When OSHA Electric Power Safety Standards Apply

Welcome to the first part of what will be a six-part series focused on OSHA’s electric power standards. We will start this series with a discussion about when the standards apply. Future articles will cover what is in the standards plus provide you with some practical ways to apply them.

If you have tried to read OSHA’s electric power standards, you may find them difficult to interpret and apply. Always keep in mind that each part of the standard was written to address a specific hazard that must be controlled. The standards outline the minimum controls you are required to put in place, so that is why OSHA standards are considered minimum performance standards. If you always begin by identifying the hazard, you may find that the application of the standard becomes somewhat simplified.

Why Does OSHA Have Electric Power Standards?
Employees who work on and around electric power installations face unique electrical system hazards with potentially high risks. OSHA estimates their electric power standards will prevent approximately 20 additional fatalities and 118 additional serious injuries annually. Each portion of OSHA’s electric power standards is designed to address electric power system hazards that workers are exposed to when performing covered work that falls under general industry or construction. 

What is Covered Work?
When determining electric power covered work, always begin by asking this question: Do we have electric power system hazards at our job site? Electric power system hazards typically are considered electrical hazards, but they also can include pole and tower fall hazards as well as generation production hazards that are unique to electric power work. Electrical hazards include but are not limited to step and touch potentials, induced voltages, induced currents, electrical contact, equipment fires and arc flashes. Always consider whether the identified system hazard can be found at different work sites outside of electric power work; if so, OSHA electric power standards may not be applicable.

Example 1
A transmission construction crew is building a new transmission line in a corridor paralleling an existing energized line. Although the crew is not working on energized equipment, there is the possibility of step and touch potentials due to voltages and currents induced by electric or magnetic field coupling, or both, with the energized adjacent lines. Every employee on the construction crew has the potential for electric shock and electrocution, similar to workers who are working on energized lines and equipment. This work would be considered covered work.

Example 2
A site-clearing company is clearing land to build an electric power substation. The area is considered a greenfield site. The site-clearing company would not be performing electric power covered work as they do not have any unique electric power system hazards. 

General Industry or Construction Work?
When applying OSHA’s standards, you will need to determine the types of work to be performed to apply the appropriate standard. Are you performing general industry work, construction work or both? If you are performing both types of work, your company standards will need to address the most stringent standard to ensure consistency for your workers. Frankly, it would be unreasonable to have different standards based on whether someone is performing general industry or construction work.

The general industry standard, OSHA 29 CFR 1910.269, applies when workers operate or maintain generation, transmission and distribution lines and equipment. This standard is typically referred to as the “269 rule.”

The construction standard, 29 CFR 1926 Subpart V, applies to the erection of new electric transmission and distribution lines and equipment, and the alteration, conversion and improvement of existing transmission and distribution lines and equipment. This rule is typically referred to as the “Subpart V rule.”

OSHA better aligned the electric power general industry and construction standards in 2014. Although both standards have a few unique areas, for the most part the standards are consistent with each other. It is important that you spend time researching the standards to understand differences based on the work performed. For instance, 1926 Subpart V addresses slightly different requirements in medical services and first aid than 1910.269 does. Most companies exceed OSHA’s minimum performance standards, but it is important to identify the required standard for the work to be performed to ensure you understand and have addressed OSHA’s minimum requirements.

Conclusion
When determining whether OSHA’s electric power standards apply, always focus on identifying whether you are performing covered work that has electrical system hazards. Next, in the second part of this series, we will discuss training and qualification requirements based on the work performed as well as the electrical system hazards associated with the work.

About the Authors: Pam Tompkins, CUSP, CSP, is president and CEO of SET Solutions LLC. She is a 40-year veteran of the electric utility industry, a founding member of the Utility Safety & Ops Leadership Network and presently serves on the USOLN executive board. Tompkins worked in the utility industry for over 20 years and has provided electric power safety consulting for the last 20 years. An OSHA-authorized instructor, she has supported utilities, contractors and other organizations operating electric power systems in designing and maintaining safety improvement methods and strategies for organizational excellence.

Matt Edmonds, CUSP, CIT, CHST, is vice president of SET Solutions LLC. A published author with over 15 years of safety management experience, he also is an OSHA-authorized instructor for general industry and construction standards. Edmonds provides specialty safety management services for electric power organizations throughout the U.S. He has been instrumental in the development of training courses designed for electric power organizations, including OSHA 10- and 30-hour courses and SET Solutions’ popular OSHA Electric Power Standards Simplified series.

About OSHA Electric Power Standards – Simplified: Topics in this series are derived from SET Solutions’ popular OSHA electric power course offered through the Incident Prevention Institute (https://ip-institute.com). The course is designed to help learners identify standard requirements and to offer practical ways to apply the standards.

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Webinar: When OSHA Electric Power Safety Standards Apply
November 13, 2020, at 1 p.m. Eastern