What Tasks Can Lone Workers Perform?
Over the course of my career in the utility industry, I’ve often been asked what tasks lone workers are allowed to perform on their own. It’s sometimes a hotly debated topic – both legally and ethically – and the answer is very much based on the employer. Each employer determines which tasks are allowed to be performed by lone workers in the field based on the workers’ job classifications and safety considerations.
Typically, OSHA does not regulate the number of employees required for specific tasks – except for the tasks found at 29 CFR 1910.269(l)(2), “At least two employees,” which reads as follows.
Except as provided in paragraph (l)(2)(ii) of this section, at least two employees shall be present while any employees perform the following types of work:
Installation, removal, or repair of lines energized at more than 600 volts,
Installation, removal, or repair of deenergized lines if an employee is exposed to contact with other parts energized at more than 600 volts,
Installation, removal, or repair of equipment, such as transformers, capacitors, and regulators, if an employee is exposed to contact with parts energized at more than 600 volts,
Work involving the use of mechanical equipment, other than insulated aerial lifts, near parts energized at more than 600 volts, and
Other work that exposes an employee to electrical hazards greater than, or equal to, the electrical hazards posed by operations listed specifically in paragraphs (l)(2)(i)(A) through (l)(2)(i)(D) of this section.
OSHA does specifically allow some tasks to be performed by lone workers, including the following found at 1910.269(l)(2)(ii).
Routine circuit switching, when the employer can demonstrate that conditions at the site allow safe performance of this work,
Work performed with live-line tools when the position of the employee is such that he or she is neither within reach of, nor otherwise exposed to contact with, energized parts, and
Emergency repairs to the extent necessary to safeguard the general public.
Some OSHA History and MADs
Overall, the electric utility industry is very disciplined and task oriented. OSHA issued the 1926 Subpart V Construction standard in 1974. Shortly thereafter, stakeholder hearings and meetings began, and information about the General Industry standard was collected. After years of meetings and much review of work tasks found in all major utilities, the 1910.269 General Industry standard was published and became law for operating electric systems. In 2014, the Construction and General Industry regulations were merged to remove older language in the Construction standard and clarify the differences between the two regulations.
Employers and workers should know that the paragraph on minimum approach distances was slightly changed to include the electrical components of the systems. Additionally, the employer became accountable for following the remaining requirements on MAD adjustments based on elevations and transient overvoltages of the system for employee protection. The employer can make decisions about which tasks are safe for employees to perform alone using the foundation of MAD regulations. They can choose the tasks their employees can perform based on their training and experience. OSHA is clear that the employer will make such determinations through industry work practices that do not violate any OSHA regulations. Employers should make their judgments based on what other utilities are doing, the training of their employees and their history of accidents. Employers must be able to defend their decisions about which tasks are allowed.
A recent survey of investor-owned utilities, cooperatives and municipals indicated differences in the tasks they allow their employees to perform alone. Some companies require two 1910.269(a)(2)-qualified employees to open a padmount transformer, while others allow a 1910.269(a)(2)-qualified serviceman working alone to write switching orders, operate elbows and cables with hot sticks, maintain MADs on energized parts and equipment, and then check for absence of voltage and ground the cables and equipment.
Overhead Line Work
In overhead line work, a person working alone must never encroach upon the MAD in any way. The use of sticks to operate equipment is allowable per 1910.269(l)(2)(ii)(B). Trimming a limb with an approved and tested hydraulic stick saw is just one example of a task that is allowed under the regulation. Training must be defined, and it must be demonstrated that the employee can safely perform the task before being allowed to do so in the field.
Employers and employees must remain highly aware that OSHA regulations are the minimum safe performance standards based on historical data, which includes testimony regarding past incidents and accidents. If accidents, injuries or employee complaints are investigated by OSHA, the employer must be able to defend their work practices.
Keep in mind that the greatest hazard might not be the shock hazard that the MAD should protect the employee from. It might instead be the arc flash hazard that could exist as employees perform their tasks. OSHA requires the appropriate PPE – including FR/AR clothing, safety glasses and face shields – for tasks that expose an employee to 2 cal/cm2 or more. That is the amount of heat energy that results in a second-degree burn, which is a significant injury. MAD is a boundary for the prevention of electrical shock to the employee. Arc flashes with significant injury can occur at much greater distances than the MAD shock boundary. There is a record of employees standing on ground, operating extendo sticks, who sustained arc flash injuries to their eyes while performing their task. That was 30 feet from the flash. All hazards must be considered by all employees when working in general, but especially when working alone. Remember that hazard control – which includes the prevention of arc and shock injuries – can only be accomplished by de-energizing the equipment and conductors. I also want to remind readers that de-energized, ungrounded conductors and equipment must always be considered energized, and MADs must always be maintained.
Calculating Exposure
OSHA regulations do not specifically explain how to perform tasks. Many times, the first hazard considered is the shock boundary determined by the MAD. But as noted, arc flash hazards must also be considered. The employer is required to determine a reasonable exposure estimate per 1910.269(l)(8)(i). Appendix E to 1910.269, “Protection from Flames and Electric Arcs,” provides examples of the methods that can be used to do so. There are also software programs as well as manual methods to determine the effort required. Remember, employers will be held accountable and responsible by OSHA for their employees’ actions in all cases.
About the Author: 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.
Learn more from Danny Raines on the Utility Safety Podcast series. Listen now at https://utilitysafety.podbean.com!
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