June – July 2024 Q&A
Q: Why don’t all utilities use rubber gloves with hot sticks?
A: One of our supporting consultants sent us this question that he gets all the time. The answer is simple: There is no requirement in any standard to use rubber gloves with hot sticks. Rubber-gloving hot sticks has evolved as a work practice in the last decade. There is nothing wrong with choosing to use rubber gloves with hot sticks, and lineworkers have been known to do so during wet or snowy conditions. But many lineworkers with more than 20 years of experience will tell you that we never used rubber gloves routinely with hot sticks and never had an issue with that practice.
Why is there no requirement? Well, that’s based on history. The inspection and maintenance protocols of OSHA and ASTM as well as the use guidelines in IEEE – wherein hot sticks are utilized as primary protection for workers without using a secondary buffer like rubber gloves – have proven to be exceptionally reliable. Obviously, if we violated the standards and stopped testing, inspecting and cleaning sticks, hazards would arise. But that is not an excuse to start using rubber gloves. Adding rubber gloves to hot-stick use has created concern among work methods specialists because the heavy gloves are likely to impede grip on the stick, resulting in greater-than-necessary wear and tear on the muscles in the hands and arms, not to mention additional wear on the gloves themselves.
Another emerging issue with adding rubber glove use is that many in the industry have recognized a higher-than-normal incidence of carpal tunnel syndrome among lineworkers who use them. No scientific studies have been conducted that we are aware of, so the evidence is considered anecdotal, but most if not all lineworkers will tell you they experience hand cramps with heavy hand-tool use when wearing rubber gloves, especially those that are Class 2 and above. A reading of the medical literature on how carpal tunnel syndrome develops puts rubber gloves directly in the “yes” column as a potential issue. Over the years, many utility safety advisers have reported a high incidence of employees with this type of injury, and several of Incident Prevention’s consultants have reported issues that likely are related via surveys and interviews. We even know of interviews with hand specialists who agree that the use of rubber gloves presents a very reasonable risk of carpal tunnel injury.
Q: What does OSHA consider inclement or hazardous weather?
A: OSHA refers to this type of weather as “adverse.” While adverse weather is not often mentioned in the standards, OSHA would treat any employee’s unnecessary exposure to such weather as potentially hazardous, and it could make the work environment potentially hazardous as well. Obviously, lightning from an approaching storm is a risk, but slippery surfaces due to rain or ice are also conditions that OSHA would expect an employer to anticipate and to then either remediate or make work reassignments to prevent exposure. These horizontal standards are based on the expectation that the employer will perform a workplace hazard assessment to identify and remediate the identified hazard. That expectation applies equally to all electric utility workplaces. Specific to the utility arena, OSHA does address weather-related hazards in both the barehand section (see 29 CFR 1910.269(q)) and the line-clearance tree-trimming section (see 1910.269(r)). OSHA recognizes storm work in 1910.269(q)(4)(iv), preceding the rule with “except during emergency restoration procedures.” But even then, there is an expectation to reasonably judge conditions and work requirements, although that assessment is purely subjective. The bottom line is that the employer, including the crew supervisor, must be able to defend the decision to work in adverse weather. That subjective assessment is based on the nature of the adverse weather conditions, risk to the employee, risk to the public, and likelihood of a reasonable, timely outcome to the repair.
However, when it comes to rubber glove work, OSHA follows the consensus standards noted in Appendix G to 1910.269, “Reference Documents.” The inclement weather clause is found in IEEE 516, “IEEE Guide for Maintenance Methods on Energized Power Lines.” The statement applies to all insulating work methods that can be compromised by weather. Generally, those recommendations apply to normal operations or scheduled maintenance work.
Emergency work for the safety of the public may allow “wet” work under informed and carefully considered conditions. For instance, a lineman using a shotgun on a wood pole may be more likely to get tracking over his rubber gloves because he is part of a circuit to ground and the pathway is of lower resistance because of wet contamination. However, a lineman isolated in a bucket truck using a shotgun and rubber gloves would likely feel no tracking at all.
In part 7.4.2.4, “Typical work guidelines,” IEEE 516 offers additional guidance to help employers make work methods decisions. The typical work requirements contained in this subclause (see italicized text below) should only be used as a guide to develop work procedures. Further guidelines may be found in the NESC, OSHA regulations, state and local codes, and other national standards.
a) When working with voltages from 600 V up to 7500 V: With the use of proper protective equipment (e.g., line hoses, blankets), this voltage level may be worked directly from wood poles and other grounded structures.
b) When working with voltages from 7501 V up to 36000 V: For voltages up to 15000 V, installation of line hose, blankets, and other protective equipment can be performed from the structure using the rubber gloving or insulating tool method. For voltages above 15000 V, line hose, blankets, etc., may be installed with live-line tools or using the rubber gloving method from an insulating device. Additional insulating devices should be used when using the rubber gloving method to reduce the leakage current in the worker. Sleeves are used when there is no positive assurance that the arms cannot violate the phase-to-phase or phase-to-ground MAD for the voltage involved. Work in damp or foggy weather is often limited by the boom leakage current or the atmospheric humidity.
Q: Does OSHA require grounding of trucks used in energized power-line work?
A: The answer is no. The singular applicable rule is found at 1910.269(p)(4)(iii)(c), which states that unless the employer can demonstrate that the methods in use protect each employee from the hazards that could arise if the mechanical equipment contacts the energized line or equipment, the measures used shall include the best available ground, bonding equipment together, using ground mats and employing insulating material.
How can we say the answer to your question is no when the first measure is using the best available ground? That answer is in found in this phrase from the rule: “Unless the employer can demonstrate that the methods in use protect each employee …” As we have written previously in Incident Prevention, the solution to employee safety is sometimes quite simple. If touching the truck can kill you, don’t touch the truck. If standing 2 feet from the truck exposes you to step potential, stand 10 feet away.
The purpose of grounding the truck is to clear the circuit by opening protectors if the grounded boom contacts the bus. A worker in contact with the truck is a parallel path to ground with the temporarily installed truck ground. It is only the coincidence of parallel resistances that may decide if that contact is lethal or not. If you ground, that is why the rule also demands that you ground in an equipotential arrangement. So, if you promote grounding of the truck to protect workers but do not employ equipotential mats, you are not in compliance with OSHA.
We encourage readers to review Jim Vaughn’s “A Close Look at Step and Touch Potentials” for a detailed review of the step and touch hazards related to grounded trucks. The article is available at https://incident-prevention.com/blog/a-close-look-at-step-and-touch-potentials/.
Q: Is fall protection required on rooftops where weatherheads exist?
Several years ago, Incident Prevention magazine published a response to a similar question. The discussion focused on an incident in which a lineman was pulled off a roof by a weatherhead that failed when he was trying to sag the service.
Here’s an explanation of the OSHA Construction fall protection standard’s preamble. The standard itself is found at 1926.500. A careful reading of it clearly indicates that none of the specified rules applies to or in any way addresses the nature, type and duration of utility workers on rooftops. Rooftops accessed by utility employees are sealed installations, warrantied by the roofing installer. It is not possible or practical to penetrate the roofing system to install an anchorage for a utility worker making a 15-minute connection to a weatherhead. It is also recognized by OSHA that the hour or more it would take to install the fall protections systems called out by the 1926.500 standard would unnecessarily expose the utility worker to hazards they likely would not face during the 15 minutes they would spend on the roof at the weatherhead.
At issue with rooftops is the lack of fall protection anchorages to which a utility worker could attach their fall protection. The lack of facilities and anchorages to attach to makes using fall protection infeasible. OSHA defines infeasible in 1926.500(b), stating that it means “impossible to perform the construction work using a conventional fall protection system (i.e., guardrail system, safety net system, or personal fall arrest system) or that it is technologically impossible to use any one of these systems to provide fall protection.”
In the preamble to the final rule on walking and working surfaces, OSHA did address temporary work. As clarified by the agency, rooftop work is temporary in nature, meaning that it is “brief or short,” that it generally includes “those [tasks] that a worker is able to perform in less time than it takes to install or set up conventional fall protection,” and that “OSHA believes worker exposure to fall hazards is very limited.” Further, “OSHA agrees with stakeholders who said that requiring employers to install conventional fall protection in these instances could increase worker exposure substantially” (see Federal Register, Vol. 81, No. 223).
Recognizing the infeasibility of erecting fall protection as described above, utilities across the U.S. do not require fall protection on rooftops when connecting services. Accordingly, utilities train employees on safe work practices, relying on the employees’ experience and the assumption that facilities installed by others are properly installed and will not be an unexpected or unrecognized risk to workers.
While Incident Prevention tries to provide guidance in compliance with OSHA and historical OSHA actions, every situation involving rooftop work may be interpreted differently by local enforcement. There is no direct answer to the issue, but we have provided what we hope is a bona-fide example of a successful appraisal of the risk, the exposure and the likelihood of a fall, as well as remediation based on OSHA’s own observations as noted in the preamble published in the Federal Register. This is information employers can use to assess their own policies and procedures.
Q: Is there any regulation regarding hydro-excavation operators and fall restraint while at the edge of an excavation?
A: Fall prevention is a general concept that applies wherever there is a fall hazard, and it is based on elevation and the potential of striking a lower level. If you read the preamble regarding pole excavations, OSHA does not expect us to provide fall protection for a hole if we are going to cover or fill that hole with a pole immediately after excavation. We are sure the preamble was assuming excavation by conventional digger derrick or post-hole diggers, but a pole hole is a pole hole no matter how it was excavated. Obviously, a poorly operated hydro excavator could create cave-in conditions that may not be expected with a digger derrick. So, the answer depends on two things: How big will the excavation be (i.e., will the nozzle fill the excavation?), and how long will the excavation be exposed?
If you are excavating for a pole and will set it or cover the hole when finished, no fall protection is needed. If you are excavating a 4-foot-by-6-foot-by-6-foot cable pit for splicing, fall protection is required.
Do you have a question regarding best practices, work procedures or other utility safety-related topics? If so, please send your inquiries directly to kwade@utilitybusinessmedia.com. Questions submitted are reviewed and answered by the iP editorial advisory board and other subject matter experts.
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