April 2015 Q&A
Q: We are a 100-year-old municipality and we have discovered some wood tools and a baker board in a long-overlooked storage area. The tools are rotted and termite-damaged, but the situation raised a question: Is it permitted to use wood hot sticks?
A: We did some checking with manufacturers and most agree that wood tools were first replaced by fiberglass-reinforced plastic (FRP) in the 1950s when utilities started transmission voltages over 240 kV. The first published FRP manufacturing standard was for fiberglass tools in the 1960s. We don’t currently know of any consensus standards for wood tools, but the 2009 version of IEEE 516 states that some wood may still be in use. Additionally, OSHA still has a voltage withstand test for wood tools, so we assume that means that it is not prohibited to use wood tools that meet the standard for both electrical and physical integrity.
As to practical industry application, we are aware that there has been some discussion on the IEEE 516 committee to remove references to wood hot-line tool use. In the course of regulatory reaction, OSHA would likely follow IEEE and remove the references as well. Finally, we asked industry experts who agreed that there is little reason to continue the use of wood insulating tools. This is especially the case considering hot-stick technology improvements like lowered weights of tools, improved strength and insulating integrity over wood. Still, we learned that wood hot sticks and platforms are still in use outside the U.S., so this may not be a universal opinion.
On a personal note, I haven’t seen any wood live-line tools in the field since I found two folding shotguns in the crew cab of my line truck in 1978. They were donated to the International Lineman Museum and Hall of Fame in Shelby, N.C., a few years ago.
Q: Overhead lines are free-swinging and configured close together with different types of insulation. Are the cover-up requirements in substations the same as those for overhead lines? What are other utilities doing for cover and minimum approach distances in substations?
A: We don’t have any data, but our colleagues tell us that more and more utilities are starting to use cover-up in substations and are using manufacturer-formed hard and rubber covers in stations. Many are also using heat-malleable hard covers or forming barriers from insulating sheets that you can cut, heat form and use to install hangers for custom barriers. As to your question about minimum approach distances, MAD is MAD, even in substations.
Q: Are lineworkers or substation workers required to wear steel-toe shoes or shoes with an electrical hazard rating?
A: In the recent years of carbon fiber technology, “steel toe” has now become “protective toe” or “hard toe” in some standards because toe caps are not always made of steel. Foot protection, like all PPE, is prescribed by the employer based on exposure and history. There are some standards – like the arc protection rules – that have criteria for foot protection, but most interpretations side with NFPA 70E and simply require leather. The PPE rules require the employer to complete a risk assessment. If the risk assessment and injury history identify a risk and history of toe-crushing exposures, protective-toe foot protection is required. There are employers who just assume that protective-toe shoes are required and make it a rule. There is nothing wrong with that. The new language for foot protection in OSHA 29 CFR 1910.136(a) requires the employer to ensure that each affected employee uses protective footwear when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole. Because of this language, some employers are assuming that hard-toe foot protection is now required, but that is not necessarily the case.
As to electrical hazard (EH) ratings, they were required for electrical workers at one time, but EH-rated shoes are no longer mandatory under federal standards. However, some states may still require them, so check carefully if you fall under a state plan. The issue with EH-rated shoes or boots is the possibility of contamination that can compromise the integrity of the electrically resistant layers in the soles. Unlike gloves, sleeves and blankets that are periodically tested to ensure their integrity, EH-rated boots and shoes cannot be reliably tested. EH-rated boots, like overshoes, are considered part of a system of protection, playing a backup role or secondary level of protection while a tested barrier provides the primary level of protection.
Q: This may not be a safety issue, but are contractors exempt from U.S Department of Transportation hours-of-service rules like utility workers are?
A: Actually, it is a safety issue since the point of hours-of-service rules is to keep fatigued drivers out from behind the wheel of a 20-ton battering ram. The reasoning behind the utility exemption is that electricity is of great importance to the health, safety and security of the public. Some enforcement agencies use that basis to decide if the contractor working for a utility is exempt from the hours-of-service rules.
If you look closely at the wording of the standards, you will see that the word “emergency” is a key part of the rule. As such, many jurisdictions interpret the rule this way: If the work you are driving to or from has no immediate risk to the health, safety and security of the ultimate consumer of the utility’s service, no exemption will be granted. This is often the issue for contractors who mobilize across states for larger projects or who are returning from storm work. Sometime lineworkers forget that when they are behind the wheel of a digger derrick for a 1,200-mile trip, they become truck drivers. Contractors make longer trips than most utility crews and get pulled over regularly for roadside inspections and cross scales. We know from feedback that states treat the utility exemption differently in each jurisdiction.
Obviously, we do want to remain aware that the hours-of-service rule has reduced the number of accidents and is about protecting drivers and the public. Awareness and applying the established drive/rest guidelines are worth consideration. During the last hurricane restorations on the East Coast, we heard several stories in which state patrols stopped convoys and had drivers get out of their vehicles and walk around to assess their fitness to drive. One contractor driving through New Mexico received seven hours-of-service violations for drivers who left New York two days earlier and had no logs to show who had been driving and how long they had been driving.
Ultimately, the best place to get a reliable answer about hours-of-service requirements is from your state Department of Transportation enforcement office. If they will write you a determination that says you are exempt, you are golden.
Q: We are a power-line contractor working in a MSHA mine site in Virginia. During the first day on the job, mine safety personnel said that we were required to use fall protection to climb into buckets. How do we do that?
A: Mine power lines and truck shops are often not under MSHA regulations, but that can be different in every mine. We are not aware of a specific MSHA rule that addresses trucks, but like OSHA, MSHA does have fall protection requirements. MSHA is very performance oriented and parts 56 and 57 of 30 CFR – which contain MSHA fall protection requirements – are not very specific. Most mines start at 4 or 6 feet depending on the applicable standard. Mines and MSHA often refer to OSHA standards for guidance. The OSHA fall protection standards of Subpart M require employees to be protected from falls on any walking or working surface, vertical or horizontal. However, the definition of a walking/working surface in OSHA 29 CFR 1926.500(b)(2) specifically exempts vehicles or trailers on which employees must be located in order to perform their job duties. This exception is practical as there is no viable means to accomplish fall protection in these work locations.
As a compliance issue, OSHA does have a reasonable exception for workers moving across trucks or equipment to get to the operator’s station or perform maintenance. Any type of arrest system would still allow workers to strike lower levels like truck beds, toolboxes or turrets. To help protect workers on equipment, the ANSI standard requires handholds, footholds and improved walking routes/surfaces to reduce fall potential, and OSHA as well as MSHA require that those devices be maintained. These are similarly covered in the crane and derrick standard, specifically 1926.1423(c). The bottom line is that fall protection is not required, pathways to operator stations should be grip-coated, and handholds and footholds should be reasonably located and maintained.
Do you have a question regarding best practices, work procedures or other utility safety-related topics? If so, please send your inquiries directly to kate@incident-prevention.com. Questions submitted are reviewed and answered by the iP editorial advisory board and other subject matter experts.