Tag: Voice of Experience

Voice of Experience: Clearing Up Confusion About 1910.269

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...

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Voice of Experience: Power Generation Safety and the OSHA Update

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...

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

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...

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

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...

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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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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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Voice of Experience: Understanding Enclosed and Confined Spaces

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...

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