Installing Fiber-Optic Cable in Electric Supply Spaces

Based on recent social media comments I’ve seen, questions submitted to Incident Prevention magazine and inquiries I’ve personally received, this installment of “Voice of Experience” is going to focus on OSHA and National Electrical Safety Code issues regarding the installation of fiber-optic cable in electric supply spaces, including who is allowed to perform the work.

So, which standards are in question and what qualifications must employees have? For starters, fiber optics is considered a communications conductor – not “supply” as referred to in the NESC. The installation and maintenance of fiber conductors is covered under OSHA 29 CFR 1910.268, “Telecommunications.” The minimum performance standards required to do the work are also found in 1910.268. There is no 1926 construction standard for fiber optics, but 1910.5(c) and 1910.12(a) contain references to general industry construction regulations.

Specifically, paragraph 1910.5(c)(1) states, “If a particular standard is specifically applicable to a condition, practice, means, method, operation, or process, it shall prevail over any different general standard which might otherwise be applicable to the same condition, practice, means, method, operation, or process. …”

Paragraph 1910.12(a) reads as follows: “The standards prescribed in part 1926 of this chapter are adopted as occupational safety and health standards under section 6 of the Act and shall apply, according to the provisions thereof, to every employment and place of employment of every employee engaged in construction work. Each employer shall protect the employment and places of employment of each of his employees engaged in construction work by complying with the appropriate standards prescribed in this paragraph.”

Which Employees Can Do the Work?
Even though OSHA standards are vertical related to construction or maintenance, there is a crossover of certain standards when performing construction tasks in maintenance spaces. The task will determine which standard applies to work practices. The question is, which employees can install and maintain fiber-optic cables in a supply space on a pole or structure?

Paragraph 1910.268(b)(6), “Support structures,” states the following: “No employee, or any material or equipment, may be supported or permitted to be supported on any portion of a pole structure, platform, ladder, walkway or other elevated structure or aerial device unless the employer ensures that the support structure is first inspected by a competent person and it is determined to be adequately strong, in good working condition and properly secured in place.”

And according to 1910.268(b)(7), “Approach distances to exposed energized overhead power lines and parts,” the employer “shall ensure that no employee approaches or takes any conductive object closer to any electrically energized overhead power lines and parts than prescribed in Table R-2, unless the employee is insulated or guarded from the energized parts (insulating gloves rated for the voltage involved shall be considered adequate insulation); or the energized parts are insulated or guarded from the employee and any other conductive object at a different potential; or the power conductors and equipment are deenergized and grounded.”

Regulation Management
The next question is, how does industry manage these regulations? Well, after reading the limitations of communications employees, it would be easier to have 1910.269 transmission and distribution employees perform the installation, but often there aren’t enough of them to go around. So, can 1910.268 employees be qualified and trained to safely install and maintain fiber optics? Industry and the U.S. Department of Labor agree that a minimum of four years of an apprenticeship and 8,000 hours of training are required to safely train a journeyman lineworker to perform energized electric utility work.

A 1910.268 telecommunications employee must undergo similar training to perform line work as a communications lineworker. While there is some low-voltage electrical training required for 1910.268 employees, the major challenge is the hands-on energized portion required of electrical lineworkers. Even the bonding and grounding of messenger cable, sometimes referred to as “strand,” can become a system neutral if an electric utility neutral is bonded to pole grounds and becomes damaged in abnormal conditions. And that means understanding the hazards of the neutral and parallel bonded strand is part of the training a communications worker should receive.

Training Requirements
Recent questions have been asked about how much training is required to qualify a telecommunications employee to work in the supply space on a pole or structure. The NESC requires 40 inches of separation between supply and communications conductors on a pole or structure. Utility companies are asking contractors to install the fiber-optic cable as close as 4 inches under the neutral. When there are open route secondaries and/or three- or four-spool racks, this is very difficult to do.

The training requirements for employees working under 1910.268 and 1910.269 are similar, but when the 1910.269 standard was updated and merged with 1926 Subpart V in 2014, a sentence was added that is believed to allow employees to be trained on specific tasks so they can perform work in the 1910.269 space while never truly becoming a qualified electrical worker per 1910.269(a)(2). See the following two OSHA standards.

Paragraph 1910.268(c), “Training,” states: “Employers shall provide training in the various precautions and safe practices described in this section and shall insure those employees do not engage in the activities to which this section applies until such employees have received proper training in the various precautions and safe practices required by this section. …” In the 1910.268 definitions, a qualified employee is defined as any worker “who by reason of his training and experience has demonstrated his ability to safely perform his duties.” Did you notice the word “demonstrated” in the definition? This means that the training includes a demonstration of skills to the employer or training agent of the employer. Paragraph 1910.268(c) also requires the employer to certify a record of training that includes the employee’s name, the trainer’s name and the date the training was completed.

Paragraph 1910.269(a)(2)(i) states: “All employees performing work covered by this section shall be trained as follows: Each employee shall be trained in, and familiar with, the safety-related work practices, safety procedures, and other safety requirements in this section that pertain to his or her job assignments. Each employee shall also be trained in and familiar with any other safety practices, including applicable emergency procedures (such as pole-top and manhole rescue), that are not specifically addressed by this section but that are related to his or her work and are necessary for his or her safety. The degree of training shall be determined by the risk to the employee for the hazard involved.”

How much additional training is required if the employee is already trained to be a 1910.268 communications lineworker? Paragraph 1910.269(a)(2)(ii) states the following: “Each qualified employee shall also be trained and competent in 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 specified in this section 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 insulated tools for working on or near exposed energized parts of electric equipment; and the recognition of electrical hazards to which the employee may be exposed and the skills and techniques necessary to control or avoid these hazards. Note to paragraph (a)(2)(ii): 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.”

Conclusion
By reading the minimum requirements of the OSHA standards regarding employees working in electric supply spaces, it is evident that training must be rigorous and lengthy. Employers are accountable and responsible for the training and performance management of their employees. It is no easy task for an employee to start working in an energized space because there are many hazards in the electric supply space that employees must recognize to safely perform their work. An intense training agenda and proficiency demonstrations with appropriate documentation are required.

I have spoken with more than one training organization about the amount of training that is required for employees to work on fiber optics in electric supply spaces, and programs are being developed now. The training is not going to be easy to complete, so employers would be wise to seek expert advice about how to move forward.

About the Author: Danny Raines, CUSP, safety consultant, distribution and transmission, retired from Georgia Power after 40 years of service and opened Raines Utility Safety Solutions LLC, providing compliance training, risk assessments and safety observation programs. He also is an affiliate instructor at Georgia Tech Research Center OSHA Outreach in Atlanta.