Lineworkers and Rubber Sleeves
I am often asked about the benefits of wearing rubber sleeves. Personally, I never had to wear them as an apprentice or a lineman because of my former employer’s belief that an insulate-and-isolate program was the best way to go. Even today, the company that employed me for over 40 years does not require lineworkers to wear sleeves for the same reason.
The OSHA Strategic Partnership Program agreement to wear sleeves was developed by major contractors and utility organizations in 2005-2006 and reaffirmed even after the 29 CFR 1910.269 updates were made in 2014. The agreement was an effort to reduce the number of incidents and fatalities due to contacts and flashes, and it was successful for those in the partnership. Most of those incidents were phase-to-ground contacts, flash-type accidents and exposed differences of potential in the work area. Rubber sleeves were thought to limit the possibility of contact by insulating the employee from differences of potential. The partnership agreed that ground to ground when climbing, cradle to cradle when using bucket trucks, and lock to lock with underground work would reduce OSHA reportable incident rates and DART rates from the preceding years for contractors.
Based on 55 years in the electric utility industry, when people ask me what I think about rubber sleeves, I offer an opinion on the need for lineworkers to wear rubber sleeves when performing energized work in the minimum approach distance of energized conductors and equipment. First, I point out the requirements of OSHA 1910.269(l)(4), “Type of insulation” (see below for the full text). OSHA regulations are enforced by the courts, and employers are legally responsible for the proper training and management of their workers. Employees are responsible for their actions and should follow the training provided by their employer as required.
For easy reference, following is the full text of 1910.269(l)(4).
1910.269(l)(4)(i): When an employee uses rubber insulating gloves as insulation from energized parts (under paragraph (l)(3)(iii)(A) of this section), the employer shall ensure that the employee also uses rubber insulating sleeves. However, an employee need not use rubber insulating sleeves if:
1910.269(l)(4)(i)(A): Exposed energized parts on which the employee is not working are insulated from the employee; and
1910.269(l)(4)(i)(B): When installing insulation for purposes of paragraph (l)(4)(i)(A) of this section, the employee installs the insulation from a position that does not expose his or her upper arm to contact with other energized parts.
1910.269(l)(4)(ii): When an employee uses rubber insulating gloves or rubber insulating gloves and sleeves as insulation from energized parts (under paragraph (l)(3)(iii)(A) of this section), the employer shall ensure that the employee:
1910.269(l)(4)(ii)(A): Puts on the rubber insulating gloves and sleeves in a position where he or she cannot reach into the minimum approach distance, established by the employer under paragraph (l)(3)(i) of this section; and
1910.269(l)(4)(ii)(B): Does not remove the rubber insulating gloves and sleeves until he or she is in a position where he or she cannot reach into the minimum approach distance, established by the employer under paragraph (l)(3)(i) of this section.
So, per the OSHA standard, the employer has the option not to require sleeves if they provide the very best insulate-and-isolate training and then manage employees to meet the remaining requirements.
The working position of an employee while performing energized gloving tasks is critical and covered by another part of the OSHA standard – 1910.269(l)(5), “Working position” – to highlight its importance. See the full text below.
1910.269(l)(5)(i): The employer shall ensure that each employee, to the extent that other safety-related conditions at the worksite permit, works in a position from which a slip or shock will not bring the employee’s body into contact with exposed, uninsulated parts energized at a potential different from the employee’s.
1910.269(l)(5)(ii): When an employee performs work near exposed parts energized at more than 600 volts, but not more than 72.5 kilovolts, and is not wearing rubber insulating gloves, being protected by insulating equipment covering the energized parts, performing work using live-line tools, or performing live-line barehand work under paragraph (q)(3) of this section, the employee shall work from a position where he or she cannot reach into the minimum approach distance, established by the employer under paragraph (l)(3)(i) of this section.
With these regulations, frontline supervisors – the first level of management over crews – are ultimately responsible for managing and overseeing the crews’ activities, including performance of the insulate-and-isolate program. Crew members should be trained to recognize and intervene if anyone on the crew fails to follow the training on proper cover-up. The “see something, say something” policy should be taught and supported by all. Use a dedicated person to observe employees performing energized tasks. Many accidents that involve energized contact and different potentials are not witnessed by anyone except the affected worker.
The Industry Question
So, the question for the industry is, do rubber sleeves make employees safer and prevent accidents? If the employer is unable to adhere to the regulations, follow the training requirements and manage employee performance, the answer is yes. Can the tasks be performed safely without rubber sleeves? The answer is also yes, provided that training and performance management are in place and that employees take ownership of each other’s safety as a team. Over the course of my career, I have witnessed the evolution of proper insulate-and-isolate programs. I have seen companies move from having contacts, flashes and fatalities to almost eliminating employee-caused contacts and flashes – just by providing and managing an insulate-and-isolate program.
One Final Question
Today, many companies’ insulate-and-isolate and cover-up programs do not address differences of potential and path to ground. Rated and tested safety cover is installed, and workers position themselves to avoid touching the differences of potential, relying on the cover of the energized parts. The reality is that most contacts are the path-to-ground variety or involve differences of potential.
My question is, why does the industry – and the regulations – only focus on the energized part? Energization at a difference of potential is mentioned only once in OSHA 1910.269(l). I wrote another article eight or nine years ago in which I asked, did OSHA miss an opportunity? When the standard was updated in 2014, OSHA made a change that requires an employee to don and doff sleeves and gloves at such a distance that the employee cannot not encroach upon the minimum approach distances set by the employer. The numerous investigations I have been involved with have been related to contact with energized conductors and equipment and different potentials without adequate cover-up or no cover at all. If an equal amount of emphasis were put on covering the grounds or differences of potential, would that eliminate the need for rubber sleeves? Maybe not, but I believe the work can be done safely without using sleeves.
About the Author: Danny Raines, CUSP, is an author, an OSHA-authorized trainer, and a transmission and distribution safety consultant who retired from Georgia Power after 40 years of service and operated Raines Utility Safety Solutions LLC for nearly 15 years.