Tag: Voice of Experience

Planning for Storm Work

Written by Danny Raines, CUSP on April 17, 2023. Posted in Voice of Experience.

The strength and magnitude of a storm should determine our methods to address it. But long before a significant event occurs, a plan to restore power safely should be made by the host company. I learned during my early days as a supervisor that a storm evaluation and restoration plan is of great value to prepare everyone for “the big one.” Everyday storms and outages can be handled locally with a single point of command and control from the system operations center. However, when a stronger, more widespread storm occurs, local and area supervision may be a better and more organized method. The...

Arc Flash Precautions: A Review

Written by Danny Raines, CUSP on February 18, 2023. Posted in Voice of Experience.

David McPeak hosts the Incident Prevention Institute Forum (https://ip-institute.com/ipi-forum/) once a month. I often take part as a panelist, helping to answer questions posed by forum attendees. During a recent forum, topics ranged from fleet mechanics to arc flash exposures and required personal protective equipment. I decided I’d dedicate this installment of “Voice of Experience” to arc flash hazards by reviewing some of the minimum precautions that employers and employees should take as well as what the regulations require.

Ground Gradient Step Potential and PPE

Written by Danny Raines, CUSP on December 16, 2022. Posted in Voice of Experience.

For various reasons, ground gradient step potential hazards are not always considered or thought to be important. I recently received a call from a large investor-owned utility whose employees had differing opinions about using super dielectric overshoes or work boots when setting a pole in an energized line. Some people are of the opinion that if you cover up the lines with a nominal voltage-rated cover, there is no danger of an energized pole and therefore no chance of ground gradient step potential. The manufacturer’s usage suggestion for any cover is for incidental brush contact by a qualified...

The Importance of Proper Coverup: Two Real-Life Tales

Written by Danny Raines, CUSP on September 29, 2022. Posted in Voice of Experience.

Very early on in my career as a lineman, I was involved in two events that taught me some important lessons about proper coverup and how critical it is to worker safety. Both events occurred between 1972 and 1973. I was working on a big line crew, and while there were different crew foremen, there was one foreman in particular who we all thought was one of the best to work for. His name was John Lane, and he’d been a lineman before I started with the company in 1967. I worked with him as an apprentice on a cut-in truck that he referred to as “South Macon Power and Light.” John was the most likable...

The End of a Career

Written by Danny Raines, CUSP on February 23, 2022. Posted in Voice of Experience.

I have been working in the electric utility business as a lineman, supervisor and safety training consultant for a very long time. I am at the point where I am ready to fade away like a light fog on an early summer morning. I dearly love the work, and I have the greatest respect for the utility employees who are doing the work. But it is time for me to say goodbye to the industry, enjoy my retirement, and spend time with my grandchildren and other family. My career in this industry started in 1967 in Macon, Georgia, when I was hired as a helper on a line crew. I progressed from journeyman all...

Installing Fiber-Optic Cable in Electric Supply Spaces

Written by Danny Raines, CUSP on December 13, 2021. Posted in Voice of Experience.

Based on recent social media comments I’ve seen, questions submitted to Incident Prevention magazine and inquiries I’ve personally received, this installment of “Voice of Experience” is going to focus on OSHA and National Electrical Safety Code issues regarding the installation of fiber-optic cable in electric supply spaces, including who is allowed to perform the work. So, which standards are in question and what qualifications must employees have? For starters, fiber optics is considered a communications conductor – not “supply” as referred to in the NESC. The installation and maintenance...

System Grounding for Worker Protection Against Induced Voltages

Written by Danny Raines, CUSP on October 4, 2021. Posted in Voice of Experience.

In the last installment of “Voice of Experience,” we reviewed OSHA’s rules for transmission and distribution (T&D) equipment grounding. This time around, we are going to discuss where and how induced voltages occur and, more importantly, how to protect employees from hazards associated with induced voltages via proper system grounding. “It’s not dead until it’s grounded” is one of the oldest and most inaccurate statements made in our industry. It’s also one of the first things I was ever told when I started working for Georgia Power in 1967 as a helper on a line crew. Many years passed before...

Understanding OSHA’s Rules for T&D Equipment Grounding

Written by Danny Raines, CUSP on August 11, 2021. Posted in Voice of Experience.

There seems to be a question of the month every month. Recently I’ve answered a lot of questions about when and how to ground distribution and transmission equipment, particularly bucket trucks, uninsulated line trucks and cranes. My standard response to those questions is, “What is required by the OSHA regulations?” I know some people do not like to attempt to read the regulations and interpret their intent, so in this installation of “Voice of Experience,” I’m going to review OSHA 29 CFR 1910.269(p), “Mechanical equipment,” which addresses equipment grounding. Specifically, 1910.269(p)(4)(iii)...

Overhead Line Work, Then and Now

Written by Danny Raines, CUSP on May 21, 2021. Posted in Voice of Experience.

Overhead line work requires much planning beforehand and total attention when it is being performed. Recently I’ve had several requests to discuss this kind of work, so I’m going to take you back to the days when I was a lineman and, later, a crew supervisor to aid in this discussion of overhead jobs. When I first became a lineman in 1972, I was hired as a helper on a line crew. The job was trial by fire in those days. There was so much material to learn, but there wasn’t much in the way of training schools back then – almost all of my training was of the on-the-job variety. Lineworkers would...

System Operations: Who’s in Charge?

Written by Danny Raines, CUSP on April 15, 2021. Posted in Voice of Experience.

System and utility operators are required by OSHA 29 CFR 1910.269(m) to have a procedure to de-energize their systems for protection of the employees working on those systems. The rules in 1910.269(m) do not specifically require a written procedure, but it is hard to imagine how an effective procedure could be maintained if it weren’t written. Unlike lockout/tagout, we refer to these programs as switching and tagging. Switching and tagging apply to transmission and distribution, including substations. The 1910.269 standard has a paragraph (d)(2) on energy control procedures for power plants...

Sharing My Story: I’m a Male Breast Cancer Survivor

Written by Danny Raines, CUSP on February 12, 2021. Posted in Voice of Experience.

It was a beautiful October day in Captiva Island, Florida, where my family and I were on a short vacation at the end of the summer season. I was in a room of the condo we had rented. Housekeeping had recently damp-mopped the tile floor in the room, and as I walked across it, I slipped and took a fall that resulted in a concussion after my head hit the tile. Thankfully, the concussion was minor, the embarrassment of the fall was short-lived, and my bruises healed quickly. While assessing my injuries, however, I found a mass on the left side of my chest that seemed odd to me. Thinking it was an...

Lone Worker Limitations

Written by Danny Raines, CUSP on December 11, 2020. Posted in Voice of Experience.

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...

Inspect and Test to Prevent Wood Poles from Falling

Written by Danny Raines, CUSP on October 7, 2020. Posted in Voice of Experience.

It happens every so often – and more often than it should. A lineworker climbs a wood pole and the pole falls. With the advent of 100% fall protection, the climber is assured serious injury and often death if a pole falls while they are tied to it. Several of these types of incidents have occurred in recent months. The first question is, why didn’t those poles get checked before anyone climbed them? The next question is, what can we do to prevent future falls? Correct Depth is KeyFirst and foremost, correct depth is what keeps a pole in the air. Most companies have a specification that determines...

Is it Maintenance or Construction?

Written by Danny Raines, CUSP on August 18, 2020. Posted in Voice of Experience.

Is it maintenance or construction? That’s a question that was asked regularly by industry workers for many years. These days, we can thank David Wallis and the committee members who diligently worked on the OSHA 29 CFR 1910.269 and 1926 Subpart V final rule published in 2014 for clearing things up. To better understand the value of the final rule, let’s review some brief history of the two standards. In 1972, the construction standard for building transmission and distribution systems was completed. Did you notice there was no mention of generation in that standard? We will address that shortly....

Opinion: Looking to the Future During an Unprecedented Time

Written by Danny Raines, CUSP on June 16, 2020. Posted in Voice of Experience.

As I sit and write this article, I’m also gazing into my crystal ball, so to speak. I realize that life as we knew it just a few short months ago has changed. COVID-19 has made its way around the world and we are now working during an unprecedented time. Utilities have been designated as essential services, requiring employees to continue working as normally as possible, but with the pandemic in the background each day, I think it’s safe to say we are establishing a new normal. Back in the 1990s, I worked with an executive who once said, “Normal will never come back.” He was referring to...

Voice of Experience: The Need for Seasoned Industry Trainers

Written by Danny Raines, CUSP on April 13, 2020. Posted in Voice of Experience.

Providing accurate, effective training to workers is one of the electric utility industry’s most pressing challenges. From my perspective, there are not enough appropriately qualified trainers to fill the open jobs available. As our industry’s attrition rate continues to increase, will we be able to provide the right training to new and existing employees? Each day, there are lineworkers being given work to do for which they are not adequately trained, endangering them and their co-workers. We need trainers to help correct this problem so that fewer lineworkers are hurt on the job. I mentioned...

Voice of Experience: Human Performance Failures

Written by Danny Raines, CUSP on February 19, 2020. Posted in Voice of Experience.

I find human performance a fascinating topic to teach during my supervisor training classes. Many readers of Incident Prevention are familiar with the topic. For those who aren’t, human performance is an analytical tool that examines how people accomplish tasks and why they perform those tasks in a particular way. Employees in the electric utility industry execute many of the same tasks each day. We do them according to the local culture’s work practices, primarily learned through on-the-job training. As older workers retire and new employees join the ranks, those work practices are passed down...

Voice of Experience: Accurate Utility Locates are Critical to Crew Safety

Written by Danny Raines, CUSP on December 13, 2019. Posted in Voice of Experience.

Each time I present an OSHA training class to electric utility workers, the topic of utility locates arises. That’s because, other than utility locates being a legal requirement in most states, it is critical for line crews to have up-to-date locates for their own safety. When locates are not in place, it’s more than just a possibility that an employer will face OSHA citations and other legal liabilities in the event of an employee’s injury or death. In most areas throughout the U.S., calling 811 will connect you with someone who can help you get applicable locates to ensure the safety...

Voice of Experience: The Safe and Proper Use of Bucket Trucks

Written by Danny Raines, CUSP on September 16, 2019. Posted in Voice of Experience.

Many industries use bucket trucks to help workers accomplish tasks. In the electric utility industry, we use bucket trucks – often referred to as insulated aerial devices – to help maintain and improve productivity and safety. The trucks are the most reliable when all of the manufacturer’s recommendations are followed and routine maintenance is performed. Manufacturing performance standards for insulated aerial devices can be found at ANSI A92.2 and OSHA 29 CFR 1910.67. I have performed fields audits for many companies over the years, and I want to share some facts about operational safety and...

Voice of Experience: Saved by the Bond

Written by Danny Raines, CUSP on August 19, 2019. Posted in Voice of Experience.

In this edition of “Voice of Experience,” we’re going to examine a recent incident that helps to illustrate the point that when workers follow the rules of OSHA 29 CFR 1910.269(n), “Grounding for the protection of employees,” it can save lives. Background InformationA transmission crew was assigned the task of transferring conductor and guys on the inside phase of a 115-kV three-pole angle. The pole had been set by another crew and was ready for the transfer; the three-pole-angle structure was sitting in a swampy area not accessible by trucks that day. The crew went in on a Marsh Master with...

Voice of Experience: What Do New Employees Need to Know?

Written by Danny Raines, CUSP on June 14, 2019. Posted in Voice of Experience.

As I’ve recently traveled around the U.S. speaking to different utilities, contractors and municipals, I’ve found that attrition is greatly affecting the workforce. And as more and more workers retire, the industry will need to hire new workers to fill those vacated roles – new workers who will need the appropriate training to safely and effectively perform their jobs. I’ve written about the value of training in the past, specifically about how the quality of training and performance management has a direct effect on the safety of employees and the productive abilities of the workforce. In this...

Voice of Experience: Clearing Up Confusion About OSHA Record-Keeping Requirements

Written by Danny Raines, CUSP on April 10, 2019. Posted in Voice of Experience.

Those of us in the industry tasked with record-keeping sometimes struggle with all of the different reporting scenarios. OSHA 29 CFR 1904, “Recording and Reporting Occupational Injuries and Illness,” gives us guidelines, but even the most thorough research of compliance requirements can still lead to questions and confusion. For example, workers’ compensation cases may not be recordable as OSHA cases due to exceptions in the agency’s record-keeping rules. Workers’ compensation is mandated by each state, while OSHA 1904 is a federal record-keeping standard. Further, OSHA’s record-keeping standard...

Voice of Experience: Planning for a Storm Restoration Effort

Written by Danny Raines, CUSP on February 18, 2019. Posted in Voice of Experience.

The electric utility industry is experiencing more major catastrophic storms than ever. Hurricanes, tornadoes, and snow and ice storms are taking their toll on both systems and employees. It was just several months ago that we were dealing with back-to-back hurricanes – Florence and Michael – and now we’re well into a winter that has dealt large swaths of the country plenty of snow and record-breaking low temperatures. At some point I stopped counting the number of storms I have worked during my 51 years in the industry. What I do know is that each storm has been a learning experience...

Voice of Experience: How Was Your 2018?

Written by Danny Raines, CUSP on December 14, 2018. Posted in Voice of Experience.

I would like to ask those of you reading this article to reflect on your professional life in 2018. What was different from previous years? Was safety at your company better, worse or about the same? As I sit and write this article during the first week of October 2018, I know that so far this year, the electric utility industry has suffered more than 20 fatal accidents and over 30 serious flashes and contacts. I don’t know what’s going to happen between now and the end of the year, but I pray no one else gets hurt. The fact is, our industry has suffered extremely high numbers of fatalities...

Voice of Experience: Why Do Accidents Keep Happening?

Written by Danny Raines, CUSP on October 11, 2018. Posted in Voice of Experience.

2018 is turning out to be a devastating year in our industry. The frequency of energized contacts, flashes, severe injuries and fatalities continues to increase. Why – in a professional trade that requires such an extensive amount of apprenticeship time – do lineworkers have such high incident and accident rates? In this installment of “Voice of Experience,” I want to review two accidents I am familiar with so that we can dive into why they happened, and how you can prevent them from happening on your job sites. The First AccidentIn the first accident, a journeyman lineman lost his right arm...

Voice of Experience: The Value of Worker Training

Written by Danny Raines, CUSP on August 10, 2018. Posted in Safety Management, Voice of Experience.

Many recent articles I have read in other magazines and via social media emphasize the importance of worker training. I couldn’t agree more. It is both important and valuable that employers invest in training for new employees entering the industry as well as current employees. While the return on investment cannot always be accurately measured and calculated, the ROI does exist nonetheless – just imagine what injury and fatality statistics would look like if we did not train our workers. One of an employer’s training-related responsibilities is to investigate cases of failure to follow training...

Voice of Experience: Understanding Induced Voltage

Written by Danny Raines, CUSP on June 12, 2018. Posted in Safety Management, Voice of Experience.

It has taken the electric utility industry many years to understand induced voltage. When I started working in the 1960s, it was explained to me that voltage remaining on de-energized lines was static voltage that had to be bled off or else it could be deadly. Now, when I speak to groups about temporary system grounding for the protection of employees, I occasionally still hear the term “static voltage” being used to describe what really is induced voltage from a nearby energized line. Even today, not everyone in the industry completely understands induced voltage. So, what exactly is induced...

Voice of Experience: When Training New Workers, Be Vigilant

Written by Danny Raines, CUSP on April 18, 2018. Posted in Voice of Experience.

In today’s electric utility environment, there are many training demands and opportunities due to new and inexperienced employees entering the workforce as older, more experienced workers continue to retire. New employees entering the field require – and are hungry for – information and hands-on experience, and they’re excited by the chance to engage in line work. To rubber-glove energized primaries and perform bare-hand transmission work is fascinating to younger workers and often provides them with an indescribable level of satisfaction and accomplishment. Ours is an exciting occupation, to...

Voice of Experience: Can Human Error Be a Root Cause?

Written by Danny Raines, CUSP on February 21, 2018. Posted in Voice of Experience.

In light of some recent incidents in the electric utility industry, numerous root cause investigations have been conducted to determine why those events occurred. The frequency of the events and their similarities are alarming. Some of the more recent cases involved induced voltages from nearby energized lines to de-energized lines and equipment. In one instance, an employee opened a system safety ground and got in series with ungrounded and grounded equipment and conductors, which resulted in severe burns to the employee. Another incident involved an uninsulated boom truck contacting primary...

Voice of Experience: Electric Utility Accidents and Injuries: Why Are We Regressing?

Written by Danny Raines, CUSP on December 15, 2017. Posted in Voice of Experience.

I travel frequently for work, and everywhere I go, I hear conversations about injuries and accidents that have occurred in the electric utility industry. Many of those conversations have included comments about how dangerous or hazardous our industry is. And in several articles published on Forbes.com based on data from the U.S. Bureau of Labor Statistics, the job title of electrical power-line installer and repairer is consistently listed as one of the 10 deadliest occupations in America. What is helping to keep this title listed as one of the deadliest jobs in the country? Many of us who have...

Voice of Experience: Distribution Cover-Up: Why Wouldn’t You Use It?

Written by Danny Raines, CUSP on September 11, 2017. Posted in Safety Management, Voice of Experience.

Over the next few installments of “Voice of Experience,” I’ll be reviewing some accidents that have taken place in the electric utility industry. I’ve had many requests for information about incident investigations and would like to share some details in hopes of preventing similar accidents in the future. Distribution cover-up will be the focus for this issue’s column. Approximately half – or even more – of accidents that result in flashes and electrical contacts are the result of poor cover-up or total lack of rated protective cover. Why would a lineworker not take the time to install protective...

Voice of Experience: De-Energizing Lines and Equipment for Employee Protection

Written by Danny Raines, CUSP on August 8, 2017. Posted in Worksite Safety, Voice of Experience.

Lately there has been a rash of incidents involving flashes and contacts with primary voltage. The incidents occurred due to improperly written switching orders or missed switching steps, none of which were recognized by the workers involved with the tasks. These types of errors have long been a problem and continue to result in numerous injuries and fatalities. In April 2014, OSHA’s revised 29 CFR 1910.269 standard was published. This was the first revision to the standard in 20 years, and one paragraph in particular that was clarified was paragraph (m), “Deenergizing lines and equipment...

Voice of Experience: OSHA Record-Keeping Requirements

Written by Danny Raines, CUSP on April 18, 2017. Posted in Safety Management, Voice of Experience.

OSHA record-keeping has long been an administrative challenge to businesses required to keep OSHA logs. In this installment of “Voice of Experience,” I’ll cover some changes that have occurred over the years as well as some essentials that all employers and employees must understand in order to maintain compliance with OSHA requirements. When the change from the OSHA 200 log to electronic record-keeping was made in 2002, it was a relief to many. At that time, all issues involving first aid were resolved; a list of first aid treatments was identified and took any doubt out of the requirement...

Voice of Experience: Inspection, Maintenance and Fall Protection Guidance for Bucket Truck Use

Written by Danny Raines, CUSP on February 15, 2017. Posted in Safety Management, Worksite Safety, Voice of Experience, Equipment Operations.

OSHA 29 CFR 1910.67 is the performance-based standard that covers requirements when using vehicle-mounted elevating and rotating work platforms, including the bucket trucks we use in the electric utility industry. There are many types of buckets, and the task to be performed will determine what type of bucket is required. This standard even covers noninsulated work platforms, sometimes referred to as JLGs, used in civil construction. For clarification, a mobile platform covered under 1910.68, “Manlifts,” is not covered under the 1910.67 standard. Mobile platforms are considered mobile scaffolding...

Voice of Experience: Switching and Working on UD Systems

Written by Danny Raines, CUSP on December 12, 2016. Posted in Safety Management, Worksite Safety, Voice of Experience, Equipment Operations.

I was recently asked to provide information about the challenges and opportunities found when working on direct-buried underground distribution (UD) systems. In light of that request, I’ll address those topics in this installment of “Voice of Experience.” My first opportunity to work on UD systems was as a truck driver operating a trencher in the late 1960s. UD systems were fairly new at the time; lineworkers were learning new techniques, using different types of tools to terminate cables and installing switchable elbows. In that day, some elbows were non-load-break. Back then the work was all...

Voice of Experience: OSHA’s MAD Changes and a Missed Opportunity

Written by Danny Raines, CUSP on October 12, 2016. Posted in Safety Management, Worksite Safety, Voice of Experience.

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...

Voice of Experience: OSHA Requirements for Step Potential Protection

Written by Danny Raines, CUSP on August 22, 2016. Posted in Safety Management, Worksite Safety, Voice of Experience.

When OSHA updated 29 CFR 1910.269 and merged almost all of its requirements with 1926 Subpart V, the requirement to protect employees from step potential was enhanced. In the months following the publication of the final rule, this change was rarely mentioned in the major webinars conducted by several prominent utility industry groups, so I want to take this opportunity to cover what you need to know. First, let’s talk a bit about the basic fundamentals of Ohm’s law and Kirchoff’s law of current division in order to ensure you understand the seriousness of step potential hazards. Ohm’s law states...

Voice of Experience: OSHA Citations and Informal Conferences

Written by Danny Raines, CUSP on April 26, 2016. Posted in Safety Management, Worksite Safety, Voice of Experience.

OSHA fines will increase for the first time in 25 years under a provision in the recently signed U.S. congressional budget deal. The Federal Civil Penalties Inflation Adjustment Act of 1990 exempted OSHA from increasing its penalties to keep pace with inflation. But a section of the new budget signed in November by President Barack Obama – referred to as the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 – strikes the 1990 exemption. Now, OSHA is directed to issue an interim final rule adjusting its penalties to account for current inflation levels, which would raise...

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

Written by Danny Raines, CUSP on February 12, 2016. Posted in Safety Management, Worksite Safety, Voice of Experience.

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’...

Voice of Experience: PPE Regulatory and Consensus Standard Requirements

Written by Danny Raines, CUSP on December 16, 2015. Posted in Safety Management, Worksite Safety, Voice of Experience.

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...

Voice of Experience: Clearing Up Confusion About 1910.269

Written by Danny Raines, CUSP on September 17, 2015. Posted in Safety Management, Worksite Safety, Voice of Experience.

It’s now been 18 months since OSHA’s final rule regarding 29 CFR 1910.269 and 1926 Subpart V was published. For the most part, the dust has settled and the industry has started to adjust to the requirements of the new standard. However, questions still abound regarding certain issues, and I’d like to address two of them – employee training and host-contractor information transfer – in this installment of “Voice of Experience.” Employee TrainingTo begin, many companies are still confused about the meaning of changes to 1910.269(a)(2). The pertinent portions of (a)(2) are printed below for easy...

Voice of Experience: Power Generation Safety and the OSHA Update

Written by Danny Raines, CUSP on August 16, 2015. Posted in Safety Management, Worksite Safety, Voice of Experience.

I have never worked in a generation plant, but I have visited many plants during my years of working with utilities. My experience has been in safety and skills training for transmission and distribution systems. I have also worked with generation employees on OSHA and DOT projects, and I am now in the process of helping a company revise their OSHA 1910.269 training program, including the portion that addresses 1910.269(v), “Power generation.” I have to say, I was surprised by the absence of changes to 1910.269(v) in the 2014 OSHA update. The revised section reads almost word for word the way...

Voice of Experience: Fundamentals of Underground Padmount Transformers

Written by Danny Raines, CUSP on June 20, 2015. Posted in Safety Management, Voice of Experience, Equipment Operations, Grounding.

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...

Voice of Experience: OSHA Updates to Arc-Rated FR Clothing Requirements

Written by Danny Raines, CUSP on April 20, 2015. Posted in Safety Management, Worksite Safety, Voice of Experience.

Over the last few months I have delivered several presentations and webinars on the recent revisions to OSHA 29 CFR 1910.269. During these sessions, attendees asked for clarification on a variety of topics, particularly arc-rated flame-resistant (FR) clothing. This month’s “Voice of Experience” is devoted to helping readers understand more about the impact of OSHA’s changes on this subject. At the time I am writing this, some of OSHA’s enforcement dates have recently changed due to a number of issues, questions and clarifications that the agency is working to address. The updated enforcement...

Voice of Experience: The Importance of Job Briefings

Written by Danny Raines, CUSP on February 16, 2015. Posted in Safety Management, Worksite Safety, Voice of Experience.

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...

Voice of Experience: How Does the Employer Ensure and Demonstrate?

Written by Danny Raines, CUSP on December 10, 2014. Posted in Safety Management, Voice of Experience.

As all of you now know, the updates to OSHA 29 CFR 1910.269 and 1926 Subpart V have been out for several months, and the October 31 enforcement date extension has come and gone. There were some anticipated changes to the standard that the industry was expecting, but the more subtle revisions I’ve seen may be the ones that are more difficult to implement. The industry was given extra time to understand and clarify some of the changes, and extensions in a few areas may be granted once again. One requirement that will likely not be granted an extension is that the employer now has to ensure that...

Voice of Experience: Flame-Resistant Apparel is Now PPE

Written by Danny Raines, CUSP on October 16, 2014. Posted in Safety Management, Worksite Safety, Voice of Experience.

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...

Voice of Experience: OSHA Eye and Face Protection Standards

Written by Danny Raines, CUSP on August 8, 2014. Posted in Safety Management, Worksite Safety, Voice of Experience.

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,...

Voice of Experience: Understanding Enclosed and Confined Spaces

Written by Danny Raines, CUSP on June 20, 2014. Posted in Safety Management, Worksite Safety, Voice of Experience.

What is the difference between an enclosed space and a confined space? Many companies do not acknowledge 29 CFR 1910.269(e), “Enclosed spaces.” Instead, they handle all spaces as confined under 1910.146, “Permit-required confined spaces,” and a few companies even handle them all as permit-required spaces. There may be some confusion and there certainly is much industry discussion about the spaces in which employees are asked to work. In this article, I will highlight several of the major differences between the spaces, as well as provide an overview of each of the OSHA standards. Where OSHA...

Voice of Experience: OSHA 300 Record-Keeping Rules

Written by Danny Raines, CUSP on May 13, 2014. Posted in Safety Management, Voice of Experience.

Every supervisor and manager should know who keeps the OSHA 300 log and what is required to document an entry. Every employee should receive awareness training about how entries are documented and what is looked for during an audit. The mystery behind the OSHA 29 CFR 1904 record-keeping standard is a result of its complexity and the confusing ways it is sometimes interpreted. I have been teaching record keepers for more than 25 years, dating back as far as the OSHA 200 days. I find it one of the most entertaining topics to learn about and teach, but it can also be challenging to fully understand....

Voice of Experience: Working On or Near Exposed Energized Parts

Written by Danny Raines, CUSP on September 19, 2013. Posted in Worksite Safety, Voice of Experience.

OSHA 29 CFR 1910.269(l), “Working on or near exposed energized parts,” requires employees to adhere to very specific rules concerning the exposure of unprotected body parts to energized conductors and equipment. I am amazed at the different interpretations of this one paragraph. I have thought about what work practices were being considered by the advisory panel that made the suggestions about how the standard should read when it was being written in the 1980s. The standard is very clear that two qualified employees are required to be on the job site when work is being performed that exposes...

Voice of Experience: Incidents and the Failure to Control Work

Written by Danny Raines, CUSP on August 19, 2013. Posted in Worksite Safety, Voice of Experience.

Flashes and contacts continue to happen throughout the electric utility industry. All sectors, from the smallest contractor to the largest investor-owned utility, report incidents every day. I have seen reports that one contractor working a 23-kV circuit locked out the breaker twice in one day. Other reports now indicate that 2013 is trending even higher than last year for the first four months of the year. The industry is on course to meet the average of 24 to 28 fatalities documented in the utility and contractor North American Industry Classification System codes reported to U.S. Bureau of...

Voice of Experience: Training for the Qualified Employee

Written by Danny Raines, CUSP on June 21, 2013. Posted in Safety Management, Voice of Experience.

Training is required by OSHA and all employees should follow proper training, but the unfortunate truth is that doesn’t always happen, resulting in accidents, contacts and fatalities. OSHA is very specific about defining what qualifies employees to work on and near energized conductors and equipment energized at greater than 50 volts. To be qualified to work on systems considered primary voltages greater than 600 volts, the mandated training is markedly more intense because of the requirements for such things as knowledge of component specialization, procedures such as insulate or isolate, and...

Voice of Experience: The Cost of Business

Written by Danny Raines, CUSP on April 29, 2013. Posted in Safety Management, Voice of Experience.

Sadly, accidents in our industry continually occur even though they are avoidable. I have spent the better part of 46 years teaching safe work practices, rules and regulations in an effort to prevent accidents from happening. However, in all the time I spent on the job, from my start as a helper on a line crew until I was promoted to line crew supervisor, I never really considered the costs of injuries or property damage. Due to the culture of the industry, the costs were seen as just part of doing business. In this article, I want to take a few minutes to share with you the costs of accidents. I...

Voice of Experience: The Definition of Personal Protective Equipment

Written by Danny Raines, CUSP on February 18, 2013. Posted in Safety Management, Voice of Experience.

I can remember a day when I would ask employees to name the five topics of a job briefing and why personal protective equipment (PPE) is the fifth point on the list of topics. Since the second part of the question was always a greater challenge for everyone to understand, I’d like to take some time to discuss the differences between protective equipment and PPE. Employees sometimes consider PPE to be system safety grounds, cover-up equipment, traffic vests and other equipment. As you can see in the excerpt below, 29 CFR 1910 Subpart I defines and identifies PPE as well as the body parts that...

Voice of Experience: Are You Ready for the Big Storm?

Written by Danny Raines, CUSP on December 13, 2012. Posted in Safety Management, Voice of Experience.

Now that Superstorm Sandy is over, there are fewer news stories about the destruction left in her wake and more media coverage of other topics. That is the nature of the news, but the truth is that Sandy cleanup will take months to complete. Many homeowners now have to cope with the new normal; their lives have been forever changed by the storm. When looking back on Sandy from a utility perspective – when you are scrutinizing what went well, what didn’t and the lessons learned – please consider the following points. Utility systems, neighborhoods and lives take years to build, and they can all...

Voice of Experience: FMCSR Compliance: Driver Qualification Files

Written by Danny Raines, CUSP on October 11, 2012. Posted in Safety Management, Voice of Experience.

As I travel around the country to audit driver qualification files, I often find that requirements found in the federal motor carrier safety regulations (FMCSR) are misunderstood by many companies. In this article I will focus solely on driver qualification files and the most common FMCSR compliance failures I see when I audit those files. Regulation 49 CFR 391.11 requires that a person must be qualified before he or she may drive a commercial motor vehicle (CMV). A CMV as defined in 49 CFR 390.5 is a vehicle, or the combination of a vehicle and towed unit, weighing 10,001 pounds or greater....

Voice of Experience: Safety Excellence Equals Operational Excellence

Written by Danny Raines, CUSP on August 27, 2012. Posted in Leadership Development, Voice of Experience.

I have been asked to present the opening keynote address at the fall iP Safety Conference & Expo, which will take place September 25-27 in Vancouver, Wash., just a few minutes outside Portland, Ore. It will be an honor to stand before conference attendees to share a safety message that will set the tone for the three-day conference. I plan to discuss safety excellence – how employees who work and operate with excellence at all times promote an excellent safety environment, one free from serious injuries and fatalities. At the time I’m writing this, there have been at least four fatalities...