Tag: ppe


FR/AR Clothing Considerations During the COVID-19 Pandemic

In 29 CFR 1910.132, OSHA clearly states that personal protective equipment and appropriate training are required for individuals working in utilities, electrical petroleum, oil and gas exploration, and other industries where there is a danger of being injured by arc flash or flash fire. This entry is part 3 of 7 in the series APRIL-MAY 2021

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Arc Rating Standards for Personal Protective Equipment

Employees who interact with electrical equipment and electrical installations may be exposed to electrical shock and arc flash hazards. A previous two-part article titled “Arc Flash Considerations for Utility and Construction Activities” (see https://incident-prevention.com/blog/arc-flash-considerations-for-utility-and-construction-activities and https://incident-prevention.com/blog/arc-flash-considerations-for-utility-and-construction-activities-part-ii) discussed the electrical hazard identification and risk assessment. If the employer has taken steps to reduce the risk of injury or death...

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Understanding, Selecting and Caring for FR/AR Clothing

When the original version of the OSHA 29 CFR 1910.269 standard was published in the 1990s, flame-resistant (FR) and arc-rated (AR) clothing weren’t even mentioned. The dangers associated with electric arcs were known at the time, but the standard only required that an employer not allow an employee to wear clothing that, when exposed to flames or electric arcs, could increase the extent of injury sustained by the employee. This eliminated use of garments constructed with synthetic materials – such as polyester, nylon, rayon and acetate – so the default was for employees to wear clothing made...

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The Hard Hat Celebrates 100 Years

When you think of people who have changed our lives with their inventions, you may think about Thomas Edison and his lightbulb or Alexander Graham Bell and his telephone. Not many of us would think to include Edward W. Bullard on that list, but 100 years ago – in 1919 – he invented the hard hat, which today is one of the most recognized safety products in the world and is responsible for saving thousands of lives over the past century. To truly trace the heritage of the hard hat, we have to go back even further to 1898, when Edward Dickinson Bullard founded E.D. Bullard Co. in San Francisco....

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Rubber Insulating Sleeves and Arc Flash Protection

Rubber insulating sleeves are commonly worn with dielectric gloves in high-voltage applications to provide added insulation from electrical contact for those working on energized equipment. The rubber insulating gloves and rubber insulating sleeves are worn for shock protection; sleeves typically are worn with rubber insulating gloves when the arm can cross the minimum approach distance or the restricted approach boundary. A protector glove typically is used for arc flash protection and for mechanical protection of the rubber insulating glove, but this over-glove does not protect the entire...

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Scenario-Based Fall Protection Solutions

At least once in their career, nearly every safety worker in the utility business has been – or will be – faced with the need to use fall protection in an area where there is no place to tie off. In my role as a safety technician, I work with personnel in both generation and transmission business units; fall protection is needed in this line of work, but I have found that anchorage points can sometimes be few and far between. It’s a problem that clearly needs to be solved, and in this article I will share what my company has done to provide scenario-based solutions. Scenario OneDuring an outage...

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Secondary FR Garments: Practical Solutions for Protection

Cleanup of potentially hazardous materials and flammable contaminants can sometimes be a part of an electrical job. When workers arrive on a scene, they cannot always be sure of the exposures or contaminants they will face. In electrical work, it could be oil that contains a small number of PCBs. This oil, and other contaminants, is flammable and can affect the flame-resistant properties of garments until it is washed from the garments. Working around flammable contaminants, as well as flame and thermal hazards like arc flash potentials and flash fire potentials, often requires a PPE safety...

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Making Sense of Protection Requirements for Open-Air Arc Flash Hazards

Electric utility workers face complex, high-risk electrical hazards nearly every day. Information about shock hazards – which may come from impressed voltage, residual energy, induction, objectionable current flow in a grounding system or stored energy – has been taught to many of us for quite some time, as have the methods of assessing them. On the other hand, arc flash hazard assessments are still relatively new to us. In the past, most of us knew that an arc flash could potentially occur during the course of performing our tasks, but the level of the flash and the PPE requirements...

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Injury Risks Associated with Climbing in the Wind Energy Generation Industry

The growth of the wind energy generation industry in the U.S. has been phenomenal. According to the American Wind Energy Association, at the end of 2016 there were over 52,000 utility-grade wind turbines operational in more than 40 states, with a total capacity of 83,000 megawatts. The Global Wind Energy Council’s latest report shows that the U.S. has the second-largest wind power capacity, after China, with 16.9 percent of the world total, and employs over 100,000 people directly or indirectly. As the number of wind turbine towers grows, so does the number of people involved in their...

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Train the Trainer 101: Training and Verification Requirements for the Safety of Electric Utility Workers

A number of years ago I investigated a pole-top flash that took place during a transfer. The flash occurred when an improperly installed blanket left a dead-end flange exposed on the backside of the metal pole-top. During untying, the tie-wire contacted the exposed flange. No one was hurt. The issue was the lineman’s selection and installation of the blanket. The foreman assumed the lineman was experienced and competent to perform the three-phase transfer with minimal instruction. The problem was the lineman had spent the last several years on a service truck, had little transfer experience...

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Train the Trainer 101: Addressing Common Fall Protection Questions and Concerns

To begin this article, I want to offer a disclaimer. One of the reasons the “Train the Trainer 101” series was created is to examine the practical aspects of compliance as they relate to the utility industry. We do that by reading the statutes, looking at how OSHA interprets and enforces the rules, reviewing what the consensus standards state and then determining practical ways the employer can manage and comply with the rules. Sometimes I raise an eyebrow, but in working with the group of professionals who review every article published in Incident Prevention’s pages, we endeavor to ensure...

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April 2017 Q&A

Q: Our plant safety committee has a longtime rule requiring electrical hazard safety shoes for our electricians. We were recently told by an auditor that we have to pay for those shoes if we require employees to wear them. We found the OSHA rule requiring payment, but now we wonder if we are really required to use the shoes. Can you help us figure it out? A: Sure, we can help. But first, please note that Incident Prevention and the consultants who have reviewed this Q&A are not criticizing a rule or recommending a rule change for any employer. What we do in these pages is explain background,...

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Maximizing Your Arc-Rated Gear

When designing your PPE program, how do you know which option will work best for your application? How can you get the most for your money? How can you get no-cheating compliance from your workers? With so many arc-rated (AR) and flame-resistant (FR) PPE products on the market, it can be difficult for a utility or utility contractor to make a sound decision. To start, complete an analysis to determine hazard levels, as well as the workers who will be exposed. Application, comfort and cost should be considered when deciding on the best product to purchase. In this article, we will help you see...

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Train the Trainer 101: The New Walking-Working Surfaces Final Rule

OSHA’s final rule on 29 CFR 1910 Subpart D, “Walking-Working Surfaces,” is finally here. It’s 26 pages of nine-point font equaling 21,675 words, and I read them all. It’s big, and if you include the preamble in your analysis, it is also complicated. It was just as hard to write about as it was to read. I guess that shouldn’t be unexpected for a final rule that has been in the works since 1983. The original 1910 Subpart D was published in 1971. The first update was proposed in 1983, but it was never ratified. Proposals were again considered in either the Construction standard or the General Industry...

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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...

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Best Practices for Arc-Rated Clothing Programs

Many things have changed since 1994, when the first hint of arc-rated (AR) materials hit the utilities. Back then, the best practice was to wear cotton jeans, heavy cotton shirts and heavy cotton-shell winter wear. Other personal protective equipment (PPE) like rainwear illustrated an industry problem: There were not many good flame-resistant (FR) clothing options available. At the time, the only markets for FR garments were military, aviation and refineries. Non-melting rainwear was not really on the market since most “FR” rainwear at that time was made of nylon or polyester, which means it...

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Voice of Experience: Hand and Skin Protection for Electric Utility Workers

With the recent changes to the OSHA standard, many employers are working on what rules apply – the arc flash standard or the PPE standard – and how to comply with them. Part of the issue is determining how many types of protection are needed and what types of protection are appropriate. To begin, OSHA’s requirements for all personal protective equipment can be found in 29 CFR 1910 Subpart I. Rules specific to hand protection can be found in 1910.138. They read as follows: 1910.138(a)“General requirements. Employers shall select and require employees to use appropriate hand protection when employees’...

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February 2016 Q&A

Q: I work for a small utility and am new to my safety role. Recently I have been wading through the Federal Motor Carrier Safety Regulations (FMCSR) in an attempt to understand my responsibilities with regard to testing CDL drivers. Can you briefly explain these responsibilities? A: FMCSR 391.31 requires the employer to ensure a driver is competent by means of road testing. The FMCSR allows a valid commercial driver’s license as evidence of competency (see FMCSR 391.33). If the employer accepts the evidence of the driver’s competency, the employer does not have to road test the driver. Rule...

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Voice of Experience: PPE Regulatory and Consensus Standard Requirements

OSHA 29 CFR 1910 Subpart I and 1926 Subpart E cover the requirements of personal protective and lifesaving equipment. With the publication of OSHA’s final rule in April 2014, the general industry and construction standards are now essentially the same for electric utilities, and there are few if any differences in the PPE required by each standard. In addition to OSHA’s regulatory standards, there are ANSI/ASTM and other consensus standards that govern the manufacturing, type and ratings for all PPE. These consensus standards change as the industry evolves and PPE improves. All PPE should meet...

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Train the Trainer 101: Practical MAD and Arc Flash Protection

Author’s Note: Before we get to the article, I want to thank the members of Incident Prevention’s editorial advisory board for their help in assembling this installment of “Train the Trainer 101.” They help me keep my head on straight, especially when I have ideas that are way outside the box. Even though I am also on the board, they still hold me to high standards of accountability and accuracy. These folks are a great asset to iP and make better writers of everyone who contributes to the publication. Over the past year, iP subject matter experts have fielded many questions about how to meet...

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N95 Filtering Face Pieces: Where Does Your Organization Stand?

When it comes to following health and safety standards, nearly every worker tries to do the right thing. And when workers deviate from standards and best practices, it is typically due to lack of knowledge and proper training. One industry topic that is not yet fully understood and continues to be heavily debated is the N95 filtering face piece, in particular its uses and program requirements. In response, this article seeks to assist those who are involved with the development and enforcement of their organization’s voluntary respiratory protection policy. To begin, there are two reasons why...

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Arc Flash Mitigating Technologies and the OSHA Final Rule

On April 11, 2014, OSHA issued the final rule regarding 29 CFR 1910.269 and 1926 Subpart V. The final rule included modifications that address minimum approach distances, fall protection systems and hazards of electric arcs. Since the publication of the rule, there have been an extensive number of articles published that detail changes to 1910.269 and 1926 Subpart V. Those articles focus on explaining the changes but most lack information about arc flash mitigating technologies. This article focuses on current technologies available to minimize and prevent exposure of workers to arc flashes....

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How to Navigate the FR Clothing Marketplace

When the original version of the OSHA 1910.269 standard was published, flame-resistant (FR) clothing wasn’t even mentioned. The dangers associated with electric arcs were known, but the standard only required that an employer not allow an employee to wear clothing that, when exposed to flames or electric arcs, could increase the extent of injury sustained by the employee. This was covered under 1910.269(l)(6)(iii). The rule eliminated the use of garments constructed with synthetics such as polyester, nylon, rayon and acetate, which could melt and drip, and led to the adoption of clothing made...

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Train the Trainer 101: Back to Basics: ‘Gentlemen, This is a Football’

I recently spent several weeks studying an incident, trying to understand how it had happened and – more importantly – how it could have been prevented. Maybe the answer was associated with human performance, or maybe culture, or it could have been procedures, or … well, maybe it could have been associated with any number of things. In other words, even with all of my experience and training, I had a hard time finding the singular root cause. This dilemma made me recall a question I missed on an engineer-in-training exam I took in the 1970s. The question had ladder diagrams and loop schematics...

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Voice of Experience: Fundamentals of Underground Padmount Transformers

In recent months Incident Prevention has received several questions about underground (UD) padmount transformers, so in this installment of “Voice of Experience,” I’d like to take the time to cover the general aspects of these types of transformers. To begin, there are a few different types of single-phase and three-phase UD padmounts: live front with exposed live primary parts, 600-amp bolt-on elbows and loop feed with bushings and elbows. All of these transformers are available in several voltage ranges. The proper PPE must be worn when an employee is opening, entering and working on energized...

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June 2015 Q&A

Q: Are there any changes to steel-toe boot requirements for lineworkers in the recently revised OSHA 1910.269 standard? A: OSHA still leaves it to employers to decide whether hard-toe or protective footwear is required. As with all other PPE, the decision should be made based on risks and history. Wearing safety footwear is not required by the PPE rule. However, what is required in OSHA 29 CFR 1910.136, “Foot protection,” is a mandatory assessment of the work environment. The rule states that the employer “shall ensure that each affected employee uses protective footwear when working in areas...

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The Roller-Coaster Life Cycle of IEEE 1307

IEEE 1307 is a little-known work group that is part of a larger IEEE subcommittee known as ESMOL, which stands for Engineering in the Safety, Maintenance and Operation of Lines. Both IEEE 1307 and ESMOL fall under the umbrella of the IEEE Transmission and Distribution Committee. IEEE 1307 is also the title of a utility fall protection consensus standard that has existed since the early 1990s. In light of the recent OSHA changes to fall protection, it seems appropriate to spread the knowledge about this industry standard. In the BeginningIn the early 1990s it became apparent that falls were...

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The Importance of Matching Evidence Marks in Accident Investigations

I have personally investigated more than 800 incidents involving serious permanent injury, death, equipment failure and structural failure. Time after time, we were pulled in late to assist with investigations in which early investigators had failed to properly investigate the incidents. They had jumped to erroneous conclusions, thus resulting in incorrect admissions, strategies or other actions in the related litigations. When properly analyzed, each incident was shown to have occurred differently than originally assumed, and often a different party or action was the precipitative cause. Finding...

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Recent PPE Changes and 2015 Trends

2014 was a year of changes in electrical safety. The new OSHA 29 CFR 1910.269 standard has moved arc-rated (AR) clothing and PPE to the forefront, unlike the 1994 changes. Additionally, for facilities covered by NFPA 70E, the new 70E standard has added a level of complexity to PPE. This article will review changes in PPE as well as trends to expect this year. NFPA 70E ChangesIn the 2015 edition of NFPA 70E, the term “Hazard Risk Category” (HRC) has been replaced by “PPE level” or “arc rated PPE category” (ARC). As a result, manufacturers may start using “ARC” instead of “HRC” on labels to indicate...

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Train the Trainer 101: Addressing Anchorages

With the new OSHA 29 CFR 1910.269 rules have come many questions, and one that Incident Prevention often receives is how to define an appropriate anchorage. There will be forthcoming interpretations as employers ask questions of OSHA, but the April 4, 2014 preamble, or “Summary and Explanation of the Final Rule,” does provide a good basis for interpreting the rules. You can read the preamble at www.osha.gov/dsg/power_generation/. Concerning anchorages, most everyone can quote the two most familiar longstanding requirements: a minimum tensile load of 3,000 pounds for lifelines or lanyards that...

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Voice of Experience: The Importance of Job Briefings

As I write this article, I am reflecting on 2014 and thinking about how many contacts and fatalities the electric utility industry suffered last year. There were fewer than in 2013, but the improvement was only slight. At present, the most accurate count for 2014 is approximately 40 fatalities and 45-50 electrical contacts. One serious injury or fatality is too many, and all of them can be avoided by planning and the proper use of training, tools, time and teamwork. As I read reports of 2014’s fatalities and serious injuries, I wondered how thoroughly job briefings were performed before these...

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February 2015 Q&A

Q: The issue of multiple snaphooks in a single D-ring and Incident Prevention’s stance on it have received a lot of attention, and we are pleased to address this topic once more in the Q&A section. A: iP received two notable responses to our guidance regarding manufacturer approvals and OSHA’s requirement that prohibits the use of two snaphooks in a single D-ring unless (1) the snaphook is a locking type and (2) the snaphook is specifically designed for certain connections. As readers may recall from the December 2014 Q&A (see https://incident-prevention.com/blog/december-2014-q-a),...

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Train the Trainer 101: Substation Entry Policies

Every utility and every contractor that works for a utility should have a substation entry training program. These programs are primarily written for non-electrically qualified workers, but there are many line personnel who do not have substation training or who do not understand the risks inherent in a substation. Hazard awareness training for substation entry is necessary for anyone who enters electrical substations to perform work tasks. Following are some recommendations for the type of content that might be appropriate for an entry awareness program. This material may not be all-inclusive...

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December 2014 Q&A

Q: In regard to work boots and arc flash protection, what does OSHA mean by “heavy-duty work shoes or boots” in 29 CFR 1910.269(l)(8)(v)(B)? Are boots made of synthetic material acceptable if they are work boots? A: As with all OSHA rules, it is up to the employer to understand the risks and the necessary protections. In many cases the consensus standards give guidance that can be used to satisfy the OSHA standard. Even though NFPA 70E exempts utilities, OSHA has clearly used the NFPA as a source of material to assist utility employers in protecting employees, and the clothing standards in 70E...

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Voice of Experience: Flame-Resistant Apparel is Now PPE

It’s official: Flame-resistant clothing is now considered PPE, and employers are required to furnish it to employees when there is a chance that they may be exposed to electric arcs or flames. This change has been a long time coming as the industry has been in limbo for years. A number of forward-thinking companies have been furnishing arc-rated FR clothing to their employees for some time, while others have waited for regulations to require them to do so. The company from which I retired as well as other large investor-owned utilities have uniform policies that incorporated arc-rated FR clothing...

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October 2014 Q&A

Q: I can’t seem to clarify what U.S. Department of Transportation hours-of-service rules apply to utility workers. Are we exempt from the rules? A: The university studies and experience of the Federal Motor Carrier Safety Administration that prompted the hours-of-service rules do have some value to us as an industry with drivers. The data used to form the rules shows that fatigue affects performance. This is a model that can help us to establish safe practices with our drivers. However, there is good reasoning for exemptions when the work we do ensures electrical service for users that...

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Train the Trainer 101: Fall Protection and the New Rule

With the publication of OSHA’s new final rule regarding 29 CFR 1910.269 and 1926 Subpart V, the fall protection rules have changed – somewhat. Both the general and construction industries have had fall protection rules in place since the advent of workplace safety rules, including the duty to have fall protection found in 1926.501. However, provisions specific to the industry have enabled utilities and their contractors to operate under fall protection exemptions for poles and similar structures. That is no longer the case. Before we go any further, there is a basic premise every safety manager...

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Voice of Experience: OSHA Eye and Face Protection Standards

In this installment of “Voice of Experience,” we will take a look at the wording in OSHA 29 CFR 1910.133, “Eye and face protection.” A review of this standard is a great opportunity to gain a better understanding of what OSHA requires of both the employer and employee in order to properly protect these vital body parts in the workplace. The standard begins with general requirements. Rule 1910.133(a)(1) states, “The employer shall ensure that each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals,...

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NFPA 70E Arc Flash Protection for Nonexempt Industry Workers

Editor’s Note: As defined in the scope of NFPA 70E, electric utilities, with the exception of certain commercial electrical installations, are exempt from the standard. If, as a safety professional, you have installations covered under OSHA 29 CFR 1910 Subpart S, “Electrical,” you are subject to NFPA 70E. In the recently published 1910.269 and 1926 Subpart V final rule, OSHA prominently mentions NFPA 70E as a beneficial informational resource for employers regarding arc flash programs. NFPA 70E is referred to numerous times throughout the final rule’s preamble, demonstrating that even as an...

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June 2014 Q&A

Q: Can you help us with regard to fall protection practices while working on top of a roof or in areas near substation transformers? We are aware of the exceptions for qualified climbers in OSHA 29 CFR 1910.269. How does that affect us? A: Most utilities will tell you that they don’t require fall protection to work a weatherhead on a roof. Many have no fall protection requirements or programs for working on top of transformers. I am aware that some utilities use the definition of a working surface issued by OSHA – at least once every two weeks or for a total of four man-hours or more during...

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Addressing Comfort and Contamination in Arc-Rated Clothing

With the revised OSHA 29 CFR 1910.269 standard slated to soon be released, the last utility companies holding out on moving to arc-rated clothing will soon be compelled to do so as a matter of law. The new standard is likely to have the same language as the National Electrical Safety Code (NESC) and will require arc flash calculations for both primary and secondary voltages. NESC 2007 excluded secondary voltages, but the 2012 edition includes a requirement to perform arc flash calculations and does not discriminate against primary or secondary voltages. To follow calculations per the updated...

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Transitioning to FR Clothing

Since Tacoma Power’s creation in the 1890s, its employees have worked on or around energized conductors and have been exposed to the hazards of electrical arcs and flames. For most of that time, electrical workers wore natural fiber clothing to reduce the risk of injury if involved in a situation that could result in an arc flash. Injuries from burning clothing can lead to permanent disabilities and death. The utility launched a project in 2009 to transition to protective clothing that would provide an even greater level of protection. Flame-resistant (FR) clothing promised a much higher level...

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Keys to Evaluating and Comparing Arc-Rated and Flame-Resistant Fabrics

When determining what type of protective clothing to purchase, the first thing specified by a significant number of safety professionals is the flame-resistant (FR) or arc-rated fabric brand. The number, type and source of these fabrics have expanded dramatically in the last few years as new offerings chase profits in an expanding market. There have also recently been significant failures, making it more critical than ever to thoroughly research and select trusted, market-proven brands. These failures can occur on several levels; one recent issue involved the failure of a fabric to be flame...

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FR Layering Techniques

With new revisions to the National Electrical Safety Code (NESC), many electric utilities and contractors are discovering that a standard HRC 2 program is no longer adequate. Numerous companies are now turning to layering of flame-resistant (FR) garments to achieve the required levels of protection. Well-designed, well-managed layering programs will increase worker safety and comfort. This article will discuss why layering is important and how to ensure that your layering program works. What Does NESC 2012 Require? Although the NESC is rather brief in its discussion of FR clothing, Section...

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Back to the Basics: PPE 101

Have you ever noticed that management likes to show up to monitor the helicopter operations? Doesn’t it seem like all the attention is paid to helicopters, stringing operations and setting 500 kV transformers? Does the same crowd show up when one of your workers is trimming trees on the right-of-way (ROW) without a face shield or chaps? Or when someone is wearing an unbuttoned FR shirt with the sleeves rolled up? How about when you climb into a vault with an attendant that’s too busy texting his girlfriend to make sure that your air monitor was calibrated recently? I’ve often wondered why people...

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Five PPE Safety Challenges

In 2012, both NFPA 70E and the NESC will change personal protective equipment (PPE) and give guidance to utilities and industrial electrical workers that they haven’t previously had. Under NESC 2007, low-voltage (LV) work in utilities had only basic coverage. If 4 cal/cm² arc flash PPE clothing was worn, the company was in compliance. There was no requirement to do an arc flash assessment if 4 cal/cm² clothing was used. The new NESC will require calculations or the use of new tables even for LV work. The tables in NESC are arc flash calculation tables that give a range of energy levels for...

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Solid Footing

In a few years I’ll be 60. I’ve been in the business now for 37 years, but no one ever talked to me about how to care for my feet until I finally had to go to a podiatrist a few years ago. When he looked at my X-rays he said, quite confidently, “You are a lineman right?” It seems he had seen the picture several times before. The bones and connecting tissue and ligaments that make up your feet and legs, as it turns out, are fairly malleable. For the first 20 years of my career, I worked in an older city area where just about every distribution pole was in a backyard, so I climbed almost every...

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Arc Suppression Blanket Installation

Use of arc suppression blankets can help reduce arc flash/blast injuries. When properly installed, arc suppression blankets absorb or deflect heat and blast energy emitted from an arc event, reducing the event’s impact on workers. Proper understanding of the elements involved in an arc flash is key to designing an installation. Heat is a major factor in an arc flash/blast event. Because of the intense heat generated in both radiation (ultraviolet and infrared) and the plasma arc (large fireball that can reach several thousand degrees), protection from this heat is the most important factor. An...

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