August-September 2024 Q&A
Q: How high can we stack poles in a pole yard? I can’t find any references in OSHA or ANSI C2/the National Electrical Safety Code. Is there a standard?
A: Your question provides us with an example of when a standard governing our industry is not necessarily found in the National Electrical Safety Code, OSHA 29 CFR 1910.269 (General Industry) or OSHA 1926 Subpart V (Construction).
What you will find is that there is no specific standard for pole piles; the rules for stacking/storage of materials are the same for every industry. Those rules are found at OSHA 1910.176 and 1926.250, in particular 1926.250(b)(9) for “cylindrical materials.”
The objective is safety in storage, access and handling as each of the rules for materials requires that they be stacked, racked, blocked, interlocked or otherwise secured – such as using chocking systems – to prevent sliding, falling or collapse.
OSHA does not detail, and for practical purposes could not detail, what would constitute safe storage in any specific way. The employer must make and be able to defend the storage and handling arrangements as safe following those general rules for storing materials.
There are no particular statistics, but injuries occurring on pole piles seem to be the caught-between variety, usually when moving poles. So, training and procedures should be guiding any pole storage areas. It’s more detailed in the 1926 Construction standard, but OSHA’s expectation is clear: Training or signage is required as to the modes of material controls; height limits of stacked materials for the competent design of pole-pile controls; and access to and handling of materials added to and removed from the storage pile.
Q: We’ve been looking for references in OSHA 1910.269 and 1926 Subpart V to define the difference between “qualified” and “competent” for our safety manual, but we can’t seem to get a handle on it. Can you give us some direction?
A: This is another example of when rules for our industry are not necessarily found in the vertical standards 1910.269 and 1926 Subpart V. For those of you still trying to figure this out, there are some industries that have their own OSHA standards because the work performed is unique and not easily covered by the general rules for all other workplaces. Those rules are known as vertical standards that only affect a particular industry. However, an industry affected by a vertical standard also must be aware of when a horizontal standard affects them. Horizontal standards are those standards that affect all industries. If you are looking for guidance within a vertical standard and can’t find it, you are most likely going to find your guidance in a horizontal standard.
Now, back to your question. In 1910.269 and 1926 Subpart V, the term “competent person” is not used except in relation to trenching (excavation), which is addressed in the excavation standard found at 1926 Subpart P (note that trenching operations are not addressed in 1910.269 or 1926 Subpart V). “Competent person” is defined at 1926.650(b) as “one who is capable of identifying existing and predictable hazards in the surroundings, or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.” Take note here: A competent person who may have control over work-task safety does not necessarily have to be a qualified person, which is a requirement for persons performing the work.
The net difference between the two terms – “qualified” versus “competent” – is specific to this provision for a competent person: “who has authorization to take prompt corrective measures to eliminate them.” OSHA chose this route to clearly identify supervising personnel who have been trained to the excavation standard requirements. All supervisors can take prompt corrective action but may not be trained to supervise an excavation under the terms of 1926.650. The term “competent person” can apply to a supervisor who is also trained to oversee a trenching operation or an individual who is not a general supervisor but who does have control over a trenching operation. When OSHA comes out and asks who the competent person is for the site, they are not asking for the general foreman or supervisor; they are asking for the specific person in charge of trenching safety who may or may not be a supervisor.
Some utilities use the competent person definition from OSHA 1910 Subpart S, “Electrical,” but that is not really appropriate. The issue with using Subpart S is that the definitions are “applicable to this subpart,” with the subpart being non-utility electrical work. If a utility industry safety professional is looking for a reference for defining “competent person,” again, they will find it in the excavation standard.
To the electric utility industry, “qualified” specifically means to include the requirements for the qualification of lineworkers defined in 1910.269(a)(2). As a reference, we should use the definition of “qualified employee” from the 1910.269(x) definitions, including the notes following the definition, which read as follows.
Qualified employee (qualified person). An employee (person) knowledgeable in the construction and operation of the electric power generation, transmission, and distribution equipment involved, along with the associated hazards.
Note 1 to the definition of “qualified employee (qualified person)”: An employee must have the training required by (a)(2)(ii) of this section to be a qualified employee.
Note 2 to the definition of “qualified employee (qualified person)”: Except under (g)(2)(iv)(C)(2) and (g)(2)(iv)(C)(3) of this section, an employee who is undergoing on-the-job training and who has demonstrated, in the course of such training, an ability to perform duties safely at his or her level of training and who is under the direct supervision of a qualified person is a qualified person for the performance of those duties.
Q: We are a small, distribution-only municipal utility that has been looking into human performance. We are having some trouble understanding it all and how it could benefit us. Most of the training resources seem pretty expensive. Can you help us sort this out?
A: We can. Human performance management (HPM) has been around in various forms and focuses since before the 1950s. Throughout the ’50s and ’60s, it seems the focus was on companies performing functional analysis and correcting issues that created losses, thereby promoting more efficient and error-resistant operations. In the ’60s and ’70s, much of the literature on HPM seemed to surround the nuclear power industry, and indeed the introduction of HPM into the transmission/distribution side of the utility industry appears to have come through the generation side. In the ’70s, researchers began to experiment and write about more closely analyzing the knowledge and skills of the performer. It took a while to sink in, but the safety industry began to research HPM as a culture analysis and risk prevention tool. It makes sense.
Human performance – in particular knowledge, skill modes, decision-making modes and performance – affects all of every enterprise whether you have an HPM program or not. Organizations are made up of people. HPM has identified and categorized commonalities in types of personalities that predict how people make decisions and perform tasks. Studying human performance can also help identify safety culture issues and risk behaviors. It’s not a big or expensive step to train your workforce in problem-solving and decision-making characteristics of the human mind. Soon they will better understand their own processes and the limitations of the way they naturally think, allowing them to make adjustments toward better performance.
So, if we can take advantage of HPM to prevent incidents, why not do it? Most organizations start small. Pick a few key people to begin training on the basics of HPM, and then look at your organization to see where the initial undertakings can do the most good. There are several experts associated with Incident Prevention who will be glad to help should you need it. Additionally, on the iP website (https://incident-prevention.com), you can find numerous HPM articles in the iP archives. HPM works. We hope you will pursue it.
Q: In our company, substations have been under the radar as a safety concern because we haven’t had any issues until recently, when one of our longtime contractors stuck a backhoe boom in a distribution bus. He’s been operating backhoes in substations to excavate for expansions. How do we electrically qualify him and others like him for various nonelectrical crafts?
A: There is a reason we build 10-foot-high fences around substations and cover them with warning signs. It’s dangerous in there. A worker may have performed a task in a substation many times, but that does not make them qualified to be inside that fence, and OSHA has some very particular rules for qualification of a worker that many utilities don’t regard. The very first step is clearly established in 1910.269(a)(2), “Training,” all the way through the note to paragraph 1910.269(a)(2)(ii), which states: “For the purposes of this section, a person must have the training required by paragraph (a)(2)(ii) of this section to be considered a qualified person.”
That’s pretty clear and we could stop right here, but there would be lots of questions, such as, “Do I have to send my backhoe operator to apprentice school to make him electrically qualified?” The answer is no, you don’t have to make him an apprentice, but you can’t just assume the years inside the fence make him qualified. The criteria to be a qualified person are clearly detailed. Those requirements are training and competency in safety-related work practices, safety procedures and emergency procedures related to the individual’s work that are necessary for his or her safety; the skills and techniques necessary to distinguish exposed live parts from other parts of electric equipment; the skills and techniques necessary to determine the nominal voltage of exposed live parts; the minimum approach distances corresponding to the voltages to which the qualified employee will be exposed and the skills and techniques necessary to maintain those distances; the proper use of the special precautionary techniques, personal protective equipment, insulating and shielding materials, and insulating tools for working on or near exposed energized parts of electric equipment; and finally, the recognition of electrical hazards to which the employee may be exposed and the skills and techniques necessary to control or avoid these hazards. These requirements are written by OSHA in such a way as to eliminate the question, “Can’t we just put a journeyman lineman in there with the civil crew while they work?” The answer is absolutely not. Read the very first rule under 1910.269(a)(2)(i). It states, “All employees performing work covered by this section shall be trained as follows.” There is no way to make that rule allow an observer in lieu of training. You may have that observer as part of the protocol for those task-specific-trained craftspeople, but not in place of training.
So, you do have to provide training meeting the listed criteria, but the process is not as complicated as it sounds. An important provision by OSHA sets out the specific expectation of the level of the training, explaining in 1910.269(a)(2)(i)(C) that the “degree of training shall be determined by the risk to the employee for the hazard involved.” This is where job-specific or task-specific training comes in. A nonelectrically qualified craftsman may be trained specifically for his job or task. The employer decides which one to choose. The task- or job-specific training is not a free ride or without a catch. The catch is that the employer had better take this provision seriously, meaning the training must meet the requirements and, like all training, there must be a mechanism to show the worker has the skills required. The training should be formalized, documented, delivered by a competent trainer, and include written and practical demonstrations of skills. Whatever you choose to do, you must be able to defend it if the worst should happen.
Do you have a question regarding best practices, work procedures or other utility safety-related topics? If so, please send your inquiries directly to kwade@utilitybusinessmedia.com. Questions submitted are reviewed and answered by the iP editorial advisory board and other subject matter experts.
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