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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 it did in the original 1994 standard. As far as the changes that were made, they consist of a few clarifications and the addition of “the employer shall ensure” to several paragraphs. That language, which is found throughout the entire 2014 1910.269 standard, removes any implied directives and expectations. It also helps to ensure the employer’s accountability and responsibility for employee safety and safe work practices.

Industry Evolution
Although there were very few changes made to 1910.269(v) in the 2014 OSHA update, it should come as no surprise that the way electricity is generated has evolved over the years. According to the U.S. Energy Information Administration (EIA), in 2014 the U.S. generated about 4,093 billion kilowatt-hours of electricity. Approximately 67 percent of the electricity generated was from fossil fuels, including coal, natural gas and petroleum. The updated 1910.269(v) focuses on, for the most part, fossil and hydro generation, just as it did in 1994. The EIA cites that in 2014, only 39 percent of electricity in the U.S. was produced through coal-fired generation; 27 percent was generated through natural gas; 19 percent through nuclear; 6 percent through hydro; 4.4 percent through wind; and 0.4 percent through solar. In light of this information, the focus on fossil plants with coal handling, conveyors, boilers and ash handling will likely diminish even more in the future. Coal generation may never be completely replaced, but the industry is now dealing with additional types of electric generation. For the most part, employees’ work activities and tasks are covered under other performance-based standards. Coal generation plant operations are similar in nature to those of manufacturing plants. They are generating electricity, so they are covered under OSHA 1910 Subpart R, “Special Industries.”

Coal-fired electric generation peaked in 2007 and has been rapidly declining because of EPA regulations. On the other hand, gas-fired and combined-cycle gas and oil generation have more than doubled since 1990. Hydro remains virtually unchanged in terms of generated kilowatts. Wind and solar generation are on the rise and have become part of the U.S. electrical grid. According to 2014 statistics, the U.S. is second in the world – just behind China – in terms of wind generation.

Unfortunately, 1910.269(v) does not reflect these industry changes, so the industry must learn to deal with them in the absence of an OSHA performance standard. In particular, the updated 1910.269(v) does not provide specific reference to or direction for working with solar, wind or gas turbines, so existing construction and general industry standards must be used as guidance. With the introduction of these different types of generation, employers must seek out safe work practices for employees.

Generator and Turbine Work
Gas turbine and combined-cycle oil generation plants are increasing in numbers all over the U.S. They are mostly owned by private companies and tie into the grid at generation facilities via generator step-up power transformers at the plant sites. The generators must sync and tie back to the transmission grid at the step-up units. From that point, the system operator controls the flow of energy in the grid. Often the generation plants are used by large investor-owned utilities as peak loading for base generation when demand is extremely high, such as during times of intense heat or cold, or when unscheduled base-loaded generator outages occur. Many do not run all the time, only when demand is high, as mentioned, or when requested by a company in the grid. The high demand of natural gas determines the availability of these plants.

Gas and oil turbines have evolved over the years, from the extremely loud jet engine types to the slower, incredibly efficient modern turbines that are much quieter by design. From the time the electricity being generated by a gas turbine is connected to the electrical grid, it is covered by the current 1910.269 standard. But what about the actual operation of the generator or maintenance of the turbine? There is a noticeable absence of references to these types of work in 1910.269(v).

Wind and Solar Generation
The greatest challenge of wind generation is the assembly and construction of the tower and turbine. The electrical connections from generator to grid are not covered by 1910.269(v). Current fall protection standards, as well as 1910 Subpart D, “Walking-Working Surfaces,” cover construction and installation activities. But what is not mentioned is generation at 800 V-DC voltage, rectifying (converting) and transforming voltage to AC and entering the grid. OSHA states that anything greater than 600 volts AC is considered high voltage. Keep in mind that 1910.269 is the performance-based standard that provides direction on the electrical safety of minimum approach distances, PPE and work practices. This is important to note for the safety of employees who use rectifiers or who transform low AC voltage to high AC voltage. In many cases I have heard that NFPA 70E is being used as a reference regarding safety practices and arc flashes when employees are working on or around rectifiers. NFPA 70E is a consensus standard that can be used by private companies; it is not normally utilized by utilities working on high-voltage systems. If a company does not employ qualified electrical workers per OSHA 1910.269(a)(2), the safe work practices found in NFPA 70E – such as those in Article 120, “Establishing an Electrically Safe Work Condition” – should be employed.

Solar generation is now becoming more popular than in the past because, like wind, solar energy is a renewable resource. This type of generation also is not mentioned in 1910.269(v). Solar-generated voltage, similar to wind-generated voltage, starts as DC that is changed to AC through the use of inverters. Step-up transformers then increase the voltage for the purposes of transmission and distribution. The current electrical and substation standards found in 1910.269 provide direction after the transformation, but 1910.269(v) mentions nothing with regard to dealing with solar generation.

I would be remiss if I didn’t mention the challenge that transmission and distribution workers face when dealing with customer-owned generators connecting back to the electrical grid. Technology has given us reverse current flow relays and frequency synchronization to ensure the system can tie in and will not affect the reliability of the grid. Technology also provides safety measures for employees working on the grid.

The Bottom Line
The lack of language referring to all types of generation in 1910.269(v) is not ideal. But in spite of these circumstances, the industry is doing its best to handle the challenges it continues to face. This is especially true when it comes to protecting our workers.

About the Author: Danny Raines, CUSP, safety consultant, distribution and transmission, retired from Georgia Power after 40 years of service and opened Raines Utility Safety Solutions LLC, providing compliance training, risk assessments and safety observation programs. He is also an affiliate instructor at Georgia Tech Research Center OSHA Outreach in Atlanta. For more information, visit

Safety Management, Worksite Safety, Voice of Experience

Danny Raines, CUSP

Danny Raines, CUSP, is an author, an OSHA-authorized trainer, and a transmission and distribution safety consultant who retired from Georgia Power after 40 years of service and now operates Raines Utility Safety Solutions LLC.