December 2014 Q&A

Q: In regard to work boots and arc flash protection, what does OSHA mean by “heavy-duty work shoes or boots” in 29 CFR 1910.269(l)(8)(v)(B)? Are boots made of synthetic material acceptable if they are work boots?

A: As with all OSHA rules, it is up to the employer to understand the risks and the necessary protections. In many cases the consensus standards give guidance that can be used to satisfy the OSHA standard. Even though NFPA 70E exempts utilities, OSHA has clearly used the NFPA as a source of material to assist utility employers in protecting employees, and the clothing standards in 70E may be a good place to start. NFPA 70E is not an adopted standard, but as OSHA stated in an October 18, 2006, letter to Michael C. Botts (see www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=interpretations&p_id=25540), “A national consensus standard … can sometimes be relevant to a general duty clause citation in the sense that the consensus standard may be used as evidence of hazard recognition and the availability of feasible means of abatement.” In Table (C)(10), NFPA 70E requires leather boots as needed.

As to OSHA requirements for protection against arc flash injury, the OSHA standard – as you point out – requires heavy-duty work boots or shoes. But here is something to consider: The OSHA standard prohibits materials that will continue to burn, which covers synthetic materials. The question to ask is, if a worker’s feet are exposed to arc flash, would the material that the boot or shoe is made of ignite and continue to burn? If so, it would likely be prohibited.

Another worthy point is that the requirement for use of arc-rated clothing is based on an assessment of the work exposure. If there is no reasonable likelihood that the feet are exposed, then there is no requirement for arc protection for the feet. If there is a likelihood of exposure – the vents at the bottom of enclosed switches come to mind – foot protection is required. Here is another issue to think about: If a forceful arc pressure flowing from vents or gaps under a switch door at ground level could burn a worker’s feet, you should also consider the chimney effect that might be created by the opening at the bottom of the pant leg. It’s one incident, but I am aware of an arc flash that rose up under a worker’s cuffs and severely burned his legs as the arc heat was trapped in his arc-rated pants.

Q: I just read “Train the Trainer 101: Stringing in Energized Environments” in the October 2014 issue of Incident Prevention, which discussed grounding while pulling conductor under tension. Did the article suggest not grounding the first and last structure with traveler grounding studded stringing blocks?

A: Thanks for the question. We are always interested in hearing from readers about the content of iP magazine, especially if readers are concerned that we made an error or may have been unclear about an issue.

To answer your question, no, we are not making such a recommendation. In fact, most iP subject matter experts would agree that the former rules regarding placement of traveling grounds are still a best practice. In the article, we only referred to the language OSHA removed from the rules that previously did designate the location of the pulling grounds and why they might have done so. A grounded traveler at the break-overs, or one span away as we do, is still the best practice for protection of personnel. As we often mention, the industry consensus standards are where employers might go to find procedures that will meet OSHA rules, and in this case we went to IEEE 524, “IEEE Guide to the Installation of Overhead Transmission Line Conductors.” IEEE 524 standardizes a grounded traveler at both break-overs with running grounds at the tensioner as well as puller if it is using steel rope.

There is an issue about how to ground, especially in distribution. For those XCP-100-size stringing blocks typically required for distribution wire stringing, we do not know of a manufacturer that makes a fault-rated grounding traveler. However, blocks with adaptor studs installed for attaching a ground will help shed current in a fault and also will help to trip a breaker even though the traveler itself won’t be much good after the event.

As to induction, if it’s high, those stud-grounded travelers are not current rated and can heat up or arc in the axle pins under steady-state currents, which can also damage or seize up a traveler and may scar wire. When protecting for any pull in an energized environment, guard structures and grounding at the crossings are important. Cover-up alone can be risky if you are depending on cover to protect your running conductors from contact. If during the pull the running conductor sags onto those covers, it will roll rubber hose and plastics right off the energized line, and pretty quickly, too.

Q: Would there ever be a time when federal or state OSHA would require a contract lineworker to wear a breakaway high-visibility safety vest?

If we recall correctly, the idea of a tear-away vest was created for highway workers who use rotating cutting tools, drills, signpost augers and related items. The idea is that a loose-fitting vest could get caught in a power tool, pulling a worker into the tool and causing injury. Obviously, loose-fitting clothes could do the same, but that’s why many safety rules require that power-tool users tuck in their shirts. Likewise, with the advent of Type III vests, they got longer and looser to meet the square-inch requirements of reflective material. Tucking in a vest hides the square inches of material required to be visible, so tear-away was invented.

Unless there is state criteria requiring tear-away, the requirement would be at the employer’s discretion after performing a hazard analysis. If there is no risk of a vest creating a hazard as previously described, there is no reason to have a tear-away version.

As to federal OSHA, it’s the same. Tear-away may be a solution if a hazard analysis identifies the risk as previously described, but there is no rule requiring tear-away. In fact, OSHA has no specific rule on traffic safety vests, but that does not mean they don’t have an opinion. In a 2009 Trade News Release, OSHA issued an opinion that traffic vests are required under the General Duty Clause to protect employees in highway construction zones since the hazard of moving traffic and construction equipment is well documented, and that high-visibility clothing is a recognized method of reducing risks to those workers. It is a short hop to all construction sites from highway construction sites. The hazard of moving equipment in a substation or power line right-of-way is just as real, so OSHA’s opinion extends there as well.

Users need to be aware that the fire-resistant rating on a typical traffic vest is not an arc rating. A traffic safety vest exposed to an arc will melt. Electrical workers exposed to traffic and arcs should either wear high-visibility arc-protective wear that meets the contract and nighttime reflectivity standards or arc-rated traffic vests.

Q: I don’t agree with Incident Prevention’s contention in the October 2014 issue’s Q&A that it is OK to connect two snaphooks into one D-ring. My understanding of the rule is that OSHA does not allow snaphooks on a single D-ring unless (1) the snaphook is a locking type and (2) the snaphook is specifically designed for certain connections, one being to a D-ring to which another snaphook or other connector is attached.

A: You are not the only reader with that opinion and we acknowledge that without issue. iP’s intent is to educate readers and make safety understandable. We provide guidance toward interpretation and cite what we best identify as the resources toward interpretation of the standards and practical workplace safety. The interpretation regarding two snaphooks in one D-ring hinges on what employers interpret as – and what OSHA accepts as – “specifically designed,” which you cited in your question.

We refer you to the original issue and reasoning for prohibiting two snaps that were discussed in the preamble to the original rule (see Federal Register Vol. 79, No. 70, pages 20392-20404). That reasoning was valid because without locking snaps, the two snaps are considered unsafe due to the potential for accidental disengagement of the snaphooks during use. Snaps are now specifically designed not to be able to be accidentally disengaged or to inadvertently open another snap in the same D-ring.

We examined literature from several manufacturers and see their fall protection and secondary lanyards listed as compatible with their two-D-ring belts. We have seen video and instruction from manufacturers using secondary lanyards on both two- and four-D-ring belts. In addition, top executives from both Buckingham Manufacturing Co. and Jelco have confirmed to iP that they have no prohibitions against users attaching locking-type snaphooks in a single D-ring. We have a letter from Buckingham that approves two locking snaps in a single D-ring, and anyone who would like to review the letter is welcome to request a copy from iP. We also direct you to the user literature from Buckingham that states that “unless you are using locking snaphooks, never attach multiple snaphooks to a D-ring.” We don’t know how that statement cannot be interpreted as permission, but many people still call Buckingham to ask if it is OK. At present, Buckingham’s answer is yes, it is OK. Obviously, Buckingham is always free to change their instruction just like an employer is free to use a four-D-ring belt, and Buckingham – which was the first in this industry to offer a four-ring body belt as a convenience to park the unused secondary safety – as well as any other manufacturer will gladly sell you one.

Finally, two-snap compatibility is a widely discussed issue and we support any questions that affect safety. However, there seems to be a lot of attention paid to this one rule but none to the rule immediately preceding it. Rule 1926.502(d)(5) states that snaphooks shall be sized to be compatible with the member to which they are connected to prevent unintentional disengagement of the snaphook by depression of the snaphook keeper by the connected member, yet no one calls the manufacturer or asks for a statement of compatibility, even when they mix manufacturer safeties, belts and fall protection devices. Our contention is still that it is not prohibited by the standard under these conditions, but again, our intent is to educate the reader toward interpretation and practical safety. We invite reader opinions on the issue, and if we learn that OSHA ever directly states that two locking snaps in a D-ring is not an allowable practice, we will be the first to say so.

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.