Author: Danny Raines, CUSP

Danny Raines, C.U.S.P.,and RUSS can serve any Safety training and OSHA or FMSCR Compliance training need for any industry including electric utility company, contractor, municipal, customer owned electrical system or co-operative. RUSS has more than 43 years of service and experience in the electrical utility business providing Safety and Compliance training. An OSHA Authorized trainer provides all 29 CFR 1910 General Industry and 1926 Construction compliance training. NFPA 70 E and NESC Trainer for electrical industry and Sub part "S" maintenance electricians.

Voice of Experience: OSHA Record-Keeping Requirements

OSHA record-keeping has long been an administrative challenge to businesses required to keep OSHA logs. In this installment of “Voice of Experience,” I’ll cover some changes that have occurred over the years as well as some essentials that all employers and employees must understand in order to maintain compliance with OSHA requirements. When the change from the OSHA 200 log to electronic record-keeping was made in 2002, it was a relief to many. At that time, all issues involving first aid were resolved; a list of first aid treatments was identified and took any doubt out of the requirement...

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Voice of Experience: Inspection, Maintenance and Fall Protection Guidance for Bucket Truck Use

OSHA 29 CFR 1910.67 is the performance-based standard that covers requirements when using vehicle-mounted elevating and rotating work platforms, including the bucket trucks we use in the electric utility industry. There are many types of buckets, and the task to be performed will determine what type of bucket is required. This standard even covers noninsulated work platforms, sometimes referred to as JLGs, used in civil construction. For clarification, a mobile platform covered under 1910.68, “Manlifts,” is not covered under the 1910.67 standard. Mobile platforms are considered mobile scaffolding...

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Voice of Experience: Switching and Working on UD Systems

I was recently asked to provide information about the challenges and opportunities found when working on direct-buried underground distribution (UD) systems. In light of that request, I’ll address those topics in this installment of “Voice of Experience.” My first opportunity to work on UD systems was as a truck driver operating a trencher in the late 1960s. UD systems were fairly new at the time; lineworkers were learning new techniques, using different types of tools to terminate cables and installing switchable elbows. In that day, some elbows were non-load-break. Back then the work was all...

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Voice of Experience: OSHA’s MAD Changes and a Missed Opportunity

In the 2014 OSHA update to 29 CFR 1910.269 and 1926 Subpart V, major changes were made regarding apparel and minimum approach distance (MAD) calculations. And yet I believe the agency missed an opportunity related to distribution voltages and gloving of energized conductors and equipment. For all intents and purposes, other than the MAD updates, few changes occurred in 29 CFR 1910.269(l) regarding working position. A new requirement removed any implied obligation that an employer is accountable for ensuring employees do not approach or take any conductive objects within the MADs found in tables...

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Voice of Experience: OSHA Requirements for Step Potential Protection

When OSHA updated 29 CFR 1910.269 and merged almost all of its requirements with 1926 Subpart V, the requirement to protect employees from step potential was enhanced. In the months following the publication of the final rule, this change was rarely mentioned in the major webinars conducted by several prominent utility industry groups, so I want to take this opportunity to cover what you need to know. First, let’s talk a bit about the basic fundamentals of Ohm’s law and Kirchoff’s law of current division in order to ensure you understand the seriousness of step potential hazards. Ohm’s law states...

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Confined Spaces in Construction

Last May, OSHA published its final rule regarding confined spaces in construction. Since that time, there have been many questions about the differences between the new construction standard and 29 CFR 1910.146, “Permit-required confined spaces.” In this installment of “Voice of Experience,” we will take a closer look at both standards in an effort to clear up any remaining confusion. “Confined Spaces in Construction” is the title of 1926 Subpart AA, the recently released construction standard. Before Subpart AA was published, 1910.146 was the only OSHA standard that addressed permit-required...

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Voice of Experience: OSHA Citations and Informal Conferences

OSHA fines will increase for the first time in 25 years under a provision in the recently signed U.S. congressional budget deal. The Federal Civil Penalties Inflation Adjustment Act of 1990 exempted OSHA from increasing its penalties to keep pace with inflation. But a section of the new budget signed in November by President Barack Obama – referred to as the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 – strikes the 1990 exemption. Now, OSHA is directed to issue an interim final rule adjusting its penalties to account for current inflation levels, which would raise...

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Voice of Experience: Hand and Skin Protection for Electric Utility Workers

With the recent changes to the OSHA standard, many employers are working on what rules apply – the arc flash standard or the PPE standard – and how to comply with them. Part of the issue is determining how many types of protection are needed and what types of protection are appropriate. To begin, OSHA’s requirements for all personal protective equipment can be found in 29 CFR 1910 Subpart I. Rules specific to hand protection can be found in 1910.138. They read as follows: 1910.138(a)“General requirements. Employers shall select and require employees to use appropriate hand protection when employees’...

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Voice of Experience: PPE Regulatory and Consensus Standard Requirements

OSHA 29 CFR 1910 Subpart I and 1926 Subpart E cover the requirements of personal protective and lifesaving equipment. With the publication of OSHA’s final rule in April 2014, the general industry and construction standards are now essentially the same for electric utilities, and there are few if any differences in the PPE required by each standard. In addition to OSHA’s regulatory standards, there are ANSI/ASTM and other consensus standards that govern the manufacturing, type and ratings for all PPE. These consensus standards change as the industry evolves and PPE improves. All PPE should meet...

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