Voice of Experience: OSHA’s MAD Changes and a Missed Opportunity
In the 2014 OSHA update to 29 CFR 1910.269 and 1926 Subpart V, major changes were made regarding apparel and minimum approach distance (MAD) calculations. And yet I believe the agency missed an opportunity related to distribution voltages and gloving of energized conductors and equipment. For all intents and purposes, other than the MAD updates, few changes occurred in 29 CFR 1910.269(l) regarding working position. A new requirement removed any implied obligation that an employer is accountable for ensuring employees do not approach or take any conductive objects within the MADs found in tables 6 to 10 of 1910.269. The standard now clearly and without any doubt requires an employer to calculate and provide MADs to all employees and contractors working on energized systems.
Paragraph 1910.269(l)(3)(i) now states that the “employer shall establish minimum approach distances no less than the distances computed by Table R-3 for ac systems or Table R-8 for dc systems.” And the updated standard also now requires an engineering analysis on voltages greater than 72.5 kV to allow for transient overvoltages that occur due to system operations, breakers, capacitors or lightning. Ironically, the MAD found in the 2002 National Electrical Safety Code for 25-kV systems was 31 inches, 12 years before it was changed in OSHA’s update to 1910.269.
Gloving of Energized Conductors
I now want to turn the focus to gloving of energized conductors. The fact that the MAD only increased 1 inch for up to 15 kV and a little over 3 inches for up to 25 kV is interesting, but that’s not the missed opportunity I referred to at the beginning of this article.
Many employers have changed their safety rules to address MADs by setting a 5-foot rule or a 10-foot rule, obligating employees to wear rubber gloves and, in some cases, sleeves if they are within a specified distance of an energized or grounded object. Others require ground-to-ground climbing, cradle to cradle when using a bucket truck or lock to lock on underground residential distribution systems. All of these additional precautions exceed the basic minimums required by the 1910.269(l) performance-based standard. However, industry workers continue to suffer severe injuries and fatalities from burns and contacts, and they also continue to fail to maintain MADs. So far, 2016 doesn’t appear to be much better than past years, even with the new standard requirements now in place. Why? It directly relates to human performance, including subjective decision-making by employees in the field, and failure to follow training. But how about a failure to properly train workers?
This subject came up at a company where I once worked, after a series of terrible incidents consisting of contacts and flashes that resulted in severe injuries and some fatalities. A root-cause analysis, performed on all past accidents involving electrical contacts and flashes, revealed that worker training was a common denominator that spurred the company to inspect how its training programs were being presented. Then the company had to look at how the programs had been developed.
The foundation of the training was in the wording of 1910.269(l)(3) through (l)(5). In these paragraphs, OSHA emphasizes how important it is for the employee to protect himself from energized parts, conductors and equipment. The word “energized” appears 11 times. So logically, the training was focused on covering all energized parts with rated cover material. Even with the focus on energized parts, there continued to be flashes and contacts, which were totally unacceptable for the company I worked for. Partial covering, openings in cover and failure to apply enough cover were identified as parts of the problem.
One critical question is, how did the OSHA standard get written as it did? Even the 2014 update didn’t change much; “energized” was mentioned seven times in the 1994 version of 1910.269. The emphasis has always been on energized parts and equipment.
My understanding is that advisory committees used existing information found in many electric utility industry safety manuals to develop the agency’s 1994 standard. There were likely many safety manuals and years of experience gathered at the table, with members of the advisory committees making suggestions as to how a performance-based standard should be written and being careful not to prescribe work practices. So many different types of systems and construction practices make it difficult to mandate a particular safe work practice. Years ago, a lot of 4-kV energized gloving from the pole was common. System voltages have increased in an effort to deal with the additional loading of systems; primary voltages now range from 7.2 kV to 34.5 kV. Bucket trucks have increased the productivity and – in some people’s opinions – the safety of employees. The work practices of gloving from a pole had much influence on the wording of the OSHA standard. Those practices were transferred from the pole to the bucket truck.
An Executive Mandate
After the company I worked for suffered much loss, there was a mandate from the executive level to determine why our best trained and most qualified lineworkers continued to be involved in flash and contact accidents. My company gloved 4 kV, and now 12.4 kV and 25 kV are the standard for serving customers. The company had never gone more than three years and 10 months without a fatality, and at one time they had two fatalities in less than two weeks. Since implementing a revised cover program, however, there has not been a fatality due to poor cover-up in 20 years, with approximately 800 to 1,000 employees performing energized work each day.
Once the company engaged in much research and review, a remarkable omission from training was believed to be the problem. After all accidents had been analyzed, it was identified that almost every incident involved improperly covering differences of potentials and grounds.
Potential differences were mentioned only once in paragraph 1910.269(l) of the 1994 OSHA standard. There was no additional emphasis on second points of contact or paths of difference of potential.
When electric utility employees were gloving from the pole, there was no need to cover anything but energized parts and equipment. That was because when standing on the pole, the employee was the ground. Energized equipment had to be covered with rated cover equipment, and the body had to be positioned away from the covered equipment. Rated equipment is for incidental brush contact by a qualified employee. The original OSHA advisory committee that worked on the 1994 standard was influenced by the fact that much of the gloving was being performed from the pole. When aerial devices came along, nothing changed. The industry stepped into a bucket, allowing employees to get to work positions never before attained. Energized cover has never been as it should, and now, with path-to-ground exposure, a worker can get in series with ground; thus, contact and flash cases have increased.
The emphasis on proper distribution cover-up, including the path to ground, was not addressed in the 2014 update to 1910.269, and I feel this was a missed opportunity. If the industry put as much emphasis on path-to-ground cover as energized cover-up, I truly believe we would not continue to suffer cover-related losses.
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 is also an affiliate instructor at Georgia Tech Research Center OSHA Outreach in Atlanta. For more information, visit www.electricutilitysafety.com.