Switching and Tagging

Discipline is one of the many things that have served our industry well. Decades before OSHA was established by the Williams-Steiger Occupational Safety and Health Act of 1970, our industry already had disciplined procedures for switching, controlling and tagging circuits. When OSHA began to establish rules for the power-line industry, they recognized the superior discipline that utilities had employed in the control of hazardous energy and wrote into the standards those procedures that were being generally applied across the industry.

Readers can find OSHA’s hazardous energy control (i.e., lockout/tagout) procedures for generation facilities in 29 CFR 1910.269(d). In 1910.269(d)(1), OSHA explains that the standard is for the control of energy sources in installations for the purpose of electric power generation, including equipment for communication or metering.

Paragraph (m) of 1910.269, titled “Deenergizing lines and equipment for employee protection,” addresses locking and tagging procedures for the energizing of electric energy sources that are used exclusively for the purpose of transmission and distribution. Rule 1910.269(m)(1) states that the section applies to the de-energizing of transmission and distribution lines and equipment for the purpose of protecting employees. So, this section is the employer’s minimum guidance for the protection of employees when opening and closing switches and when energizing and de-energizing systems. How the employer accomplishes protection of the worker is entirely up to the employer, with some guidelines in place through 1910.269(m) and the National Electrical Safety Code.

Background
The Williams-Steiger OSH Act was signed into law by President Richard Nixon in 1970. OSHA – the agency itself – got off the ground around 1972. The 1972 standards included 1926 Subpart V. Over the following decade, there were many problems with the application of the Subpart V construction standard among operating utilities. OSHA published the final rule adopting 1910.269 in the general industry standard in 1994. No revisions to the switching and tagging standard were employed until the latest OSHA changes in 2014, with clarifications to some standards in 2015.

OSHA used material from the IEEE’s National Electrical Safety Code, also historically referred to by ANSI – the original developer of the standard – as ANSI-C2. It was originally part of an ASTM standard that was separated during this OSHA development period. OSHA adopted many of the C2 standard requirements from the 1984 and 1987 editions to develop much of the 1994 edition of the general industry 1910.269 standard. OSHA also considered proposed rules from Edison Electric Institute experts and from a panel of experts at the International Brotherhood of Electrical Workers. Those experts proposed their rules based on at-the-time practices already familiar and common to the industry.

Incident Prevention magazine’s “Train the Trainer 101” frequently refers to the value and importance of industry-related consensus standards to OSHA, and 1994 was no different. The agency heavily relied on the existing written consensus standards for their proposed rules. In the 1910.269-1994 preamble, OSHA wrote, “… the OSH Act requires the Agency to look to consensus standards for guidance in setting occupational safety standards.” Section 6(b)(8) of the OSH Act states, “Whenever a rule promulgated by the Secretary differs substantially from an existing national consensus standard, the Secretary shall, at the same time, publish in the Federal Register a statement of the reasons why the rule as adopted will better effectuate the purposes of this Act than the national consensus standard.” Thus, OSHA relies heavily on consensus standards in developing requirements for employee safety and health.

Contributing Factors
In the 1994 preamble to 1910.269, writing about effective switching and control, OSHA noted that there are several factors that have contributed to the utility industry’s successful use of tagout programs.

First, OSHA wrote, these notably successful companies had implemented detailed energy control procedures that were quite similar to those set forth in both the proposed and final lockout/tagout standard.

Second, they had established and utilized extensive training programs to teach their employees about their energy control procedures, including the use of tags and the importance of obeying them.

Third, these companies reinforced their training periodically. However, it is the fourth common element – discipline – that appeared to be the most critical to the success of these programs. Companies with effective tagout programs applied disciplinary action to both supervisors and employees who violated the tagout procedures.

OSHA believes that an effective tagout system needs all four of these elements to be successful. But it is discipline that is the most difficult to incorporate into a regulatory approach in the final rule. Not surprisingly, this also reflects the most serious limitation of tagout, which does not arise with lockout. Because a tagout program does not involve positive mechanical restraints on energy control devices, it requires constant vigilance to assure that tags are properly applied; that they remain affixed throughout the servicing and maintenance of equipment; and that no employee violates the tag by re-energizing the equipment, either intentionally or inadvertently, before the tag is removed.

Despite OSHA’s contention that the standards are performance-based, meaning “what the employer must accomplish,” the agency has been very particular in how electrical system control is to be facilitated. There are also referenced consensus standards regarding switching and tagging (see Appendix G to 1910.269), as well as Part 442 of the National Electrical Safety Code. The NESC, being an OSHA referenced consensus standard, does not have the force of law. That means a violation of an NESC rule cannot be the basis of a citation. However, if OSHA decides to cite an employer with a violation of the General Duty Clause, they often use phrases found in the consensus standards if they can show the employer knew or was aware of the protective nature provided by the particular consensus standard rule.

As a consultant and third-party investigator, I often find issues with switching and tagging programs, typically in the execution of switching orders and clearances. Those issues are usually found after a weakness in the program gets someone hurt. As you have often read in these “Train the Trainer 101” articles, rigor and discipline are the best ways to prevent incidents. “Rigor” means the policies and procedures, and “discipline” is the attitude that there is no other way to perform a task except in accordance with the correct policies and procedures.

Common Issues
Let’s wrap this up with a look at a few of the most common issues I see.

First, keep it as simple as possible. The more complex a procedure is, the harder it is to remember and follow. Some attempts at developing a bulletproof switching policy end up with too many layers of preapprovals and management signoffs followed by multiple tag colors that represent different departments. The basic requirement is two people: a system operator and a person authorized to order a line clearance. Start here.

Obviously, the more complex a system is, the more security, engineering and load management must be considered. Systems tend to get more complex as these diverse group responsibilities are added. When it comes to tags, there are two requirements found at 1910.269(m)(3)(v), which states, “Tags shall prohibit operation of the disconnecting means and shall indicate that employees are at work.” I have found tags with nine different written notations required on them. The issue is that most of the time, only two or three of those notations are filled in. If you are going to have a policy, make it simple, make it doable, and expect employees to do it the way it was designed.

Many employers require grounding of the de-energized bus before a clearance can be issued. There is no basis in compliance for that rule, and it creates a problem. If you have grounded as part of a switching order, consider whether you can remove grounds to perform testing without releasing the switching order – because you are changing the condition upon which the clearance order was issued. The issue is usually due to a misreading of the standard.

Paragraph 1910.269(m)(3)(vii) states, “The employer shall ensure the installation of protective grounds as required by paragraph (n) of this section.” Paragraph (n) does not require grounds as the only mode of work. Paragraph (n)(2) establishes the characteristics of isolation of circuits for protection of the worker.

Per 1910.269(m)(3)(x), releasing a clearance includes removing grounds and notifying the system operator that the conditions for releasing the clearance have been met, including having removed grounds. To keep it simple, I suggest that a switching order establish isolation of the circuit and then authorize the clearance for crew control of the isolated circuit. The policy would be that the crew who owns the clearance decides which work mode will be used, either isolation or EPZ grounding after testing and verifying the absence of circuit voltage or induced voltage hazards.

The last issue – ownership of the clearance – often comes up with contractors when a utility won’t allow a contractor to hold a clearance. Rule 1910.269(m)(3)(ix) requires that the clearance holder be on-site and in control of the clearance. The standard is very specific about being on-site and transferring the clearance if the holder must leave the work area.

A Final Reminder
I spent some time at the beginning of this article discussing the history of the power-line industry’s switching procedures and their effectiveness. I cited what OSHA had discovered, and I will end here with a reminder of what makes our switching and tagging effective:

• A well-written policy guided by OSHA 1910.269(m) and Part 442 of the NESC.
• Extensive training for personnel. Remember that even the most well-written program is only as good as the training you do when you roll it out.
• Periodic review of the effectiveness of the program and supplemental training opportunities.
• Accountability across management, supervision and operators regarding the proper implementation of the policy. Rigor and discipline: Make them part of your safety culture.

About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn, CUSP, has devoted the last 27 years to safety and training. A noted author, trainer and lecturer, he is a senior consultant for the Institute for Safety in Powerline Construction. He can be reached at jim@ispconline.com.