speed and load at commissioning, not assuming it.
  • Sorting-chain stops. WAC 296-78-84001(12) requires a stopping device readily accessible at all times to at least one employee working on the chain.
  • Start warnings and interlocks. WAC 296-78-71501(6) requires machinery or equipment started by a control so located as to create impaired vision of any part of it to have an audible warning device where it is exposed to contact at points not visible to the operator, and the device must be sounded before starting up unless positive mechanical or electrical interlocking controls prevent starting until all such posts are cleared (the rule's own word); the unscrambler article covers it with the feed-stop rule in -71501(7).
  • Restart after a stop. As engineering practice, the 2020 restart case argues for zone start permissives: a conveyor stopped by a panic stop, a gate, or a lockout should not restart from a remote station until the zone is confirmed clear, and presence sensing where people enter under a machine is one input to that permissive.
  • PLC logic. Logix 5000 controller tasks can be configured as continuous, periodic, or event, and a periodic task performs a function at a specific time interval.
  • Standards framework. ISO 13849-1:2023 specifies a methodology and provides related requirements, recommendations and guidance for the design and integration of safety-related parts of control systems that perform safety functions, for high demand and continuous modes of operation only. ISO 12100:2010 specifies principles of risk assessment and risk reduction to help designers achieve safety in the design of machinery. IEC 60204-1:2016 applies to electrical, electronic, and programmable electronic equipment and systems to machines not portable by hand while working, including a group of machines working together in a co-ordinated manner.

UTEC Industrial, a Rockwell Automation Recognized System Integrator, builds UL 508A control panels and integrates Allen-Bradley ControlLogix and CompactLogix control with VFD and servo drives into the handling systems it builds (Washington L&I WAC 296-78-2026, §296-78-71501, §296-78-84001, and §296-78-84003; OSHA Accident Summary No. 127637.015; Rockwell Automation 1756-RM094N-EN-P-2025, Ch. 5 pp. 39 and 41; ISO 13849-1:2023; ISO 12100:2010; IEC 60204-1:2016).

Where does the build chain put these rules into the machine, and what should the specification say?​

These rules become steel, welds, and wiring long before a mill inspector sees them:

  • Design and engineering turn the rules into load cases and layouts: trough strength for a broken chain under WAC 296-78-84003(2), (3), and 84001(26); live-roll fill at crosswalks for a four-to-one factor under -84001(18); walkways over moving equipment under -71007(2); and a four-to-one factor for new or majorly changed structures under -71001(2).
  • Fabrication, weld fatigue, and stress relief decide whether troughs, guards, and walkway frames keep carrying those loads under vibration and impact.
  • Drives, controls, tuning, and monitoring set the stopping distance behind -84003(7), the start warnings and interlocks behind -71501(6), and the logs that show whether stops still perform.

A specification that works in both jurisdictions should state:

  • the jurisdiction, 29 CFR 1910.265, chapter 296-78 WAC, or Oregon's rules, and which edition of B20.1 applies, 1957 as incorporated or 2024;
  • the broken-chain load each trough must carry, and where return strands pass over passageways or within 7 ft of the floor;
  • every panic-stop and sorting-chain-stop location, with the required stopping distance;
  • walkways, crossovers, railings, and toeboards;
  • isolation points by conveyor section, and how a restart is prevented while someone is inside.

UTEC Industrial performs factory acceptance testing and on-site commissioning, where stop locations, stopping distances, and interlocks can be demonstrated against the purchase order before production starts (Washington L&I WAC 296-78-2026, §296-78-71001, §296-78-71007, §296-78-71501, §296-78-84001, and §296-78-84003; OSHA 29 CFR 1910.265-2016: Sawmills; ASME B20.1-2024).

Related Articles

References​

  • OSHA 29 CFR 1910.265-2016: Sawmills. U.S. Department of Labor, 2016.
  • Washington L&I WAC 296-78-2026: Safety Standards for Sawmills and Woodworking Operations. Washington State Department of Labor and Industries, 2026.
  • OAR 437-002 Subdivision R (AO 6-2017): Special Industries. Oregon Occupational Safety and Health Division, 2017.
  • ASME B20.1-2024: Safety Standard for Conveyors and Related Equipment. ASME, 2024.
  • OSHA. eTool: Sawmills. U.S. Department of Labor, 2026 (undated web documentation, accessed September 2026).
  • OSHA. Employee Is Killed When Sawmill Chain Conveyor Starts Up, Accident Summary No. 127637.015. U.S. Department of Labor, 2026 (undated web documentation, accessed September 2026).
  • OSHA. Employee Amputates Leg When Caught In Chain Conveyor, Accident Summary No. 123199.015. U.S. Department of Labor, 2026 (undated web documentation, accessed September 2026).
  • OSHA. Employee Dies When Caught In Stick Conveyor, Accident Summary No. 157679.015. U.S. Department of Labor, 2026 (undated web documentation, accessed September 2026).
  • OSHA 29 CFR 1910.147-1989: The Control of Hazardous Energy (Lockout/Tagout). Occupational Safety and Health Administration, 1989.
  • Rockwell Automation 1756-RM094N-EN-P-2025: Logix 5000 Controllers Design Considerations. Rockwell Automation, 2025.
  • ISO 13849-1:2023: Safety of machinery — Safety-related parts of control systems — Part 1: General principles for design. International Organization for Standardization, 2023.
  • ISO 12100:2010: Safety of machinery — General principles for design — Risk assessment and risk reduction. ISO, 2010.
  • IEC 60204-1:2016 (Ed. 6.0): Safety of Machinery -- Electrical Equipment of Machines -- Part 1: General Requirements. International Electrotechnical Commission, 2016.

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