Lone Worker Limitations
Over the years, I’ve received numerous questions about which duties lone workers can safely and legally perform, and which ones require more than one qualified worker to complete.
Tasks that require at least two qualified employees are defined in OSHA 29 CFR 1910.269(l)(2)(i), which states the following: “Except as provided in paragraph (l)(2)(ii) of this section, at least two employees shall be present while any employees perform the following types of work: installation, removal, or repair of lines energized at more than 600 volts; installation, removal, or repair of deenergized lines if an employee is exposed to contact with other parts energized at more than 600 volts; installation, removal, or repair of equipment, such as transformers, capacitors, and regulators, if an employee is exposed to contact with parts energized at more than 600 volts; work involving the use of mechanical equipment, other than insulated aerial lifts, near parts energized at more than 600 volts; and other work that exposes an employee to electrical hazards greater than, or equal to, the electrical hazards posed by operations listed specifically in paragraphs (l)(2)(i)(A) through (l)(2)(i)(D) of this section.”
The exceptions that allow for a lone worker are described in 1910.269(l)(2)(ii), which states, “Paragraph (l)(2)(i) of this section does not apply to the following operations: routine circuit switching, when the employer can demonstrate that conditions at the site allow safe performance of this work; work performed with live-line tools when the position of the employee is such that he or she is neither within reach of, nor otherwise exposed to contact with, energized parts; and emergency repairs to the extent necessary to safeguard the general public.”
What is a Qualified Worker?
Since we are reviewing tasks that qualified workers can perform either on their own or with others, it’s important to understand the definition of “qualified” and what kind of training must be completed to be considered a qualified worker. This information is found in 1910.269(a)(2), “Training.” Readers are probably familiar with the (a)(2) rule, which requires employees to be trained in and familiar with the safety-related work practices, safety procedures and other safety requirements in the section that pertain to their job assignments. Notice here that the rule specifically relates to safety-related training. OSHA does not regulate craft training skills, only skills related to the safety of completing tasks. Obviously, much of craft skills is inextricably related to safety. In other words, OSHA is not concerned about how fast or precise your operator skills are on a digger derrick, only that your competencies assured by the employer mean that you won’t hurt anyone while operating in an unsafe manner.
Paragraph 1910.269(a)(2)(i)(B) requires that employees be trained in other safety-related practices, which is pretty ambiguous, but that requirement is followed by this text: “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.” This can be interpreted very broadly and probably should be. Our work locations are not just wood poles and manholes. The employer is expected to have a rescue plan for any workplace with workstations that are difficult to access, like transmission poles, substation superstructures, mid-span wire carts, and all of the nooks and crannies associated with generation plant structures.
Paragraph 1910.269(a)(2)(i)(C) further explains that training does not mean everyone has to excel in all of the various examples above. OSHA, very reasonably, only requires training for the tasks that the worker performs. The degree of training shall be determined by the risk to the employee for the hazard involved.
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.”
A note to paragraph 1910.269(a)(2)(ii) states that a person must have the training required by paragraph (a)(2)(ii) to be considered a qualified person.
Another point to remember regarding training is found in 1910.269(a)(2)(v)(C). This rule sets out a training requirement for employees who are assigned to temporary tasks that necessitate safety-related skills not normally used during their regular job duties. It also sets out a requirement for retraining when the skills needed are employed less than once a year. So, this rule seems to require annual training on safety-related skills, but a very important aspect of the rule is the section on temporary assignments or tasks assigned that are not normally part of an employee’s regular job duties. This is quite a directive because it means that when assigning a task to an employee, consideration must be given to the emergency and rescue training required as well as the safety-related skills that must have been demonstrated to the employer. Your safety program training should have a procedure to ensure these requirements are addressed.
Other Training Considerations
OSHA provides a list of topics as well as information about when initial training and refresher classes should be performed. However, the list is an ambiguous one with ill-defined topics. For example, there is nothing specific to distribution coverup, system grounding or de-energizing for the protection of the employee. Essentially, the employer must determine when these topics are to be included in employee training.
It’s important to note that 1910.269(a)(2)(i)(C) states the “degree of training shall be determined by the risk to the employee for the hazard involved.” So, once the employer has determined the amount of risk, it should be compared to the requirements of the qualified worker definition found in 1910.269(a)(2).
All of this illustrates the amount of difficulty and accountability the employer faces to determine the level of qualifications an employee must be trained to. Paragraph 1910.269(a)(2)(i)(C) is interpreted by many to mean that an employee can be qualified to perform certain tasks, but they will never really be a qualified electrical worker as it was understood prior to the 2014 update to the 1910.269 standard.
Exceptions to the Two-Person Rule
Now, let’s get back to exceptions to the two-person rule, as it is sometimes referred to by employees and employers.
Paragraph 1910.269(l)(2)(ii)(A) regarding routine circuit switching is open for debate. The rule does not define the task as overhead or underground distribution or transmission.
Paragraph 1910.269(l)(2)(ii)(B) regarding work with live-line tools is the same – there is no definition of the system type or condition. Here, live parts are considered to be exposed conductors and equipment.
Paragraph 1910.269(l)(2)(ii)(C) is the least descriptive exception and loosely interpreted. It pertains to emergency repairs to safeguard the public. There is a reason for this rule, and most people believe it is permissible to ask a qualified worker to perform a task that may encroach on minimum approach distances of nominal system voltage greater than 600 volts if there is a public emergency. This sometimes happens in rural areas where additional qualified help may be many miles or hours away. In an emergency, a qualified worker may be permitted to clear a highway or other public area of downed conductors. Of course, if this exception is used, the employer must train the employee and manage the performance of the worker so that they safely perform the task.
Underground Padmount Transformers
While talking to utilities and contractors over the years, here’s another question that has come up: What tasks can a lone worker perform with underground padmount transformers?
In a survey I conducted of more than 50 investor-owned utilities, electric cooperatives, municipalities and contractors, the answers indicated a wide range of allowable tasks. Most companies surveyed said that it’s permissible for a lone worker to inspect padmount transformers prior to opening the lids or doors provided the appropriate PPE is worn. Once the doors are open, opinions begin to change. The vast majority of companies I surveyed allow a lone worker to switch insulated cables once the equipment has been inspected for any defective elbows or bushings. About 20% of those surveyed require a second qualified employee to switch cables. Thermography also is allowed by many to be a lone worker task. Approximately 75% of employers allow lone workers to install temporary or new permanent services with proper cover equipment installed on insulated elbows and bushings. Fewer than 10% do not allow a qualified lone worker to even open an underground padmount transformer.
There is much less confusion and difference of opinion when considering the lone worker and overhead distribution. Lone workers can perform tasks including switching in substations and even limb removal from a primary conductor that is de-energized and not grounded as long as minimum approach distance is maintained and no unprotected body parts encroach on the minimum approach distance.
In summary, some tasks can be performed by a lone qualified employee, while other tasks require more than one.
Per 1910.269(l)(2)(i), most tasks above 600 volts require at least two qualified employees. These tasks include installation, removal or repair of lines energized at more than 600 volts; installation, removal or repair of de-energized lines if an employee is exposed to contact with other parts energized at more than 600 volts; installation, removal or repair of equipment, such as transformers, capacitors and regulators, if an employee is exposed to contact with parts energized at more than 600 volts; work involving the use of mechanical equipment, other than insulated aerial lifts, near parts energized at more than 600 volts; and other work that exposes an employee to electrical hazards greater than or equal to the electrical hazards posed by operations listed specifically in paragraphs 1910.269(l)(2)(i)(A) through (l)(2)(i)(D).
Tasks that can be performed by a lone worker are described in 1910.269(l)(2)(ii). They include routine circuit switching, when the employer can demonstrate that conditions at the site allow safe performance of this work; work performed with live-line tools when the position of the employee is such that he or she is neither within reach of nor otherwise exposed to contact with energized parts; and emergency repairs to the extent necessary to safeguard the general public.
While certain OSHA task definitions are clear and precise, others allow for interpretation by the employer. Some of the largest utility and contractor companies have some of the most liberal interpretations of the lone worker rule. It is all about the amount of informed risk an employer is willing to accept. The competency and training of employees are key to determining that risk level.
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.