Train the Trainer 101: Are Those Tools and Equipment Approved?
We provide tools and equipment for our crews. Sometimes they are special tools, and sometimes they are generic tools necessary to support routine crew work. Sometimes they are accessories for trucks and equipment, and sometimes they are simply extra tools or equipment to make things easier on the people in the field. The question then is, are these tools approved?
The following is going to aggravate some readers, so let’s start with a reminder: I attempt to clarify and simplify compliance with this series. This is about making compliance easier and sometimes less expensive. So, here is an example.
About 20 years ago I was organizing a training school for a community college in Florida. I was recruiting utilities as clients. A visiting utility safety director saw that we had 40-foot-length retractables at the tops of the training poles. He said, “You are going to get into trouble with those yo-yos. They have to be mounted on approved davits.” My first question – and what should be your first question, too – was, approved by who? Without skipping a beat, the safety director responded, “OSHA.” We then went to his office where he had a similar device for which they had paid a little over $2,000. And just like he said, right there on the box was clearly printed “OSHA approved.” It only took me a few minutes on OSHA’s website to show him reference after reference and interpretation after interpretation in which OSHA stated to employers and manufacturers that it does not approve equipment. If an employer writes to OSHA and asks if they approve of having the employer’s employees in a specific type of exposure, and the employer intends to use a specific tool and equipment in a particular configuration, OSHA will respond that the agency does not approve equipment. The agency will then go on to state that in the situation described, using the equipment as described, OSHA believes the employer’s solution would – or would not – meet OSHA’s requirements.
That is about as much approval as you will see from OSHA. Let me also clearly explain here that approval by OSHA for one employer is not a blanket approval for all employers. It’s likely that using the same process in a similar situation would be acceptable. Every employer has to decide how to meet OSHA requirements. If you have time, write to OSHA. You can even call the agency and explain what you want to do, and often they may be able to advise you over the phone. But each employer has to be able to defend the measures taken toward compliance with OSHA requirements.
Now, back to the fall protection I previously mentioned. The retractable price was about $2,000. A pole-mounted davit arm to mount the retractable was a little over $2,500. Each davit arm could support 6,000 pounds. Our installation was on double fiberglass arms rated at 8,000 pounds at less than a quarter of the cost of the manufacturer’s davit arm. Not only that, we could hang two retractables, one on each side of the pole, on the same set of arms.
Rope and Equipotential Mats
Let’s talk about rope. I have come across several utilities that no longer permit the use of rope slings. I have no problem with that, but often the reasoning is due to a misunderstanding of the rules. The prohibition usually is based on the belief that knots are a prohibited method of joining a rope. That is not quite right. Read the rules closely. Paragraph 1926.251(d)(2)(v) states that knots shall not be used in lieu of splices. Tying a rope on a transformer using a square knot to haul it up the pole is not splicing. The next objection is that using a rope as a sling is not approved because it does not have a permanently affixed rating tag for attachment configurations. Let’s look at that rule, found in paragraph 1926.251(d)(1). It states that employers “must not use natural- and synthetic-fiber rope slings with loads in excess of the rated capacities (i.e., working load limits) indicated on the sling by permanently affixed and legible identification markings prescribed by the manufacturer.” That sounds right except for one important fact: The employer is not a manufacturer. In fact, the very next rule – 1926.251(d)(2) – states the following: “All splices in rope slings provided by the employer shall be made in accordance with fiber rope manufacturers recommendations.” That’s pretty simple. The Cordage Institute indicates three-strand nylon-polyester rope has a minimum breaking strength at about 5,600 pounds. The working load with a safety factor of 12 is about 470 pounds. OSHA refers the employer to manufacturer’s data for sizing and loading rope. Samson Rope’s user’s manual requires that the working load limit equal the maximum breaking strength divided by a safety factor. The safety factor for normal rigging operations is recommended at 5 and 10 for climbing ropes. At 5,600 pounds, a working load safety factor of 5 as recommended by the manufacturer establishes a safe working load for a rope sling of half-inch three-strand at 1,120 pounds, about two times the weight of a 25-kVA transformer. There is one other practical consideration. A few weeks ago, I was auditing a crew for a utility. The adjustable half-inch rope sling provided by the employer was so badly worn it needed to be retired from service immediately, even though the rope-sling tag indicated it was rated for 4,400 pounds. While there is nothing wrong with a store-bought transformer sling, in this case of an overused, worn, factory-manufactured transformer rope sling, I can make a pretty strong argument for the safety of a new rope sling competently installed by a lineworker to hoist transformers.
Here is another example. Not long ago I was working with a contractor in developing equipotential mats for wire-pulling equipment. I showed them photos of mats using hog panels purchased from a farm store. Hog panels are used across the country as equipotential mats. The panels themselves are welded wire constructed of 4-gauge galvanized wire welded in a 4-by-5 grid. They are typically in 16-foot-by-5-foot size. These panels are available at any feed store. They are rigid enough that on reasonably solid terrain, you can drive a digger derrick over them without bending them out of shape. The best evidence of these hog panels for me is experience. They work. The problem was that the utility wouldn’t approve them for the contractor because they weren’t manufactured as equipotential mats. There is nothing wrong with the utility’s demand. They have their reasons and concerns for their own liability. There is an electrical test specification for manufacturers to design by. That ASTM specification has little to do with the mats’ efficiency in use. The test is only for the mat. There is no test for mats in the field, and the effectiveness of the mat is based on connections and conditions of use. It’s all about understanding the expectations and requirements of the code with a little out-of-the-box thinking.
Interpreting OSHA Standards
As you read earlier in this article, the interpretation of OSHA standards is not as difficult as it seems, but it does take some effort. Here are a few steps I recommend. Begin with the rules themselves. Remember that for utilities and utility contractors, all of the applicable rules are not limited to 1910.269. If you can’t find it in 1910.269, you will have to look in the horizontal standards. Rules for ladders, aerial devices, confined space, hazardous atmospheres, medical surveillance, recordables and reporting, as well as rubber goods and PPE, are found in standards other than 1910.269.
Use OSHA’s website (www.osha.gov) to do your research. When you find the rule, look closely at the color of the rule number. If it’s blue, it’s a clickable reference that will take you to interpretations or related materials. There you can find information that might help with your compliance.
The preambles to the rules – which also are accessible at www.osha.gov – are a little harder to research. They are a record of all of the stakeholder discussions and OSHA explanations for the intent of the rules that took place during the development of the rules. Not every rule has a preamble discussion. However, if there is one, it is a great way to learn what OSHA’s intent was when they wrote the rule.
Consensus standards are the next best resource. ANSI, ASTM, IEEE and the like are standards for performance that have been agreed upon within the industry. Take a look at 1910.6, “Incorporation by reference.” Here you will find the consensus standards that OSHA uses as compliance guides. Consensus standards adopted by reference have the weight of OSHA rules. Failure to follow them can be treated as a violative act and you can be fined by OSHA. You also should see Appendix G to 1910.269, “Reference Documents.” Pay attention to the guidelines for employers concerning these referenced standards. These consensus standards are not adopted, meaning you can’t be cited strictly on the language of the standard. Read the guidance below found in the first paragraph of the appendix.
“The references contained in this appendix provide information that can be helpful in understanding and complying with the requirements contained in 1910.269. The national consensus standards referenced in this appendix contain detailed specifications that employers may follow in complying with the more performance-based requirements of 1910.269. … [H]owever, the Occupational Safety and Health Administration will not necessarily deem compliance with the national consensus standards to be compliance with the provisions of 1910.269.”
So, now we circle back to the advice found in the beginning of this article. It’s up to the employer to decide how to comply with OSHA. Stay tuned or write to us. We will do everything we can to help you get it right.
About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn, CUSP, has devoted the last 20 years to safety and training. A noted author, trainer and lecturer, he is a senior consultant for the Institute for Safety in Powerline Construction. He can be reached at firstname.lastname@example.org.