When allowed to be immersed in their desired craft, our workers become proficient, experienced and competent. Adept lineworkers, for example, will interact with thousands of poles and pieces of hardware in their careers. They have a deep understanding of strain, depth, condition and loading after only moments of viewing a pole they are about to work on. But does the industry recognize and treat our workers like they are the experts? This article is not meant to tell you what you should do, but I am going to provide information for you to discuss, interpret and decide how to implement. If the words in this article cause you to pause, reflect and then act on a potential change in strategy, I am interested in hearing what you learn from your experience. You may agree or disagree with what I write about in these pages, but the most important reaction is to question the material and engage in discussions about it. Earning a Ph.D. in Line Work On average, it takes about 8.5 years to earn a Ph.D. in the U.S. With that amount of learning and experience, a level of mastery of the subject matter is achieved. Bestselling author Malcolm Gladwell has stated that it takes 10,000 hours to achieve a mastery level in anything. Neuroscience has proven that mastery actually changes the structure and chemical composition of the brain to allow for faster decision-making with less cognitive load and more subconscious processing. Considering the time element to change the structure of our brains, I submit that any worker who is a continuous learner, and who has more than 10,000 hours in their trade, has unofficially earned a Ph.D. in what they do. Again, though, this only applies if you are continuing to learn, always. How can we test that theory? How do you know if your brain has changed over time? If anyone reading this has opened a print drafted by someone with a master’s degree in design engineering, there is a phrase often heard almost immediately upon viewing the print: Why are we doing it this way? This question occurs because upon seeing the print, there seems to be a better, more efficient design in the crew leader’s mind. While the crew leader looking at the print may not be privy to the property issues, available materials or other aspects of design because the first time they see the print is when the job is released, the designer, with their degree in design engineering, does not have a Ph.D. in doing the crew’s work. When mastery of anything is achieved, we subconsciously “see” things others don’t. An emergency room doctor profiles people unconsciously while having dinner in a restaurant. He may, for example, point out someone to his wife who looks like they are in liver failure. Obviously, the doctor is not at the restaurant to profile patrons for illnesses. It happens subconsciously until a connection is made and delivered to his consciousness. It’s the same for a lineman who goes on vacation and notices a blown fuse on a pole he is passing. Once a level of mastery is reached, the lineman subconsciously patrols lines wherever he goes. Daniel Coyle, author of “The Talent Code,” has stated that talent “is grown, not learned.” Essentially, talent is myelin, which is the insulation that thickens on the nerve fibers that we use repeatedly. In acting as insulation, myelin allows for a faster electrical signal to be sent to the much-used nerve fiber group, resulting in faster discernment with less effort. Some Common Conversations Imagine a workforce of skilled, competent employees, all at different stages of their career. Some are new apprentices while others are somewhere between new and having a lifetime of experience in the industry. Do we treat our workers like they have the answers and know their work? Sometimes. Having been a lineman, I can tell you that other times, I have been expected to get the work done regardless of my experience. The following conversations I have had may sound similar to those you have had: Underground Me: I need an extra man to run in that three-phase underground today. An apprentice will work. Boss: Why? Me: Because I need one person to watch the reel, one to put the wire in the ditch and one to drive. Boss: Can you do it without the apprentice? Overhead Me: This No. 6 copper primary is in really rough shape. I could use an outage for this in case it falls down. Boss: Can’t get an outage, figure it out. Design Me: Looking at this print, if we converted the six sections of three-phase before the riser pole, we wouldn’t have to put a ratio bank and the three-phase riser on the same pole. Boss: Just build it the way it’s designed. Materials Me: I don’t think we can build this design; we are short on materials. Boss: Failure is not an option. We have to complete this project. The industry continues to pressure employees to get the work done. Skilled workers are consistently questioned and denied their requests or asked to explain the obvious. Imagine if you did that to your young children. How would that affect their confidence? If we consistently deny that our workers have knowledge and experience, a condition called “learned helplessness” begins to occur. We learn that no matter what we say or ask, we can’t change things, so we give up and just get the work done. Then, when an incident occurs, sometimes you will hear, “What were you thinking?” Treating skilled workers like they know less than they do creates problems with crew dynamics. It also becomes more difficult for crew members to speak up. And why speak up if nobody is listening? I bring this to your attention as an observation. But let’s also consider this question: What effect does learned helplessness have on our ability to mitigate risk? Listening for Red Flags “I think,” “should be OK,” “probably” and “might be fine” all mean that we don’t know. If you say or hear these words, stop and take a moment to evaluate the situation. Because of our workers’ competence levels, ideas are constantly surfacing and being considered. When we doubt ourselves or our ability to act on ideas, we begin to accept the status quo. But the reality is that we as a species have survived 75,000 years with about the same brain we currently possess. We can determine from this that our species has enough abilities to have avoided extinction thus far. Our workers know more than we give them credit for, but almost none of them realize that they have a Ph.D. level of expertise. When we realize we know more, we also realize that we already have answers to some of the questions we ask ourselves during the course of our work. For instance, before a lineman climbs a wood pole that’s in rough shape, he assesses it. If it looks questionable, he then does a sound test, hitting the pole with a 2-pound hammer. If it sounds OK, he then digs 12 inches under the ground to drive a screwdriver into the pole. The reality is that this test is subjective, and the only reason the pole is being sound-tested is because the lineman has already determined the pole is in poor condition. He’s used his experience to evaluate and judge the pole. So, perhaps the best decision is to tie three ropes to the pole on the way up so that the lineman fails safely if the pole has a structural failure. And that’s the whole safety strategy – to listen for red flags, both in conversations with others and with ourselves, consider them and then act on them. Here are some other examples: Q: Do you think I need more rubber hose? A: Yes, because you wouldn’t have asked otherwise.   Q: Do you think that wire will hold? The splice felt funny when I put in the wire. A: No, you have doubt or you wouldn’t have asked the question.   Q: Do you think the pole hole is deep enough? A: No, it must be marginal or else you wouldn’t have asked.   Q: The tangent pole is going up 8 feet. Do you think the tie wire on the next corner pole will hold? A: No, I don’t think so – because you asked. Set up and secure that corner pole. When we respect ourselves for what we know – and when others respect us for what we know – we begin to realize that the reason a thought or idea appeared in our consciousness is because something put it there. Some connection was made behind the veil of our consciousness, and without invitation, the thought then arrived in our consciousness. If there is a consequence tied to that thought, deploy this as a simple strategy: Wait 10 seconds and consider the consequence of doing nothing. Since we consciously process 40 to 50 bits of information per second, that’s roughly 500 more bits of information in those 10 seconds. Increasing Workforce Competence Our industry has a lot of work coming down the pike. We are destined to have more workers with less cumulative experience. In my opinion, the industry has unwittingly eroded the confidence of our workforce, first by not acknowledging their level of expertise and second by continuing to try to find system fixes where – again, in my opinion – greater competency is needed. For example, if someone cuts their hand, we put everyone in cut-resistant gloves. If someone slips, we require everyone to wear anti-slip footwear. If a worker cuts out while climbing a pole, everyone is mandated to use a pole-choke device. These are all good safety efforts, but none of them makes the worker more competent. To increase competence in the workforce, we must determine how we can help our employees get better at their work. One important way is to consistently encourage workers to take the time they need to consider why certain thoughts occurred to them; that time spent may prevent an incident from occurring. Ten seconds is enough to change your mind, share your thoughts with your crewmates and potentially save a life. Further, encourage your co-workers to act on their inconvenient thoughts that pop up in the middle of a critical move and make it safe for them to speak up. As humans, we are excellent at driving a bad plan all the way through to failure. Let’s learn to interrupt that plan if it’s needed and take a minute to change outcomes. Conclusion Everyone reading this article is aware of fatalities in the industry. Every single one of us has been involved in a near-miss and has been lucky. Let’s remove luck as a strategy to stay safe. It’s time to recognize just how talented and smart you are at your trade. Listen to yourself and each other, and speak up when there are potentially serious consequences to an action or a lack of action. Agree to fail safely so we can all go home healthy every day. About the Author: Bill Martin, CUSP, NRP, RN, DIMM, currently works in safety and training for Northline Utilities LLC and Northeast Live Line. He has held previous roles as a lineman, line supervisor and safety director.

Task-based and daily wear PPE programs help protect a company’s workers and improve resilience. Alexander Pope famously wrote that “to err is human,” yet as safety professionals, we often feel that we can prevent incidents if we eliminate all risk. It’s a concept that has permeated nearly every facet of the safety sphere: account for the risks, eliminate their presence and prevent injuries. Even still, incidents and injuries do happen, sometimes with catastrophic consequences. This has brought about a shift in the safety mindset, moving toward a more resilient outlook.

Progress over the last decade has made the industry a safer place for line-clearance workers. When I started working for an investor-owned utility in 1974, I was fresh out of high school and had little knowledge of safe work practices and policies. I was truly fortunate to collaborate with people at the utility who cared about my safety and made sure I developed safe work habits that I still espouse today.

Here’s what owners and operators should know about upcoming updates to the standard. 

Updates are coming to the ANSI A92.2 standard, titled “American National Standard for Vehicle-Mounted Elevating and Rotating Aerial Devices.” Your most common piece of powered equipment soon will have new or revised requirements for design, manufacturing, testing, training and operation. These new requirements go into effect in August of this year. First, let’s cover some of the most notable changes, and then we’ll look at some often misunderstood training requirements.

On October 27, 2021, OSHA published in the Federal Register an advance notice of proposed rulemaking for heat injury and illness prevention in outdoor and indoor work settings. This followed OSHA implementing an enforcement initiative on heat-related hazards and the development of a National Emphasis Program on heat inspections in September. At the same time, the agency formed a Heat Injury and Illness Prevention Work Group of the National Advisory Committee on Occupational Safety and Health to start collecting information in preparation for the rulemaking.  Past Not many hazards found in the workplace share the same historical prevalence as heat stress. In fact, one could surmise that workers getting sick or injured while working in the heat dates to the beginning of human history, except maybe during the Ice Age. One might also think this problem would be figured out by now, so why is it still an issue in the workplace? Some point to climate change, that exposure to heat is more widespread than in the past and temperatures climb higher and for longer durations. Another potential reason is that exposure to environmental heat is seen as a fact of life, a hazard presented by Mother Nature herself in most cases. Many readers can recall a time when they had to work in the heat and possibly a time when the heat was too much to manage. Images of overstressed workers gathering under a tree trying to cool off are easy to conjure up. In fact, heat stress has been managed this way for a very long time – and still is in many places. Traditional controls tend to focus on the worker’s ability to manage their own health while working in high heat. This is usually supported with reminders from the employer to be careful, take breaks and drink plenty of water. Great advice, but it’s not much of a strategy, especially when considering that by the time a worker perceives the threat, it may already be too late. Traditionally, OSHA has chosen to address the hazard through education and the General Duty Clause, which obligates all employers to provide a work environment “free from recognized hazards that are causing or are likely to cause death or serious physical harm.” There are also 28 states that have their own safety and health programs, typically referred to as “state plans.” Four of these state plans have developed regulations that specifically target heat illness and injury prevention. California began developing a regulation in 2005; Washington did so in 2008, followed by a more protective emergency standard in 2021; Minnesota did so in 2014; and Oregon was the most recent state to develop a regulation, in 2021. Beyond these regulations, many organizations have conducted research on the topic and developed, or are working to develop, recommended standards for OSHA to adopt. Most notably, the National Institute for Occupational Safety and Health has been working on a recommended standard since 1972. There have been some revisions to their recommended standard since then, and it’s safe to say that NIOSH is eager for their research to find its way into the proposed OSHA regulation. In addition, the American Society of Safety Professionals has been working on BSR/ASSP A10.50 as part of their ANSI/ASSP A10 Construction & Demolition Standards. For some, a federal regulation is long overdue, and with the rulemaking process underway, things are definitely heating up.

The topic of step and touch potentials is controversial, which is precisely why we need to discuss it. In my role as a work methods auditor and consultant, I see more variations in how employers address step potential than in any other aspect of equipotential bonding. I know the reasons for this and will address them here. But first, I need to clearly state the following:

• The theoretical argument for hazardous step potential in electric utility work environments clearly exists.
• Every employer must assess the hazards of step potential in their work environments and adopt a plan to protect exposed workers.
• Every employer must train their employees to recognize step potential hazards and employ the procedures necessary to protect workers from step potential hazards.

Anyone who has read my past articles knows I approach each topic from the aspect of OSHA requirements, the consensus standards, best practices, and many years of research, training and experience. I have written about step potential before, most recently regarding horizontal boring operators being compelled to wear dielectric overshoes by manufacturer operator manuals. I received a lot of feedback from that article, some of it accusing me of ignoring the risks. That is not the case and will not be the case here. I know very well that step potential is possible. As a matter of record, my first incident forensics case was for the family of an 8-year-old boy who was fatally injured by step potential created by an improperly installed underground community baseball-field lighting system. Yes, I know when and how step potential becomes deadly. As an employer or a worker, you must have the information necessary to perform a proper and effective analysis of the hazards associated with your work. An improper understanding can lead to a lack of preparation. On the other hand, a lack of information can also lead to overreactions that can include risks inherent to the work methods that are not necessary. Yes, if you don’t understand the nature of the risks and can’t decide which expert is right, all you have to do is equip everyone with dielectric boots and rubber gloves and you will prevent step and touch exposures. And yes, that is impracticable for a host of reasons, so read on and we will solve this the practicable way: through research. What Does OSHA Have to Say? First, let’s look at OSHA. As I understand it, OSHA has always respected the hazard of step and touch potentials occurring around energized equipment. And at least since 2014, OSHA literature and guidance have specifically included utility towers and ground rods as sources of step and touch hazards. The rules include the famous catchall, 29 CFR 1910.269(p)(4)(iii)(C). It’s a huge rule, so I will not repeat it here in its entirety. The rule generally requires that if the methods used to protect workers do not ensure protection, you must satisfy four specific requirements. Requirement three is the use of equipotential mats. Requirement four is to use insulating protective equipment or barricades to guard against any remaining hazardous potential differences. Equipotential mats are self-explanatory. Insulating protective equipment could be rubber or cover, but since the phrase includes “guard against any remaining,” the assumption is that the rule is referring to personal protective equipment such as protective footwear and rubber gloves. Throughout OSHA’s litany of PPE guides, the understanding is that employers use procedures, engineering barriers or guards to protect employees, with PPE being the last layer of protection. For that reason, we take rule 1910.269(p)(4)(iii)(C)(4) to include foot and hand protection through PPE, such as dielectric or insulating footwear and rubber gloves. In addition, a reading of Appendix C, “Protection From Hazardous Differences in Electric Potential,” finds references to use of PPE and distance as a means of protecting employees from step and touch potentials. We can also take advantage of some OSHA guidance included in 1910.333, “Selection and use of work practices.” Some readers will say that this section does not apply; however, they are wrong. I have defended utility employers against this section, and the section was ruled as applicable because of the very precise wording of this note: “The work practices used by qualified persons installing insulating devices on overhead power transmission or distribution lines are covered by 1910.269 of this Part, not by 1910.332 through 1910.335 of this Part. Under paragraph (c)(2) of this section, unqualified persons are prohibited from performing this type of work.” Did you notice the precise wording of the phrase “installing insulating devices”? Utility operators of trucks are covered by this section, but that is good because of section 1910.333(c)(3)(iii)(C), which states, “If any vehicle or mechanical equipment capable of having parts of its structure elevated near energized overhead lines is intentionally grounded, employees working on the ground near the point of grounding may not stand at the grounding location whenever there is a possibility of overhead line contact. Additional precautions, such as the use of barricades or insulation, shall be taken to protect employees from hazardous ground potentials, depending on earth resistivity and fault currents, which can develop within the first few feet or more outward from the grounding point.” Here is a valuable reference for the employer in OSHA, noting that hazards develop “within the first few feet or more” from the source. This statement is not found in 1910.269. To comply with the OSHA standards, we must clearly interpret a somewhat confusing paragraph in Appendix C. Let me warn you from experience: I have had to defend employers against this paragraph before the Occupational Safety and Health Review Commission, an independent agency created by the U.S. Congress to adjudicate contested OSHA citations at the federal level. Paragraph (III)(D)(2) to Appendix C, “Acceptable methods of grounding for employers that do not perform an engineering determination,” is written in very precise legal terms designed to be easily interpreted in the event that an employer contests an OSHA violation based on Appendix C guidance. Of value to employers is that this paragraph clearly explains the primary rule requiring equipotential grounding in the workplace – if you can figure it out. The paragraph explains that rule 1910.269(n)(3), “Equipotential zone,” was written to satisfy two principles: tripping the circuit, and to ensure that potentials in the work area are as low as possible (bonding). However, the paragraph also explains that 1910.269(n)(3) does not specifically require that the employer’s grounding methods “meet the criteria embodied in these principles” (tripping and bonding). In its specific wording, 1910.269(n)(3) requires that the protective grounds be “placed at such locations and arranged in such a manner that the employer can demonstrate will prevent each employee from being exposed to hazardous differences in electric potential.” In essence, this guidance from OSHA says the intent of the rule is tripping the circuit and bonding the worker, but the requirement of the rule is demonstration that the intent is satisfied. Then we get to the real hook. In every appendix throughout the OSHA standards, there is text stating that the appendix does not create mandatory requirements for the employer, explaining that the procedures in the appendix can assist the employer in meeting the requirements of the standard. In some cases, such as in Appendix C, we read that the “Occupational Safety and Health Administration will consider employers that comply with the criteria in this appendix [Appendix C] as meeting § 1910.269(n)(3).” That means the employer must perform an engineering analysis of risks and protection methods if they don’t follow OSHA’s procedures generalized in Appendix C. My first question is, who did the engineering analysis for the work methods called out by OSHA in Appendix C? The answer is, not OSHA. OSHA is relying on the research of others to compel employers to follow OSHA procedures or do their own engineering analysis. The methods in the appendix are based on the electrical physics of charge, transfer and current flow, as well as accepted theory. OSHA knows these steps will work and is using the threat of citation over an engineering study as leverage to get employers to take seriously the risk of step and touch potentials. And we should do that. The reality is that many employers don’t take any precautions to protect workers from step and touch potentials, and that is what the appendix is trying to change. By the way, OSHA does not specify what the engineering determination consists of nor does the agency require any calculations or protocols to be used to meet the requirement of a determination. If the employer turns the task over to a qualified engineer, the assessment may only need to be an assessment of system protection compared to work methods, PPE and barricades. It’s up to the engineer to decide. The bottom line is that OSHA expects the employer to either perform an engineering analysis of the employer’s grounding methods to ensure the worker is protected, or you can simply follow the guidance in Appendix C. So now, let’s look at the issues. Touch Potential The first one – touch potential – is very easy. Solution one is, if touching the equipment will get you electrocuted, don’t touch the equipment. Yes, it’s that simple. There are two conditions to consider. One is direct contact with the equipment with an energized bus. That could mean the boom contacts the bus or the bus falls on the boom. If either of those things occur, anyone in contact with the equipment who is standing on the ground or who is not at equipotential would be at risk. The other is a grounded truck. If a truck is grounded to a system neutral or a pole bond that is connected to a system neutral, the truck is a parallel path to ground through any worker standing on the ground touching the truck. In either case, not touching the truck mitigates the risk. Of course, this is only part of the problem and doesn’t solve step potential risks. I’m sure some readers are now wondering about grounding the truck for tripping the circuit. Well, here is the deal: Tripping the circuit removes any continuing threat of electrical hazard to workers. This may sound like a joke, but it’s truly a response to the OSHA issue. If an ungrounded truck does not trip the circuit quickly or does not trip the circuit at all, and if no worker is put at risk by that condition, would OSHA cite that employer? The answer is no. OSHA does not care if you burn the truck to the ground as long as no one is at risk. So, whether the truck is grounded or not, if touch potential is the issue, there is no risk to the worker if they are not in contact with the truck. Again, this only solves the touch potential issue, not the hazard of step potential. Step Potential Gradients, or step potential, are a little more difficult. First, let’s clarify that the risk is not the level of voltage in the ground; it’s the level of voltage between the worker’s feet that creates the hazard. The voltage between your feet is created by the voltage drop that occurs across the resistance of the earth between your feet. The circuit voltage into the earth may come from a 13.8-kV circuit or a 345-kV circuit. The earth will substantially reduce that voltage, but it’s still the voltage drop at your feet that creates risk. The question we should be asking is, how hazardous is step potential? Earlier, we discussed issues created by grounding trucks associated with touch potential. The fact remains that if you don’t get the boom in the bus or drop wire on it, nobody is at risk, so why ground it? But if you can’t assure a truck will not become energized, there is no doubt that effectively grounding a truck will lower step potential by limiting voltage and current leaving the truck into the earth. Effective grounding collapses voltage and divides current between the low-resistance ground path and the path through the high-resistance earth. The theoretical basis is clear that gradients will occur. The employer must decide both where they will occur and how dangerous they may become. Not every space around a truck, structure or ground rod will be at the same level of risk. A means of protection includes defining the spaces that are risky and keeping those areas barricaded. I want to mention here that a barricade is a line of cones or maybe even barricade tape. A barrier is a physical separation, such as a construction fence. When we train our workers to respect the invisible barricade, defined by a frame of cones, and when we remind workers during the tailboard how to respect that invisible barricade, we meet the requirement of barricading a prohibited space. Now, back to the question: How hazardous is step potential? That question brings us to current flow versus potential in the analysis of the step potential hazard. Voltage absent current is not a deadly hazard. That is partly why the industry has mixed feelings regarding step potential. I find that we talk about it, but in the field, most workers don’t worry about it. You would have a hard time finding a lineworker who knows of someone who was killed by step potential in a utility workplace. For that reason, few workers are concerned that step potential might be a threat. What about the research? Any aware reader would see that in research on step potential, current is not an aspect of the data but an assumption of testing. I would be interested in speaking with any researcher who has measured current flow across the ground from an electrode. Every test published can measure current through the electrode from the source, but I have yet to see any tabulated data that measures current 10 feet away from the electrode. That is pretty easy to explain, and it also explains why the consensus standards have considered step potential a negligible risk up until the most recent revisions. Step potential is a theoretical concept that can be measured with the right instruments. Current flow is also a theoretical concept that has not been demonstrated in testing with surface-bearing electrodes. Herein lies the problem. We control or equalize potential because if a worker is not exposed to a potential that can penetrate their body insulation, current cannot flow and the worker cannot be injured. Even if there is a highly unlikely possibility of current flow across the soil, a potential that can penetrate the worker’s skin would allow current, if it were present, to penetrate the worker and cause a fatal injury. For the most part, current flow is also a theoretical concept that can’t be demonstrated in testing with surface-bearing electrodes. Since voltage without current represents a negligible risk, very little attention has been paid to it. Here is the difference between voltage and current and dirt as a conductor. Voltage is developed across the earth simply by electrical transfer of the charge between conductive elements in the soil. Current must have a path to earth to flow horizontally across the soil. That is almost impossible without an extremely high voltage to push it, and that voltage is hard to develop in a grounded circuit. Current cannot flow where there is no conductive path to ground. However, as noted in IEEE 80, “IEEE Guide for Safety in AC Substation Grounding,” if there were a high-resistance layer beneath a lower-resistance layer of conductive soil, and if the soil were conductive enough to support current flow, and if the current flow were a path across the insulating layer into a path to ground, then current could flow with the voltage. For this reason, we cannot assume there is no current risk. Now, what do we do about it? Potential Solutions For decades with contractors, we have been constructing equipotential grids during stringing, pulling and splicing operations. We have also been using them around the bases of structures. You will find these site-constructed grids mentioned in both Appendix C to 1910.269 and in the IEEE consensus standards. The grids are typically constructed using 16-foot-by-50-inch cattle panels made of #4 welded galvanized wire or concrete-reinforcing panels made of uncoated, welded #4 wire. Today there are commercially available grid sections that can be assembled to create the same effect. These eliminate step potential around any equipment staged over them. Where a grid is not used, the most recent study I have read – and found great value in – is the Electric Power Research Institute’s “Vehicle Grounding and Personal Utility Distribution Guide Technical Report 2019.” This is a copyright-protected document and the property of the utilities that sponsored the research. For those reasons, I cannot reproduce its tables or citations. I can share with you that many of the findings support what we are discussing here. Anyone can purchase a copy of the report from EPRI (www.epri.com) at the sponsor’s fee. What I found most valuable is the measuring of actual step potential voltages, not just the voltage measured in the ground. There is also a valuable section on the efficacy of insulating, dielectric and electrical hazard-rated boots. Further, there are recommendations for protective actions based on the research. In the summary of the EPRI findings, as I have been recommending for years, there is not one solution but a system of steps used together that help to ensure worker protection against step and touch potentials. In summary, to meet the requirements of 1910.269(n)(3), the requirements of 1910.269(p)(4)(iii)(C) and the guidance of Appendix C:

• An engineering determination must be made to quantify the hazards of step potential and mitigation strategies for the workforce.
• Those who don’t use an engineering analysis must use a combination of methods as described in Appendix C.
• Training for the workforce must be delivered regarding the hazards determined and the strategies to be employed to protect the worker.

Regarding the second bullet above, based on all the discussion in this article, here are some recommendations for combinations of work procedures that can limit risk to workers as part of a system of protection. For all system voltages:

• Observers for aerial booms to prevent contact.
• Good and effective cover to prevent contact.
• Work plans that eliminate trips to the truck.
• Position vehicles out from under conductors when practical.
• Consider not grounding to limit voltages being coupled onto vehicles through the neutral (if no workers are endangered as specified in 1910.269(p)(4)(iii)(C)).
• Ground vehicles that are an electrocution hazard to the best available ground.

Where vehicles are grounded to the system or subject to induction-coupled magnetic current:

• Prohibit contact with vehicles that are grounded to the system.
• Bond conductive-boom man baskets to the grounded bus to protect workers aloft.
• Establish barricades for non-entry spaces around equipment.
• Maintain distances from equipment away from hazardous gradients.
• Employ dielectric, insulating or electrical hazard-rated boots where hazardous gradients cannot be eliminated.
• Use equipotential mats with insulating approaches where touch potential or gradients are a risk.
• Lay a bonded grid to create a plane of equipotential around all trucks, structures and ground rods.
• In the absence of any combination of work methods, use dielectric overshoes and rubber gloves rated for the system voltage or expected voltage differences.

Conclusion Whatever your motivation – whether it’s just to check a box or to seriously protect workers – don’t wait until it’s too late to take the steps. Have a defensible, compliant plan in place. About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn, CUSP, has devoted the last 24 years to safety and training. A noted author, trainer and lecturer, he is a senior consultant for the Institute for Safety in Powerline Construction. He can be reached at jim@ispconline.com. Paragraph (III)(D)(2) of Appendix C to OSHA 29 CFR 1910.269 “The grounding methods presented in this section of this appendix ensure that differences in electric potential are as low as possible and, therefore, meet § 1910.269(n)(3) without an engineering determination of the potential differences. These methods follow two principles: (i) The grounding method must ensure that the circuit opens in the fastest available clearing time, and (ii) the grounding method must ensure that the potential differences between conductive objects in the employee’s work area are as low as possible.   “Paragraph (n)(3) of § 1910.269 does not require grounding methods to meet the criteria embodied in these principles. Instead, the paragraph requires that protective grounds be ‘placed at such locations and arranged in such a manner that the employer can demonstrate will prevent exposure of each employee to hazardous differences in electric potential.’ However, when the employer’s grounding practices do not follow these two principles, the employer will need to perform an engineering analysis to make the demonstration required by § 1910.269(n)(3).”

Q: Why are communications systems bonded to a utility system neutral? Doesn’t that make the communications messenger a parallel neutral path? A: Yes, it does, but this is a case of “Which is worse?” There are a number of things we do for one purpose that create hazards for another. We must know the issues and choose what we will do. Down guys are one example. In transmission and distribution, many utilities install insulators in the upper section of a down guy to isolate it from the electrical environment at the top of the pole. The purpose is to protect the public from the potential of a hot guy. Then the engineer calls for a bond connection below the insulator to ground the guy, further ensuring the guy cannot become energized, again to protect the public. But the protection of the public endangers the lineworker. The bonding of the down guy connects the guy to the neutral or the transmission static that is bonded to the pole bond. Current follows every available path, so current from the neutral divides down the guy into the earth through the anchor. It’s the same for the static. It has induction from the parallel transmission conductors flowing to earth through the pole bond.

Protection from Flames and Electric Arcs It is important to remember that all arc hazards are not equal. By Pam Tompkins, CUSP, CSP, and Matt Edmonds, CUSP, CIT, CHST According to OSHA, electric power generation, transmission and distribution workers face a significant risk of injury from burns due to electric arcs. Studies have concluded that a large percentage of arc-related incidents resulted in either a fatality or in extremely painful third-degree burns, which require skin grafts and leave permanent scarring. Based on these conclusions, OSHA adopted standards to address forms of personal protective equipment other than clothing. These standards – titled “Protection from flames and electric arcs” and found at 29 CFR 1910.269(l)(8) and 1926.960(g) – require employers to assess the workplace for hazards associated with flames and electric arcs and to provide PPE to employees who will have exposure. Since these standards require PPE, the employer is obligated to purchase and ensure appropriate maintenance of that PPE. Utilizing the hierarchy of controls is necessary to eliminate or effectively control hazards. Since that’s the case, why would OSHA design a standard that specifically addresses PPE, the last line of control? OSHA addresses this concern in the preamble to the final rule by stating that “the final rule protects employees in case an electric arc occurs in spite of other provisions in the final rule designed to prevent them from happening in the first place.” Plainly speaking, OSHA designed the entire electric power standard for the prevention of flames and electric arcs, so the PPE portion of the standard is designed to be the last line of control in case all else fails.  Standard Requirements Five important requirements are found within this standard. These can be met by using Appendix E to both 1910.269 and 1926 Subpart V, “Protection From Flames and Electric Arcs.” The requirements are as follows:

1. Assess the workplace for hazards from flames or electric arcs.
2. Estimate the incident energy when there is exposure.
3. Prohibit specific clothing when incident energy could ignite that clothing.
4. Require flame-resistant clothing under certain conditions.
5. Select clothing with an arc rating greater than the estimated incident energy.

 Hazard Assessment OSHA requires employers to assess the workplace to identify employees who have exposure to hazards from flames and electric arcs. A hazard assessment includes identifying potential sources along with the completion of a risk assessment to determine the probability and severity of the potential exposure. Appendix E to 1910.269 and 1926 Subpart V identifies sources of electric arcs as unguarded, uninsulated live parts; switches that arc in normal operation; sliding parts subject to faults; and electric equipment subject to failure. Sources of flames include open flames and ignitable material near flames or arcs. It is important to remember that the employer is responsible for determining sources, so this should not be considered an exhaustive list. Appendix E also identifies the probability of an occurrence to include whether conductive objects can fall on live parts; whether an employee is inside the minimum approach distance; whether operation of electric equipment is part of a normal operation or occurs during servicing; and whether there is evidence of impending failure. It is important for employers to use a developed process to appropriately determine potential sources and assign risk. Without an effective hazard identification process, employers may place focus on the use of PPE instead of hazard mitigation.  Estimated Incident Energy It is important to remember that all arc hazards are not equal. Therefore, electric power organizations can’t just address arc hazards the same way as the neighboring utility does. OSHA requires employers to estimate the potential amount of incident energy available at work locations. Incident energy is a measure of thermal energy at a working distance from an arc fault. The unit of measurement for incident energy is known as cal/cm². Working distance is an extremely important component of incident energy levels because the levels decrease as an employee moves away from the arc source. OSHA does not require employers to estimate incident energy exposure for every job task. Broad estimates that cover multiple system areas can be used to provide reasonable assumptions. Table 3 of Appendix E outlines the appropriate engineering methodology utilized to determine incident energy levels. This table provides employers with the engineering methodology for various types of arc hazard exposures, including single-phase open air, three-phase open air and three-phase in an enclosure. It is important to verify appropriate calculation methods to provide appropriate incident energy values for the work to be performed. Remember that an electric power system is constantly changing and updating, so it is important to regularly review engineering analyses to ensure incident energy levels are accurate for the work to be performed. Additionally, host employers are required to furnish incident energy levels and/or required PPE to affected contractors as a part of information transfer requirements.  PPE Requirements Where arc hazards exist, workers are prohibited from wearing clothing made from acetate, nylon, polyester, rayon or polypropylene, either alone or in blends. Garments to be used must have an effective arc rating. OSHA requires the outer layer of clothing to be flame-resistant when an employee is exposed to contact with energized circuit parts greater than 600 volts when an electric arc could ignite flammable material in the work area, and when molten metal or electric arcs from faulted conductors could ignite clothing. Additionally, employers are required to provide arc-rated PPE when employee exposures exceed 2 cal/cm². The expectation is that PPE with an arc rating equal to the estimated incident energy will be capable of preventing a second-degree burn injury to an employee exposed to the incident energy from an electric arc. OSHA requires that arc-rated protection cover the employee’s entire body, with limited exceptions for the employee’s hands, feet, face and head. Appendix E identifies those exceptions in an easily accessible format. It is especially important to ensure employees do not wear undergarments made from prohibited clothing even when the outer layer is flame-resistant or arc-rated. The undergarments can melt or easily ignite when an arc occurs. Logos and tags made from non-FR material can also adversely affect the arc rating or FR characteristics.  Conclusion Always remember that all arc hazards are not equal. Electric power organizations have a responsibility to provide an effective hazard control process as well as the appropriate FR and arc-rated PPE. The industry has become more proactive by developing new design and engineering controls to reduce arc hazards. In addition, arc-rated PPE has greatly improved over the years, making it easier to wear correctly. About the Authors: Pam Tompkins, CUSP, CSP, is president and CEO of SET Solutions LLC. She is a 40-year veteran of the electric utility industry, a founding member of the Utility Safety & Ops Leadership Network and past chair of the USOLN executive board. Tompkins worked in the utility industry for over 20 years and has provided electric power safety consulting for the last 20-plus years. An OSHA-authorized instructor, she has supported utilities, contractors and other organizations operating electric power systems in designing and maintaining safety improvement methods and strategies for organizational excellence.  Matt Edmonds, CUSP, CIT, CHST, is vice president of SET Solutions LLC. A published author with over 15 years of safety management experience, he also is an OSHA-authorized instructor for general industry and construction standards. Edmonds provides specialty safety management services for electric power organizations throughout the U.S. He has been instrumental in the development of training courses designed for electric power organizations, including OSHA 10- and 30-hour courses and SET Solutions’ popular OSHA Electric Power Standards Simplified series. About OSHA Electric Power Standards – Simplified: Topics in this series are derived from SET Solutions’ popular OSHA electric power course offered through the Incident Prevention Institute (https://ip-institute.com). The course is designed to help learners identify standard requirements and to offer practical ways to apply the standards.