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Tag: Worksite Safety

Field-Level Hazard Recognition Training That Works

As a safety professional or operations leader in your organization, one of your primary responsibilities is to ensure your employees can and do complete their work safely. People don’t want to get hurt and you don’t want them to. With that as a given, the question then becomes, how do you accomplish this? You can’t be everywhere watching everything all the time. You can’t point out every hazard on every job site for every worker. So, how do you rest easy in the belief that your employees are recognizing and mitigating hazards and working as safely as possible when you are not around? I’m going...

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The Future of Ergonomics

Over the last decade, our industry has done a great job of reducing work-related injuries as a whole, but musculoskeletal disorders (MSDs) – also known as ergonomic injuries – are on the rise. From 2008 to 2012, work-related injuries decreased steadily each year. During that same period, however, ergonomic injuries increased by approximately 15 percent, according to the U.S. Bureau of Labor Statistics. As we know, OSHA sets standards and precise thresholds, such as those for vibration and noise exposure, in an effort to improve work site safety and prevent injuries. But there are no specific...

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Train the Trainer 101: Grounding for Stringing in Energized Environments

A few years ago I came upon a crew using 6-inch chocks to hold back a 38-ton crane truck. I told the crew I was happy that they were making an effort at compliance, but I had to ask them, “Why do we place chocks under a truck’s wheels? Is it to comply with our safety rules or to keep the crane from running away?” It was obvious to me that the short chocks would not hold the crane. The driver proved my assumption true a few minutes later. From the cab, with the transmission in neutral, he released the parking brake. The crane easily bounced over the chocks and, unfortunately, hit my pickup truck. Sometimes...

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Voice of Experience: OSHA Citations and Informal Conferences

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...

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April 2016 Q&A

Q: What is an employer’s affirmative defense relative to an OSHA charge and how does it work? A: In simplified legal terms, an affirmative defense is the act of an accused party putting forth a set of alternative claims or facts. The purpose of the accused party doing this is to mitigate the claim against him, or at least the consequences of the claim, even if the facts of the claim are true. Following is an example of a fairly common scenario in which an affirmative defense is claimed by an employer. OSHA investigates an incident that resulted in an injury to an employee and finds the employer...

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Trenching by the Numbers

By and large, organizations directly provide the training and other resources needed for the development of their foremen and crew chiefs. Such training tends to be built around two components: following the standards set forth by OSHA and other regulatory agencies, and adhering to organizational policies and procedures. This is a great approach but perhaps an incomplete one. Truly impactful safety training typically includes a third component: sharing of personal experience. For instance, I once observed a training session in which the instructor drew from his experiences during a discussion...

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Understanding Your Safety DNA

Last summer my extended family planned and hosted a long-overdue family reunion. This one was particularly special because my Uncle Roy, who is now in his 80s, was there, and it was the first time in many years that I had the opportunity to see and spend time with him. Prior to his retirement, Uncle Roy was a railroad engineer in charge of and responsible for driving a freight train engine. From a safety perspective, I should explain a few details about trains before I continue. First, a typical freight train can be 120 to 140 cars or approximately one-and-one-half miles in length. Second,...

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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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Auditing for Safety Improvement

The mere thought of participating in an audit can be unnerving. Consider IRS audits for a moment – they can never mean good news, right? So why would an organization want to spend time, money and other resources to conduct an audit when it could be painful? The answer is that, regardless of the feelings they evoke, audits – when done right – can be a powerful organizational improvement tool rather than just a way to monitor compliance. To better understand the importance of auditing for improvement, let’s review an example of a traditional compliance audit. In this example, the audit identified...

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Train the Trainer 101: Safety Cops and the Continuum of Safety

Words have power. We confirm that every day when we examine why people do what they do. Communication is often the root cause of accidents, particularly how the receiver interprets what he or she hears. That communication is not always something said in the moments before an incident; it can occur days, weeks or months in advance. I have discussed this issue with behaviorists on a number of occasions, and I am convinced that some of the words I – and many others – have repeatedly heard over the years have served to limit our success in the quest for a strong, positive safety culture. The real...

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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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Stringing Best Practices: Mesh Grips vs. Preforms

When you ask lineworkers what differentiates their work from general construction, it’s not surprising that they will typically say they work with big lines at high voltages. Lineworkers take pride in keeping lines up and fixing them when they come down. We know that lines do come down inadvertently, and we also know that the losses resulting from such incidents can be substantial. No amount of regulation will combat these problems, so that’s where best practices come into play. Best practices establish the most common methods to achieve operational success within the parameters of regulations,...

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RF Safety for Utility Workers

Utility workers could be exposed to radiofrequency (RF) radiation every day and not even be aware of it. With today’s telecommunications explosion, even utility poles are housing cellular systems such as antennas and distributed antenna systems. And yet, the rapid growth rate of RF technology does not change the fact that we are still obligated to follow the laws and comply with OSHA and Federal Communications Commission (FCC) requirements, especially when dealing with RF radiation exposure limits. Required TrainingNot surprisingly, training is the best route to both RF safety and rule compliance....

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Train the Trainer 101: Practical Underground Safety: Handling Neutrals and Rescue

Over the years I spent as a lineman, I did my share of underground installation and maintenance work. During my years in safety, I have seen the expansion of safety processes associated with underground, especially in response to the most recent OSHA changes. Not all of the changes have been effective, and that’s why we’re now going to spend some time addressing several underground safety questions Incident Prevention frequently receives. We’ll look at the rules and practices and what works from a practical perspective. Handling URD NeutralsThis will not come as news to most of you, but for...

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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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December 2015 Q&A

Q: I’ve been reading ASTM 855, IEEE 1048 and the National Electrical Code, and I’m a little confused by the practice of grounding through a switch. Can you help me better understand this? A: In transmission/distribution applications, there is no issue with grounding through a switch. To explain, we always have to ask whether the issue is grounding through (in the path) a switch or grounding (by way of closing) a switch. The application may sound the same, but it depends on which standard you read. Our subject matter experts think the confusion lies in the well-known NEC rules, which require...

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Fundamentals of Substation Rescue Plans

I’ve worked in substations for most of my adult life, and I’ve picked up a few things along the way. Some were the result of good experiences, while others I learned through less than ideal circumstances. In this article, I want to share with you what I learned from my first experience with confined space rescue in a substation. It was mid-August of 1983 in Florida and the outside temperature was in the high 90s. Inside the 69/13-kV transformer, the temperature was well over 100 degrees. Two journeymen were conducting an inspection inside the transformer when they discovered a problem in the...

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Investigating Industrial Hygiene at Salt River Project

At Salt River Project, a large utility based in metropolitan Phoenix, there are a great variety of jobs, situations, risks and exposures that must be addressed, assessed and controlled. Journeymen lineworkers labor in heat approaching 120 degrees on the desert floor, while hydrologists trudge around in near-zero-degree weather to examine snowpack on the mountainous Mogollon Rim. A pressman needs a hearing assessment to judge the impacts of a six-color press, while electronics technicians must be evaluated for radio-frequency exposure from telecommunications equipment. A warehouseman at a power...

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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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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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October 2015 Q&A

Q: Is equipotential grounding now a personal protective grounding method required by OSHA? A: The answer is yes, even though OSHA doesn’t specifically say so in terms we easily understand. The terminology isn’t OSHA’s fault. As an industry, we adopt certain familiar ways of describing or discussing things and simply don’t recognize what OSHA is trying to communicate unless we do some diligent research. In 29 CFR 1910.269(n)(3), OSHA requires arrangement of grounds to protect employees without using the word “equipotential.” The title of the rule, however, is “Equipotential...

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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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Stepping Up Steel Safety Education

It’s estimated that between 2 million and 4 million utility poles are replaced annually in the U.S., and in almost every region of the country, many of those replacement poles are now made of steel. In fact, more than 1 million steel distribution poles have been installed by electric utilities across the country in the last decade. That number is expected to rise considerably as utilities strive to keep up with the need for new lines, replace aging and damaged poles and harden existing lines. The increased use of steel utility poles in distribution lines has created a need for new training...

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Rigging Fundamentals for Utilities

Over the past 20 years I have had the great opportunity to travel the country observing everyday safety practices in the utility industry. During this time it has become clear to me that, more often than not, employees are practicing inadequate rigging techniques that put them and their co-workers at risk on a daily basis. These poor practices are being perpetuated from one generation of riggers to the next. Employees who learned improperly from previous trainers go on to train new employees in the same fashion. It seems that a number of workers have bought into the dangerous idea that unsafe...

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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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Train the Trainer 101: Practical Personal Protective Grounding

In the last 10 years I have consulted on dozens of induction incidents, eight of which resulted in fatalities. There were commonalities in each one. Just about every Incident Prevention reader will agree that one of the topics that receives the most attention across the power industry – in writing, training and conversation – is personal protective grounding (PPG). Not a week goes by that I don’t email or talk to someone about PPG and, in particular, about dealing with induction. At iP we discuss and share information as well as news about incidents involving induction, and yes, they do...

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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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August 2015 Q&A

Q: I’m wondering about an issue with a third-party safety analysis required by one of our clients. We are required to satisfy their safety requirements, including creating programs and safety manual changes worded to meet their criteria. I have issues with the required changes because they don’t fit into our safety program. A: You are not alone in your concerns. OSHA issued a warning about this exact topic, and it was a reason for changing the language in the proposed rules from June 2005. In the proposed rule, 29 CFR 1926.950(c) required contractors to follow a utility’s work rules...

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Making the Switch

It is an undisputed and well-known fact that workers’ use of manual tools increases repetitive movement, introduces awkward working postures and elevates the risk of ergonomic injuries and illnesses. Throughout the past decade, the utility industry has done a great job of recognizing these ergonomic safety issues, and a number of utility tool manufacturers have responded by developing new battery-operated tools and tool features that address them. Slowly but surely, ergonomic safety is increasing in the workplace as investor-owned utilities, contractors, cooperatives and municipalities make...

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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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Arrive Alive

On a clear, sunny day following a fierce thunderstorm the night before, Mark drove off to work. The schedule for the day was busy with repairing downed lines in several heavily trafficked neighborhoods followed by some scheduled maintenance at a router station. Mark met up with his crew, reviewed the schedule and then the team headed out for what they expected to be a long day. The crew was experienced, though, so Mark felt confident they would be able to complete their list of tasks. In the driver’s seat of the crew cab on the way to repairing the downed lines, Mark thought about the task...

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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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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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OSHA and the Host-Contractor Relationship

The revisions to OSHA 29 CFR 1910.269(a)(3) and 1926.950(c) regarding information transfer have brought many changes to the relationship between host and contract employers in the utility industry. As OSHA noted in the preamble to the revised standard, the existing Multi-Employer Citation Policy is insufficient to ensure workplace safety, and hence the agency has implemented a host-contract employer information transfer standard. The following article will shine light on what information must be communicated by which employer as well as how it should be communicated. Employer DefinitionsBefore...

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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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Facing Unique Challenges

Established in 1891 by a royal charter from King David Kalakaua, today Hawaiian Electric provides electric service to 95 percent of the state of Hawai‘i. The company has approximately 1.4 million customers on five islands, with Hawaiian Electric providing service to O‘ahu; subsidiary Maui Electric providing service to Maui, Moloka‘i and Lana‘i; and subsidiary Hawai‘i Electric Light providing service to Hawai‘i Island. The state of Hawai‘i is located in the middle of the Pacific Ocean, about 2,000 miles away from the coast of the continental United States. This isolated geographic location,...

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Train the Trainer 101: The OSHA-EEI Subpart V Settlement

In February of this year, Edison Electric Institute (EEI) circulated an agreement with OSHA. This agreement – which can be viewed at www.osha.gov/dsg/power_generation/SubpartV-final-settlement.html – ended the petition for review filed over several new provisions of the April 11, 2014 final rule affecting the general and construction industry rules for transmission, distribution and line clearance work. The agreement as delivered consisted of the final agreement and four exhibits that specified the agreed-upon terms. Exhibit A is a series of 46 questions and answers reflecting more detailed...

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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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April 2015 Q&A

Q: We are a 100-year-old municipality and we have discovered some wood tools and a baker board in a long-overlooked storage area. The tools are rotted and termite-damaged, but the situation raised a question: Is it permitted to use wood hot sticks? A: We did some checking with manufacturers and most agree that wood tools were first replaced by fiberglass-reinforced plastic (FRP) in the 1950s when utilities started transmission voltages over 240 kV. The first published FRP manufacturing standard was for fiberglass tools in the 1960s. We don’t currently know of any consensus standards for...

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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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Measuring, Planning and Cutting Methods for Chainsaw Operators

The first two articles in this series discussed the risks of chainsaw operation as well as chainsaw safety, planning and precision felling techniques. In this final article, I will discuss several other topics that chainsaw operators should be knowledgeable about, including how to estimate tree height, make an open face notch and use felling wedges. Estimating Tree HeightAn important part of felling trees is the ability to estimate a tree’s height in order to determine its position as it falls, hits the ground and comes to rest. Accurate height estimation allows the operator to determine if...

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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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Arc Flash and the Benefits of Wearing PPE

Part of the recent OSHA updates includes increasing protection for employees who may be exposed to arc hazards. I am aware that there are many utilities that have proactively completed an arc hazard analysis for their systems, and that their employees are already wearing arc-rated clothing. Some of these utilities provide a full wardrobe of arc-rated clothing, including shirts and pants. Some utilities currently only provide tops. Still others have not completed their arc hazard analyses and do not provide their employees with any arc-rated clothing. Clark Public Utilities is one of the proactive...

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Closing the Safety Gap

The safety gap is that dimly lit space between what is and what should be, between the expectations set forth by your safety program and the actual work practices that take place on your work sites. Within that gap lurks all that we hope to avoid. As safety managers, one of our primary objectives is to close the safety gap by identifying and eliminating risk in our work environments. To do so, however, requires clarity. Without a thorough understanding of our risks, both historical and present, we are left with a static, generalized program that is not responsive to the dynamics of our work. Allow...

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Chainsaw Safety, Planning and Precision Felling Techniques

Chainsaw operators have to be able to think on their feet and adjust to their surroundings. Accidents and injuries can be dramatically reduced, and productivity increased, when workers have the knowledge, training and skills they need to properly operate a chainsaw. In the following article – the second part of a three-part series – I will discuss a variety of components related to safely operating a chainsaw, including what operators need to know about PPE, body positioning and reaction forces. I will also detail a five-step felling plan used by chainsaw operators around the world that you...

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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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Photovoltaic Solar Safety Management for Utilities

Most people who have worked in the electric utility industry are familiar with the safety concerns and applicable safety regulations associated with conventional nuclear and fossil electric power generation. Over the past several years, however, there has been an increase in the number of new generating facilities constructed across the U.S. that incorporate renewable technologies such as solar, wind and biomass. This article will provide a basic overview of one of these technologies – utility-scale photovoltaic (PV) solar – along with discussion of related safety considerations. PV FundamentalsIt...

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The Risks and Rules of Chainsaw Operation

Welcome to the first in a three-part series about arborist safety. In the second and third parts of the series, we will take a look at tree-felling and cutting methods as well as storm response techniques for utility workers. This first article, however, will give readers a broad overview of chainsaw safety, including powerful statistics, reasons why chainsaw operators struggle to follow safe work practices, and the essential education and training for workers who engage in chainsaw-related activities. Chainsaw Injury StatisticsThere is a wealth of impactful information available about chainsaw...

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Train the Trainer 101: Stringing in Energized Environments

Stringing wire in any environment can quickly go wrong. Dropped conductors can wreak havoc if precautions are not taken. In an energized environment, the result of losing control or dropping conductors has a greatly magnified risk. Guard structures are the first type of protection conventionally used to prevent contact with energized lines. Ideally, guard structures are positioned so that whether it’s the unexpected loss of stringing tension or something as major as a dropped conductor, the conductor being pulled will not make contact with the energized lines. There are other requirements, too,...

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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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SRP Rope Access Program Addresses Towers of Power

You’re working 120 feet above the desert floor on a high-voltage transmission line. A crewmate slips out of part of his rigging and hits hard against the skeletal metal superstructure of the lattice tower. The work site is miles away from town and emergency first responders. Your crewmate dangles perilously, dazed and perhaps critically injured. What do you do? If you work at Salt River Project – a major public power, water and telecommunications utility that serves central Arizona – you and your other crewmates shift into rescue mode according to the utility’s transmission tower rope access...

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Responding to Pole Fires

From time to time, most utilities with high-voltage systems have to deal with the problem of pole fires. While causes vary, fires always affect system reliability by damaging facilities and resulting in outages. Worse, it is hard to define the risk to workers dealing with a pole fire, especially when the fire’s cause is not easily determined. The most common cause of pole fires on Tacoma Power’s electrical system is high-voltage current tracking across insulators and finding a path to ground. This tracking can build heat and result in a fire within the wood pole. In addition to the potential...

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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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August 2014 Q&A

Q: Can a boom truck be used as a manhole rescue device? I’ve heard that OSHA rules prohibit boom truck use because the truck has too much force, resulting in greater harm to the employee in need of rescue. A: There may be issues with a boom truck as a rescue device, but its use is not prohibited in the situation you mention. Based on the criteria for rescue, however, it’s possible that the use of a boom truck may not be your best option. Incident Prevention does not advocate this method nor any other particular method of rescue from a manhole, but we do make every attempt to give you the information...

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The Final Rule

We have been expecting it since 2005. It’s here, and it’s big. The OSHA final rule regarding 29 CFR 1910.269 and 1926 Subpart V was announced April 1, popularly known as April Fools’ Day. The significance couldn’t have been missed by those at the U.S. Department of Labor. Who says they have no sense of humor? The unofficial PDF version published April 1 has 1,607 pages. The official version – published April 11 in the conventional three-column Federal Register format – has a mere 429 pages. The final rule becomes effective July 10. The first 313 pages of the final rule comprise...

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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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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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Accident Analysis Using the Multi-Employer Citation Policy

OSHA regulations are promulgated under the Occupational Safety and Health Act of 1970, as amended. In accordance with the regulations, employers are obligated to provide both safe work and safe workplaces. They must adhere to requirements for training, supervision, discipline, retraining, personnel protection, job planning and job control. Section 5 of the OSH Act – also known as the General Duty Clause – requires both employers and employees to do their part to adhere to OSHA regulations. Although present statutes do not allow OSHA to fine employees who violate regulations, employees are required...

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Understanding and Influencing the ‘Bulletproof’ Employee

Some employees are regrettably willing to take risks, as though they believe that they cannot be injured. This is the challenge of the “bulletproof” employee. To influence these kinds of employees, we first need to understand why they take the risks that they do, and our approach to understanding these employees, as it turns out, is where the challenge starts. By breaking a handful of old habits and adopting a more useful model for understanding others’ decisions and actions, we can become better equipped to tackle this challenge head-on and positively influence these employees. Dealing...

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Electrical Safety for Utility Generation Operations Personnel: A Practical Approach

Developing safe electrical work practices for generation personnel is an evolutionary process that can become extremely complex. South Carolina Electric & Gas Fossil/Hydro (SCE&G F/H), which includes nine large generation facilities and several other small peaking gas turbines and hydro units, quickly learned that even the choice of consensus standards – either the National Electrical Safety Code or NFPA 70E – can be a matter of debate when determining electric generation safe work practices. Although SCE&G F/H had an existing electrical safety program, updates in 2012 electrical...

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Fact-Finding Techniques for Incident Investigations

If you’ve been a safety professional or an operational manager for any significant amount of time, you’ve probably had your share of safety-related incidents. The most significant incidents are usually measured by their consequences. These may result in death, serious injuries, lost or restricted workday cases, OSHA recordable cases, first aid treatment, and/or equipment or property damage. Other incidents are commonly referred to as near misses, where serious consequences like the ones previously listed could potentially have occurred, but, through luck or circumstance, did not....

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What OSHA’s Proposed Silica Rule Means to You

Airborne crystalline silica has long been discussed as a health hazard in the workplace. When inhaled, very small crystalline silica particles referred to as “respirable” particles are known to cause silicosis, a fatal lung disease, as well as other respiratory-related diseases such as chronic obstructive pulmonary disease and lung cancer. Exposure to respirable particles can occur anytime dust is produced by cutting, grinding, drilling, sanding or crushing materials such as stone, rock, concrete, brick or blocks. It should be understood, however, that being in an area where silica-containing...

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The Singing Lineman

Brandon Wylie grew up with line work in his blood from his father and music in his soul from his grandfather, so it was just a matter of time before the two parts collided. And when you cross line work with a passion for music, you end up with a song that can light up a room and help bring recognition to an entire industry. Wylie wrote the song “Highline Cowboy” to express his love of the electric utility industry, and he can be found working on his music when he’s not teaching safety to lineworkers in his role as a certified safety and training specialist for Electric Cities of Georgia. But...

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Voice of Experience: Working On or Near Exposed Energized Parts

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...

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Are Your Temporary Protective Grounds Really Protecting You?

National equipment standards constantly evolve due to near misses and incidents that occur in the field. This evolution results in electric utilities adopting different work methods and procedures, equipment, education and training to keep utility workers and the public safe as every electric utility company builds and maintains the national electric grid. Personal protective grounds are placed between de-energized conductors in case the conductors become accidentally energized. The assembly creates a short circuit, causing the circuit to relay out, and protects a worker from dangerous differences...

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Ergonomics for Lineworkers

I am not an ergonomics expert. I am, however, a former lineman now in my 50s, experiencing aches and pains from many years of working in the field. I became interested in how ergonomics – the field of study that fits the job to the worker rather than the worker to the job – could improve line work after reading an article that explained how We Energies, an electric service provider headquartered in Milwaukee, had conducted a study in conjunction with the Electric Power Research Institute and Marquette University to determine why their employees were suffering so many hand, shoulder, knee and...

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Voice of Experience: Incidents and the Failure to Control Work

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...

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Starting From the Ground Up

Whenever we are fortunate enough to see a competent climber working off of a pole or tower, it can be favorably compared to watching a well-oiled machine at work. Each part of the body is coordinated and working together. A person with no understanding of the business might think climbing is something anyone can do. It is not. That climber has, more than likely, spent numerous hours learning his craft and practicing it day in and day out during the course of his duties. Even that climber who looks so graceful had to start somewhere, and that is what we are going to look at in this article –...

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Safety Awareness for Substations

There are a number of hazards unique to substations. The substation safety information found in this article is drawn from 30 years of personal experience as well as industry best practices, regulations, codes and company policies. During my time working in substations, I have seen some horrible accidents and hope the following lessons I’ve learned will prevent other people from having to experience injury or death. A Lesson for BeginnersOne thing I remember thinking as I walked into a substation for the first time is that it would be pretty easy for a person to get killed inside the facility....

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Occupational Dog Bite Prevention & Safety

According to The Humane Society of the United States, there are approximately 78.2 million owned dogs in the country and about 40 percent of all households have at least one dog. Of course, the percentage of households with dogs is higher in suburban and rural areas than in cities, but the fact remains that dogs are nearly everywhere. Couple these statistics with the fact that most households with dogs also have electric service, and those of us who work in the transmission and distribution departments of electric utility companies have a potential problem. OSHA would consider dogs a recognized...

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NESC and ANSI Z535 Safety Sign Standards for Electric Utility Power Plants and Substations

Both the NESC ANSI C2 rules and OSHA regulations require signs at appropriate places around utility facilities and workplaces. ANSI Z535 standards that specify the attributes of appropriate safety signs and labels for utility use include ANSI Z535.2: Environmental and Facility Safety Signs, ANSI Z535.3: Criteria for Safety Symbols and ANSI Z535.5: Safety Tags and Barricade Tapes (for Temporary Hazards). The coordinated ANSI Z535 criteria apply to every temporary or permanent safety sign or tag on a utility system. Recent Format ChangesSafety signs are comprised of a signal word panel and a message...

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Public Safety and Our First Responders

The threat of high-voltage electrical contact is very real for emergency first responders who are called to the scenes of accidents and other unplanned events. The safety of the public and our emergency workers should be a top priority. “You fight the fires, we deal with the wires” is a theme that is stressed in the comprehensive outreach program created by NSTAR, a Northeast Utilities company based in Boston. Contacting the utility company first, before any actions are taken by responders, is essential when dealing with an invisible force that travels at 186,000 miles per second. If you make...

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Implementing a Zero Injury Program

You’ve said it and heard it many times before: “Accidents happen.” It’s a phrase that essentially allows us to admit that accidents can’t be prevented. In business, that attitude has the potential to breed complacency when it comes to worker safety. A zero injury philosophy, however, maintains that there always exists some combination of tools, work practices and personal protective equipment that enables workers to carry out their assignments without being injured. Consequently, striving for zero injuries makes sense; it is a practical, achievable goal. American Transmission Co., a transmission-only...

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Detecting Shock Hazards at Transmission Line Work Sites

The line crew’s job for the day is to replace a 115-kV wooden H-frame transmission structure. No problem – this crew has done this type of work a number of times in the last few years. Upon arrival at the job site, the bucket truck and crane are arranged according to the job plan. A tailgate safety meeting is conducted, during which the clearance is reviewed and the points of isolation are identified. The work procedure is analyzed, including a discussion of the possible hazards and grounding plan for this work site. It is noted that, although not visible from this work site, this transmission...

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Train the Trainer 101: Enclosed Space Rescue

Following is a treatment of the complex subject of enclosed space rescue and it’s a lot of information. I would like to just tell you what to do, but there is no single solution. Your background understanding of the relative standards, interpretations and directives is necessary for you as trainers and administrators to mount an effective enclosed space program. Part of the confusion is the very particular language in the relative standards. There are a couple of important keys to proper interpretation. One is to be clear that an enclosed space is really a confined space, subject to 29...

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Train the Trainer 101: Ferroresonance Explained

Ferroresonance is a complicated issue. It is important to familiarize crews with ferroresonance because as the number of URD systems installed increases and as systems age, the incidence of ferroresonance increases and so does the threat to equipment, service reliability and, most importantly, the safety of workers and customers. Ferroresonance is a rare condition most likely to occur with three-phase pad-mount delta-connected transformers. Not nearly as often, ferroresonance has also been documented in wye-wye transformers and in aerial three-pot banks served by long-dedicated aerial circuits....

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Keys to Effective Fall Protection

The electric utility industry is loaded with potential hazards. Climbing at heights is one of those inherent safety risks that come with the job. At Louisville Gas and Electric (LG&E) and Kentucky Utilities (KU), we require 100 percent fall protection on poles and towers for our employees and business partners. This policy is part of our “no compromise” approach to safety and supports our belief that we can leave nothing to chance when it comes to the well-being of our workers. We also know that effective fall protection requires much more than just putting on the necessary gear. We have...

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Safety Rules and Work Practices: Why Don’t They Match Up?

What do safety rules mean to the organization? To the worker? Does having a safety rule mean it has to be followed 100 percent of the time, part of the time or not at all? Most employers and employees would say 100 percent of the time. So why do safety rules and actual work practices not match up every single time? Is the rule not known or not understood, does it not fit the application or has it always been done that way? In a recent survey by an electric utility, employees affirmed that there were often violations of safety rules, they did not always believe the safety rules were applicable...

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Working in Winter

No matter what time of year you are operating your utility truck, there are always best practices to follow for safe setup, operation and transportation. Particularly in colder weather when temperatures drop below freezing and stay there for an extended period of time, there are some specific things you need to keep in mind in order to keep your truck running and your crews productive. “When it comes to working in the winter, all the same practices for safe operation apply,” said Jim Olson, product and safety engineer for Terex Utilities. “It is important to always follow the safety guidelines...

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100 Percent Fall Protection: A Joint Union-Management Effort

Alliant Energy (AE) management and International Brotherhood of Electrical Workers (IBEW) union personnel began looking at the 100 percent fall protection issue about four years ago. AE is comprised of two utilities: Wisconsin Power and Light (WPL) and Iowa Power and Light (IPL). Union workers are represented by five IBEW locals. Internal statistics regarding falls during climbs on wood poles showed numbers in the teens over the last few years and a trend of near misses and minor injuries. Easing into 100 Percent Fall ProtectionBelieving that fall protection straps would probably be required...

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ATV Safety Begins with Proper Training

All-terrain vehicles, also known as ATVs, have a long-standing reputation for being unsafe and dangerous for riders and passengers. Operational injury statistics are staggering, averaging well over a half-million injuries in the U.S. since 2004. Although many injuries are linked to recreational use, ATVs in the workplace are expanding in a variety of industries, thus increasing the risk of job-related injury. Many theories exist about what can be done to reduce or eliminate ATV-related injuries, but one thing is certain: Proper training to avoid hazards, execution of preventive maintenance...

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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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What Do We Do About Arc Hazard?

To be absolutely clear – there is an arc hazard in the utility workplace. There is also a need for protecting employees with arc protective clothing. If you are responsible for hazard mediation, you should have an arc protection program or at least a plan to begin a program. Regularly, people call me and ask what they should do about NFPA 70E: Standard for Electrical Safety in the Workplace; and therein lies the problem. NFPA 70E is not the solution to utility arc flash hazards. What Does NFPA 70E Say?I have found out that most people who ask about complying with 70E have not thoroughly read...

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What You Need to Know About Substations

Beyond information peculiar to technical crafts, every person who enters a substation has a common need to understand substation grounding. This includes things to look for that might indicate problems in the station’s grounding system. Substation grounding plays the primary role in several key aspects of fault clearing, equipment preservation and, most importantly, personnel protection as well as protection of the passing public. In fact, if the ground grid in a station were not in place, anyone standing next to a breaker that operates stands a good chance of being shocked, if not killed. Twenty...

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Tower Rescue Pre-planning Pays Off

Tower rescue presents a completely different level of difficulty in planning and methodology. Whether 250-ft communications or transmission towers, they are often necessarily placed in remote areas, and usually inaccessible to conventional paramedic rescue vehicles. While it is each individual employer’s responsibility to make their own determinations on how rescues will be accomplished, the following may help in preplanning for these unusual rescue situations. Pre-planning for rescue in these situations must answer several questions. Effective Communications911 plays a key role in surviving...

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4 Rules to Live By

Looking for an alternative to ground-to-ground and cradle-to-cradle? The method suggested here could be your answer. Georgia Power Company (GPC) has developed the 4 Cover-up Rules philosophy to train employees rather than requiring a ground-to-ground or cradle-to-cradle glove and/or sleeve rule. Every fatality in the last 89 years at GPC has been phase-to-ground contact or in-series with line-to-load on either primary or secondary voltages. GPC has not had a fatality on system or source voltages (feedback) since the 4 Rules of Cover-up were developed and implemented after the last fatality in...

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Notes From the Underground

In the May/June 2005 issue of Incident Prevention the cover article, “Why Single-Point Grounding Works,” generated a lot of inquires about single-point worksite grounding in underground installations. The most frequently asked question was, “How do we create an equipotential zone for underground worksites?” I received inquiries from California to Maine, North Dakota to Florida. There were so many that IP asked if I could immediately address underground protective grounding for employees in this issue. OF BONDS AND BOUNDARIES Let’s begin with the practicality of...

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Why Single-Point Grounding Works

The pros and cons of single-point equipotential grounding, as opposed to working between your grounds or bracket grounding, has generated a lot of discussion. As found in IEEE-1048 Guide for Protective Grounding of Power Lines, single-point equipotential grounding is becoming more simply and accurately referred to as worksite grounding. In most cases, those who don’t trust worksite grounding don’t understand how or why it works. In fact, we have always been taught as linemen to “work between your grounds,” and that seemed like good advice. But it may not have been the...

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