Information Transfer: What’s Needed to Protect Affected Workers?
As with all the other articles in this series, when it comes to information transfer, it is important to start with the hazard. Individuals who work on or near electric power lines and equipment face a multitude of potential high-risk electrical hazards. Employers have the responsibility to identify and control known hazards to ensure worker safety. When unknown hazards exist, the level of risk is elevated because workers may not have all the information they need to safely perform their work.
To ensure all workers have the knowledge they need to work on or near high-risk hazards, OSHA requires host employers – generally electric utilities – to exchange specified information with contract employers so that each employer has the information needed to protect affected workers. These information transfer requirements can be found in OSHA 29 CFR 1910.269(a)(3) (general industry) and 1926.950(c) (construction).
It should be noted that OSHA addresses multiemployer work sites within horizontal construction standards; however, the electric power information transfer standard adds more requirements for host employers that are unique to electric power installations.
Information Transfer Requirements
Information is required to be shared when a contract employer is working in a covered process. You may remember from the first article in this series that a covered process involves work areas with electrical system hazards.
OSHA uses the terms “host employer” and “contract employer” throughout the information transfer standard. A host employer is typically an electric utility or another entity that operates or controls the operating procedures for an electric power installation. A contract employer is any contractor or subcontractor that performs covered process work with electric power system hazards.
A host employer is required to share information with and receive information from a contract employer using an appropriate communication method. According to OSHA, an appropriate communication method includes but is not limited to a telephone call; an email; a text message; a bid package; a map or similar document along with the information or guidance to interpret the map or document; a contract; a developed website or other computer program; or an orientation session. The most important questions to consider when determining the effectiveness of a communication method is, did the communication reach the workers in the field, and are they using the information to safely perform their work? If not, the method may not be appropriate.
OSHA also requires host employers to provide information to contractors concerning system characteristics and known conditions. It is important to understand what is required within these key terms to ensure information transfer programs appropriately address regulatory requirements. Let’s take a closer look at these two areas.
System characteristics include specific operating details about the electric power system, such as the nominal voltage of lines and equipment; maximum switching transient voltages per unit; hazardous induced voltages; presence of protective grounds and equipment grounding conductors; and location of circuits and equipment, including supply communication and fire protective signaling circuits. If the host employer does not have the required information available, they must obtain the information and make it available to their contractors.
Host employers are also required to furnish known system information related to safety and requested by the contractor as well as known system design information needed for required assessments. These assessments include but are not limited to:
• Does an enclosed space need to be entered as a permit-required confined space? Does forced-air ventilation need to be maintained? If so, for how long?
• What is the minimum approach distance for the work to be performed?
• Are employees exposed to hazards from flames or electric arcs? If so, what is the estimated incident energy?
• Are devices designed to open or close circuits under load conditions?
• What are the known sources of electric energy – including backfeed – supplying electric circuits?
• What are the sources of hazardous energy, including potentially hazardous stored or residual energy?
• Do protective grounds have adequate current-carrying capacity?
• Is there a possibility of hazardous transfer of potential should a fault occur?
• Are overhead structures, poles and towers capable of sustaining stresses imposed by work?
Known System Conditions
OSHA requires host employers to furnish known system conditions to contract employers when the conditions may affect their work. System conditions include but are not limited to known conditions of protective grounds and equipment, known conditions of poles and known environmental conditions related to safety.
For example, take a pole inspection program completed by a utility. If a contractor is hired to perform work on or near poles that may need repair or replacement due to ground rot, the utility must furnish this information to the contractor to ensure the job can be effectively planned while incorporating the identified pole hazards.
Contract Employer Requirements
OSHA requires contract employers to provide needed information to field personnel that they have obtained through the information sharing process. This requirement outlines due diligence for a contract employer receiving information from a host employer to ensure that effective controls are used at the work site utilizing the shared information. For instance, if a contractor at a work site is using 1/0 protective grounds instead of system-required 4/0 protective grounds, this is a true indicator of a breakdown of the information transfer. Breakdowns can occur when required information is not shared effectively, whether by the host employer or the contract employer.
Additionally, OSHA requires contract employers to provide information to host employers within two days of discovering a hazardous condition. Utilities and contractors should address this requirement early in the contract process to ensure an effective communication method is developed and implemented.
The final portion of the standard requires host employers and contract employers to coordinate their work rules. OSHA does not require contractors to follow utility safety rules, but they do require both work groups to ensure compliance with OSHA rules and to coordinate their work activities to ensure worker safety throughout the work site.
In today’s world of electric power operations, utilities and contractors have designed and implemented robust processes to ensure workers don’t have to face the challenges of years ago when a hands-off approach was used with contractors. The thought within the industry was that no information means no liability. We have come a long way from this outdated thinking via effective information sharing processes between utilities and contractors working on shared sites. These requirements are playing a key role in ensuring workers have the information they need to work safely.
About the Authors: Pam Tompkins, CUSP, CSP, is president and CEO of SET Solutions LLC. She is a 40-year veteran of the electric utility industry, a founding member of the Utility Safety & Ops Leadership Network and presently serves on the USOLN executive board. Tompkins worked in the utility industry for over 20 years and has provided electric power safety consulting for the last 20 years. An OSHA-authorized instructor, she has supported utilities, contractors and other organizations operating electric power systems in designing and maintaining safety improvement methods and strategies for organizational excellence.
Matt Edmonds, CUSP, CIT, CHST, is vice president of SET Solutions LLC. A published author with over 15 years of safety management experience, he also is an OSHA-authorized instructor for general industry and construction standards. Edmonds provides specialty safety management services for electric power organizations throughout the U.S. He has been instrumental in the development of training courses designed for electric power organizations, including OSHA 10- and 30-hour courses and SET Solutions’ popular OSHA Electric Power Standards Simplified series.
About OSHA Electric Power Standards – Simplified: Topics in this series are derived from SET Solutions’ popular OSHA electric power course offered through the Incident Prevention Institute (https://ip-institute.com). The course is designed to help learners identify standard requirements and to offer practical ways to apply the standards.
Learn more on the iP Institute Podcast. Visit https://ip-institute.com/podcasts/#OSHA or scan the QR code to listen now!