February 2016 Q&A
Q: I work for a small utility and am new to my safety role. Recently I have been wading through the Federal Motor Carrier Safety Regulations (FMCSR) in an attempt to understand my responsibilities with regard to testing CDL drivers. Can you briefly explain these responsibilities?
A: FMCSR 391.31 requires the employer to ensure a driver is competent by means of road testing. The FMCSR allows a valid commercial driver’s license as evidence of competency (see FMCSR 391.33). If the employer accepts the evidence of the driver’s competency, the employer does not have to road test the driver. Rule 391.33(c) allows the employer to conduct a road test if they so choose even if the driver has a current license and certificate of competency. If the employer intends for the driver to haul double or triple trailers, they are required to conduct a road test. The road test criteria are listed in FMCSR 391.31(c).
As to actual licensing, most states require a knowledge test to earn a commercial learner’s permit (CLP). No matter who delivers training, the driver cannot be on the road until he or she has demonstrated the appropriate driving and control skills. Many states contract with third-party training/road testing services. When the road test is successfully completed using a third party, the trainee is issued a certificate by the trainer, which is then shown at the state licensing office. The driver takes the CDL exam and, if he or she passes, the driver is issued the CDL. For states that conduct road tests, the CLP holder does not have to train with a third party, but the individual better be ready when he or she reports to the appropriate state office for the CDL exam and road test. State-conducted road tests usually begin on a test range for the purposes of demonstrating basic skills. If the driver does not excel there, the examiner will not allow him or her onto the road for the highway portion of the test. Note that some states have minimum criteria that must be met before a candidate can take a state-conducted road test.
Most utilities provide some form of evaluation of new employees who are CDL drivers, or they provide training to new CDL candidates to assist them in obtaining their CDLs, especially candidates who have never driven a commercial vehicle.
The driver road test has to be taken in a vehicle most typical of the one the driver will operate on the road, such as a digger derrick with a pole trailer attached. Even though that’s the truck the driver uses in the test, it does not prohibit him or her from driving bucket trucks or even tractor-trailers. It is the employer’s responsibility to ensure the employee is competent to drive the other types of vehicles.
Even though we operate as utilities and are usually exempt from hours-of-service logs, we do have to operate as a carrier when it comes to licensing, drug testing and record keeping. Every employer has to keep driver qualification files as defined in the FMCSR, and every driver has to have a valid medical certificate registered with the licensing state.
Q: We just started using grounding collars on our reel trailers for pulling in energized environments. Is it possible for the reel to create a transformer effect with the coiled conductor?
A: It’s not likely. Grounding collars can be an effective tool depending on how they are connected. The device may be either a grounding collar connected to the wire and earth, or a bonding collar connected to the wire and trailer. Each has a specific purpose. In either configuration, they do have limits to their protection, but transformer/coil effect is not one of them. Transformer coils have insulating coating on the wire that provides isolation of the individual turns from the adjacent turn in the coil. Your coil of conductor is uninsulated wire wound fairly tightly, so there are no individual turns of wire. Electrically, the reel is more like a big aluminum plug. Concerning the actual experience with the collars, some users report problems with the grounding connections being in the way, but the bonding collars work to equalize potentials between wire/wire reel and trailer. However, so does a traveling ground bonded to the trailer.
Q: If a space becomes a permit-required confined space, typically due to a hazardous atmosphere or another hazard, can it be reclassified as an enclosed space once the hazard has been mitigated?
A: Absolutely. Conditions can be mitigated, and a permit-required confined space can be returned to an enclosed space classification just as if it were the initial classification of the space. The issue would be identifying and understanding the source of the change and ensuring mitigation is effective.
Q: How do we put grounds on distribution travelers during a pull?
A: You can’t, at least not any grounds that will pass fault-current ratings from ASTM F855 for temporary protective grounds the way many transmission travelers do. To be fair, the F855 standard specifically addresses ground cables, clamps and ferrules. F855 sets criteria for performance at different fault levels and then categorizes them by grade numbers 1-7. This has been an issue for many years. The OSHA standard requires installing grounds when pulling in an energized environment, but the equipment industry does not manufacture the equipment to do so. OSHA has revised the language in the most recent rules, removing the locations for these grounds, but the various consensus standards recommend grounds at break-overs, energized crossings and for certain distances. We are not aware of any test protocols for traveler grounds in consensus standards. However, according to one manufacturer, transmission traveler grounds are subjected to high-current tests predicated on the ground clamp tests in F855 and then are advertised as meeting the fault-current ratings of F855.
Some manufacturers have accessory studs that can be installed in the main bearing through-bolt to provide a ground connection point, but these accessories are not rated to any standard. Here’s another consideration: Ground studs installed this way will create a path through the bearing and erode the bearing’s surfaces if induction is present. Talk to your manufacturer’s rep to get information about the electrical testing they have performed.
For practical matters, not being able to pass an electrical stress test may not be a good reason to decide against grounding distribution travelers using the manufacturer-provided accessory attachments. The traveler and perhaps the conductor may not survive the incident unscathed, but if they trip the offending circuit, safety has been enhanced and injuries may have been prevented. Those repair or replacement costs are much easier to take than the loss of an employee. We have lots of examples to demonstrate that these devices provide protection to workers.
At the very least for distribution pulling, traveling grounds at the tensioner can effectively bond that equipment, and the use of equipotential mats at pulling and tensioning points will protect workers whether or not grounds are employed on the line. Any additional paths to ground made on the line serve to help trip the circuit and lower that fault current.
Q: Is it safe to wear hearing aids or earbuds during an arc blast? Will they melt?
A: Not all hearing aids are the same and not all amplification and frequency modulation by hearing aids is the same. Many users of hearing aids can function safely without the aids for a short time if other risks are significant. Our first thought was that if the wearer is properly protected from an arc blast, his or her hearing aids should not be affected. It would be easy to remove them during the exposed period, but that may not be practical for another reason. I wear hearing aids under headphones on the shooting range. It seems illogical, but without them I cannot effectively hear the range master’s safety instructions. If a worker removes his or her hearing aids during critical work, the individual may not hear important safety communications from co-workers.
Hearing damage may be the bigger issue. Most people forget that an arc blast is percussive and has noise associated with it that can damage hearing. It is appropriate to use hearing protection when protecting against an arc blast. Those who wear hearing aids can’t use earplugs, so they would most likely use in-ear headphones or earbuds, which may stick out from behind the reflective heat barrier provided by a face shield. Some in-ear headphones and earbuds have pretty flimsy vinyl covers over the padding, which could be an issue if they are not covered by the balaclava. In that case, a hazard analysis might determine that not using hearing aids is sufficient for safety and earplugs can be worn.
Q: Can portable grounds be placed by hand if a ground has been installed at the opposite end of the circuit?
A: OSHA has pretty clearly stated that grounds must be placed by insulating tools for safety. We are aware that there are companies that allow subsequent placement of additional grounds or personal protective bonds in leather gloves. The justification is that under OSHA, if a grounded cable is safe to contact, it should be safe to add grounds. There are two basic reasons why this interpretation may not be able to be supported. One is the basic rule. The standard does not state that if other grounds are in place, it’s OK to install them by hand. The second reason is even better. The purpose of grounding is to cause immediate operation of a protective device. Grounding in itself does not necessarily protect the worker – bonding does. If the conductor should inadvertently energize or have hazardous induction on it, that second ground or bond being installed could expose the installer to a hazardous difference in potential. Even though the conductor is already grounded, the second ground is still a parallel path and – under certain conditions not necessarily within your control – could have high enough current in the connection you’re making to be hazardous.
Q: The 4-inch opening meat hooks we use to climb towers are not side rated. Are they in compliance with OSHA regulations with the lack of the gate rating? We like them because they are half the weight of the side-rated hooks, but is it acceptable to use them?
A: As usual in the Q&A, we strive to provide readers with all of the information, practical and statutory, from which to make decisions. Yes, how a snap is used determines what stresses it is exposed to and that was the basis for OSHA’s interpretation related to your question.
OSHA addressed the side-opening gate standard in Letter #20070920-8088, dated October 13, 2009 (see www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27302). In the letter, OSHA explains that the agency has not adopted the 3,600-pound side-load gate rating now found in ANSI Z359.1-2007, paragraph 18.104.22.168.3., so the gate rating is not considered part of the statutes.
OSHA also explains in the letter that the agency only requires tensile load tests, not compressive strength tests that involve side-stressing the gate. Tensile loading duplicates the type of stress expected in fall protection. In climbing rigging, such as rappelling and high-angle technical rescue, the gates on carabiners or snaps used may be laid over an edge and subject to side loading, thus the new compressive standard.
However, as is usually the case, the ANSI standard has revealed a potential failure mode and test to ensure performance against side-loading failure. As such, if the utility employer determines that side loading is an issue, the ANSI standard has a standard of performance for compressive loading on the gate that gives the employer a choice to provide that additional protection. As OSHA states it, the ANSI standard is evidence a hazard exists and that abatement of the hazard is feasible.
The letter further states that even if OSHA has not adopted the ANSI side-gate rating, use of such equipment is required under the General Duty Clause. OSHA does not explain that if the use of the snap does not include side loading, there is no risk of failure and therefore no requirement to abate a risk that does not exist. An example of rigging that would side-load a gate might be a man on a lattice bridge attaching a meat-hook snap to a vertical angle but allowing it to lay over or rest on a horizontal angle that would create side loading in a fall. In that case, side-load compressive strength could prevent a hook failure. If side loading is a stress imposed in the way a snap is used, and in particular if a side-load failure injured an employee, OSHA would cite the employer under the General Duty Clause.
The bottom line is that the OSHA standard has not adopted ANSI Z359.1 and there is no written requirement to have side-load-rated gates. Snaps/gates used where no side loading is present is not a citable offense. Snaps that would likely be exposed to side loading, or that failed in a side-loaded exposure, would be cause for citation under the General Duty Clause.
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