August-September 2019 Q&A
Q: What is considered a forklift? We use wheel loaders equipped with accessory forks on our rights-of-way to unload and move poles and pole sections. We were told by our client’s safety inspector that the loader operators have to be certified as forklift operators because the loaders are equipped with forks. We have always used loaders and loader operators and never had an issue. Where do I find the information to resolve this issue?
A: OSHA refers to forklifts as powered industrial trucks or PITs, while the industry commonly calls them forklifts. OSHA’s construction standard has a section on material-handling equipment. The very last rule is 1926.602(d), “Powered industrial truck operator training.” The rule consists of a single note that states, “The requirements applicable to construction work under this paragraph are identical to those set forth at §1910.178(l) of this chapter.”
I have had people tell me that this rule means that operators of construction equipment using forks, like a loader, are required to be licensed or certified as a PIT operator. That is not the case. The PIT standard that contains forklift operation and training rules is found in the general industry rules. The second sentence of paragraph 1910.178(a)(1) states the following: “This section does not apply to compressed air or nonflammable compressed gas-operated industrial trucks, nor to farm vehicles, nor to vehicles intended primarily for earth moving or over-the-road hauling.” Wheel loaders are designed to move earth. They are not PITs even if they are equipped with forks.
Q: I am reaching out for clarification on OSHA’s requirements for fall protection on horizontal work locations, specific to line work. My understanding is that work positioning is for vertical applications only, such as poles and tower legs. When a lineman needs to access a crossarm or tower arm, he will then be entering a horizontal work position and therefore needs a fall arrest system that is anchored to the pole or tower body. I thought all of this was addressed in the preamble to the final rule, but I am having trouble finding it. Can you please give me direction on how to locate this information within OSHA?
A: The section you are looking for begins at about page 20398 of the preamble to the final rule (see www.govinfo.gov/content/pkg/FR-2014-04-11/pdf/2013-29579.pdf). On horizontal surfaces, we are required to use either fall-arrest or travel/fall-restricting equipment. The problem with arms is that fall arrest cannot be rigged to limit the fall distance where you can’t anchor at shoulder level. Several utilities have done modeling on tower members and found those lattice towers with single-member knee braces to be problematic as fall-arrest attachment points. The challenge is to meet the expectation of the standard. I’ve seen various methods, like what has been called “first man up” or “first man out.” The first lineworker out on the arm takes a safety line through carabiners attached to the steel with short circle slings clipped. The first lineworker rigging the safety line uses short lanyards and alternately clips to the steel as they go. Workers can use the rope as a safety line or they can all slide out, clipping to the arm steel. If rigging a safety line, workers following use two short lanyards and clip to the safety line, alternating lanyards to cross the clips securing the safety line to the steel. The number of clips holding the safety line and the short lanyards limit the fall arrest distance. The new tie-back adjustable lanyards were made just for this problem.
Some companies are roping back to the tower and walking out on the arm, but that has an inherent problem. The issue with roping back to the tower is that if a man falls from the arm, the pendulum swing back to the tower likely will seriously injure him on impact. Such a scenario would be a problem for OSHA, not to mention the worker.
Q: We have asked for your guidance in the past and are hoping you can answer another question that has come up. The question is, when grounding a bucket or line truck, does the grounding chain need to be pulled completely off the reel of the truck to be made up to a grounding point? Or, can it remain on the reel and you only pull off the amount you will need to make up your ground? I asked our truck vendor directly; their response was, “It is up to the individual companies.”
A: Take the entire chain off. Do not leave any coils on the reel. The coils in the chain create a high impedance in the chain during a fault and, in the worst-case scenario, will cause an explosion.
Q: Our company recently updated our safety manual and added a rule requiring rubber gloves when using hot sticks at any voltage. Why is or isn’t that a good idea, and what is the justification, if there is any? The safety department said the company was concerned a stick could flash over and that gloves would protect the worker. Linemen say that gloves prevent sensing a stick that is leaking. What is practical, and what do the rules say?
A: Yours are loaded questions that need several explanations. I say that the questions are loaded because the answers are going to disappoint and maybe even embarrass some safety managers. Gloves are not required when using hot sticks. They don’t improve safety when using a hot stick, and not using rubber gloves doesn’t allow a lineworker to sense a stick breakdown.
Let’s start at the beginning. First, there is no rule, industry-accepted best practice or consensus standard that requires, recommends or even suggests that rubber gloves are a good idea when using hot sticks. In fact, as far as consensus standards go, it’s just the opposite. There is a principle of electrical physics that plays a role in the performance of insulating materials. Every reader is probably already aware that an insulating boom leaks current. That’s why we annually test gloving booms and bare-hand booms: to check the integrity and leakage to ensure the insulating boom is doing its job to protect workers. This leakage plays a role in the quality of the insulating material’s performance in the same way primary voltage cable works. Most trained cable splicers have been told to maintain the integrity of the cable design to keep it from treeing or burning through. That’s because the insulation leaks. The design of the cable uses a semi-con shield and a conducting tape, or a uniformly applied concentric shield, to collapse that leaking voltage and safely conduct the very low leakage current to ground. If that shielding is damaged or defective, the voltage leaking through begins to build, eventually building enough stress to burn through the insulation. Insulating booms and hot sticks work the same way. There is a very, very low current leaking across the stick and through the lineworker and the pathway to earth across the boom, structure or platform the lineworker is working from. If you read paragraph 4.10.2 (c) in IEEE 516, “IEEE Guide for Maintenance Methods on Energized Power Lines,” it states: “The live working tool is a very high impedance element, which allows for the voltage gradient to be spread across the stick from the line part to ground. To do this, a very low leakage current must pass through the worker holding the stick to ground. This current should be very low and may not be detected by the worker. For the above reason, it is not recommended that rubber gloves be worn when holding a live working tool on lines operating above the rating of the gloves.” So, wearing rubber gloves can block the current that is a necessary component of the physics of insulating material performance.
From a practical perspective, I have two observations. First, hot sticks are slick. They are supposed to be. A good, secure grip is necessary to effectively use sticks. It is not easy to get a good grip on them through two pairs of gloves, particularly when they are filled with sweat and when the stick diameters are on the larger side. Trying to affect a good grip through those conditions creates stress on the hands and arms that can result in soft-tissue injury over an extended period of time as well as loss of effective control of the stick in real time. You could argue that the risk of losing grip control and the risk of suffering a soft-tissue stress injury are not justified when the gloves serve no purpose in enhancing safety.
The next practical concern is that properly maintained hot sticks are not remotely likely to flash over. Fiberglass sticks are a primary means of worker protection when using the sticks for energized maintenance. They are designed at 100,000 volts per foot (see 1910.269(j)(1)(i)) and in-service tested at 75,000 volts per foot (see 1910.269(j)(2)(iii)(E)(1)). OSHA 1910.269(j) and the IEEE 516 standard referenced earlier have codified practices that the industry has proven for years ensure that sticks protect lineworkers and perform as expected.
As someone who has many times switched hot circuits from wood poles in the rain, I can assure readers of the integrity of well-maintained sticks. Yes, I did get tingled from time to time, but I was certain then and still am now that those sticks were not going to fail. I also can head off the reader who is thinking they heard of a time when a stick flashed over. Because of the historical record and industry testing, I can confidently assume that if a stick did flash over, there was a serious lack of integrity in the maintenance and care of that stick, or it was improperly employed. Care and maintenance are absolutely necessary for sticks, just like they are for gloves, sleeves, booms, blankets and cover.
Here’s one last observation: If a company is concerned that hot sticks are not properly cared for, and they are creating new rules to accommodate a lack of procedural rigor and safety discipline, that’s a problem a whole lot bigger than sticks.
Q: I am the fire captain for a local fire department, and I want to vent on behalf of my firefighters. We have utilities showing up with one or two people to make restorations after a crash or fire. They take advantage of the free volunteer firefighters to protect their work area. This likely isn’t happening everywhere, but it’s a problem for us and a sore point with most fire departments in the area. I believe that the utility should be showing up with enough equipment, personnel, signs and cones to protect their own work area. We do not mind responding to the initial emergency for the purposes of assisting in rescue, protecting the public, and assisting with protecting police investigators and tow operators. But we don’t like the idea of being expected to hang around to fill gaps for unprepared utility crews who show up after we’ve already expended energy and resources doing our jobs, especially when we’re weighed down in bunker gear.
A: Captain, thanks for your service and for contacting us with your observation. Power crews typically are equipped with plenty of traffic control devices, and they typically are trained in traffic control and should be capable of instituting controls that suit their work area exposure. Perhaps this is an opportunity to bring to our attention that the assumptions we make when we show up are inappropriate if not inconsiderate. We should be training crews in practices that will ensure they are capable of setting up traffic controls and conducting work safely and appropriately. Emergency scenes are different than the routine side-of-the-road work we do, and perhaps the utility crew just assumes incorrectly that they don’t need to set up a work zone. Once the emergency is over and traffic lanes are restored, we have an obligation to set up in accordance with the Manual on Uniform Traffic Control Devices, just like any work area any other time. There are some different risks. Most people don’t really understand the nature of distraction and how distracted drivers raise risk to both our people and your people. Vests and traffic cones are great, but they won’t stop a car. Perhaps we should have police or fire personnel train crews on traffic scenarios and the nature of drivers in these emergency conditions. It would certainly help to hear from professionals how poorly skilled drivers are, and that most drivers faced with the choice are inclined to avoid hitting a big truck by instead striking a smaller person – such as a firefighter standing in the road guiding traffic. We do need to know that the tailboard we conduct includes traffic control, and that traffic controls must be taken care of before anyone starts picking up wire. My recommendation is that if the fire department is still on the scene when line crews arrive, fire department personnel assist with traffic until the line crew gets their work zone in place.
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