Q: Our plant safety committee has a longtime rule requiring electrical hazard safety shoes for our electricians. We were recently told by an auditor that we have to pay for those shoes if we require employees to wear them. We found the OSHA rule requiring payment, but now we wonder if we are really required to use the shoes. Can you help us figure it out?
A: Sure, we can help. But first, please note that Incident Prevention and the consultants who have reviewed this Q&A are not criticizing a rule or recommending a rule change for any employer. What we do in these pages is explain background, intent and compliance issues for workers and employers in the workplace.
You mentioned a longtime rule that probably dates back to the early OSHA rules that required electrical hazard boots for electricians. We can’t remember exactly when, but there was a letter to administrators in the early 1990s and subsequent rule-making that changed the language on the use of electrical hazard shoes. Your auditor is right; if you require employees to wear them, you are required to pay for them because unlike regular safety shoes, the electrical hazard criterion makes the safety shoe a specialty shoe. Specialty shoes must be provided at no cost to the employee (see www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=29825).
Now let’s address the question, are the shoes required? Employers are required to perform a workplace hazard assessment and then use engineering or procedural controls to eliminate hazards. If a hazard cannot be eliminated by procedures or engineering, PPE is required. OSHA agrees throughout current literature that electrical hazard shoes are to be employed as part of a system of protection based on the hierarchy of controls. If you read the rule closely, you will see that the language is very particular. OSHA 29 CFR 1910.136(a) – edited here for clarity and space – states that the “employer shall ensure that each affected employee uses protective footwear … when the use of protective footwear will protect the affected employee from an electrical hazard, such as … electric-shock hazard, that remains after the employer takes other necessary protective measures.” Those other measures are the hierarchy first, PPE last.
Why is this the case? The issue is that there is no means of in-service testing to ensure the shoes are rated at 600 volts as designed. Contamination and conditions of use can diminish the dielectric integrity of the soles of the shoes, and there is no way to effectively ensure they will work, especially with the worker compressing the soles. A worker could leave the tool room with good dielectric protection and then contaminate the soles on the way to a motor control center. In fact, OSHA mentions in several publications that the risk of issuing the shoes alone could provide a false sense of safety for the electrical worker.
So, here we return to procedures and engineering. First, PPE procedures dictate that the employer train the employee on use, maintenance and limitations of PPE. There is no difference when it comes to electrical hazard shoes. Next, procedures themselves will be more reliable than the shoes. Even if a worker is wearing good dielectric shoes, hands in a panel often result in backs of hands, shoulders and elbows in contact with panel sides and doors. All the shoes in the world won’t stop an electrical path across the body unless you are wearing them on your hands. Finally, plant electricians are largely covered by NFPA 70E, which requires “safe work” conditions and thereby practically prohibits working exposed energized systems. The intent of 70E essentially is to eliminate energized work instead of prioritizing de-energized work. OSHA enforces those rules by way of the General Duty Clause. If a worker never comes into contact, purposely or inadvertently, the electrical resistance of the worker’s shoes makes no difference. It boils down to the employer’s assessment. If the employer can reasonably assure work practices and procedures protect craft employees from electrical hazards, the employer does not have to mandate the use of electrical hazard shoes.
Q: Where does self-rescue from a bucket fit into OSHA’s requirements, and why doesn’t OSHA address it more directly?
A: Self-rescue from a bucket is not required by OSHA, but that by itself is not a reason for an employer not to consider adopting it. Your question gives us an opportunity to discuss how conventions develop within the industry and how interpretation of standards can be confusing.
It must be pointed out that self-rescue is not really rescue if there is no immediate element of danger involved. We’d prefer to refer to self-rescue systems as bucket self-egress systems instead. It is easy to say from the comfort of the writer’s desk, but we have been there, and in most cases being stuck in a disabled bucket is more of an inconvenience than a danger. There are some employers that think self-rescue is a requirement, but despite the name of the process, self-rescue is an invention of employers solved by manufacturers. Many employers do issue the equipment and some report the equipment being used successfully in aerial lift malfunctions. Still, it is not that simple, and employers need to realize that simply buying equipment is not the end of the matter. In fact, some situations may be made more dangerous by attempting to rappel from a basket rather than waiting for another crew or a mechanic. Sometimes the best solution is a radio, sunscreen and patience.
Here are a few real-life self-rescue failures and complications the employer may want to consider.
• A poorly trained employee got his upper arm wedged between the end of the boom and the bucket lip as he went over the side; he suffered permanent damage to his arm.
• An employee contacted a secondary buss as he rappelled from a disabled bucket.
• A worker’s poorly maintained descent device locked up and the suspended employee suffered suspension trauma while waiting for rescue.
• During training, an older, less agile worker broke his ribs while exiting his bucket, and another middle-aged worker fell during egress practice, striking his face.
Sometimes it’s easier for us older guys to wait for the mechanic. It’s not difficult to see how any one of these situations could occur, turning a great idea into an unnecessary injury or death. If you are considering employing self-egress systems, the employer must be careful to adopt a training and evaluation program, ensuring every worker issued a self-egress system is competent to use it safely. We came across some great programs while researching this Q&A and might ask the developers of those programs to write about what they have done at their utilities. For the employer that chooses to adopt these devices as part of a safety or emergency rescue plan, training and maintenance of the equipment must meet the guidelines of any other component for training and retraining of employees. Workers also must be trained to recognize when the devices should and should not be employed.
Q: In your opinion, what is the cardinal electric safety rule?
A: We once heard the following cardinal rule from a human performance specialist: Do not take sleeping pills and laxatives together before you go to bed. So it seems that cardinal rules are based on perspective and that they differ according to environment. No one has ever asked us this question before, so we decided to list a few responses from some of iP’s Q&A consultants and then add some discussion.
1. Stay in the truck. This response initially sounded like it was a blow-off, but it isn’t, although it is kind of funny. “Ensure the effectiveness of your training” is a better way of stating it. If you do it right, an employee never goes beyond the point that his training does not protect him. It is the beginning of training for any workplace. If you teach the novice to understand and respect that imaginary line at the hazard, he will not cross it. The point here is that until you are familiar with the hazards and risks, you simply don’t go near the hazards. We may not often think of this as a cardinal rule, but it should be one.
2. Know the difference between energized and de-energized. In many incidents workers assumed the lines and/or equipment were de-energized. What does de-energized mean? The NESC definition for de-energized is “disconnected from all sources of electrical supply by open switches, disconnectors, jumpers, taps or other means.” Note: De-energized conductors or equipment could be electrically charged or energized through various means, such as induction from energized circuits, portable generators or lightning.
The word de-energized can become confusing, so using “dead” or “at zero potential” may be more appropriate terms for your workplace. Train your workforce to use common terms so that they effectively communicate when discussing the work and safety plan. Lines and equipment must be disconnected, tested for absence of nominal voltage using a live-dead-live test and grounded using an effective equipotential zone method. Grounding methods must ensure the work area, wire and workers are at equipotential to ensure the elimination of shock hazards.
3. Work practices should only allow two methods of work: full energized work (working it hot) or assured grounded work (at equal-potential method). Work methods should never allow anything in between these methods. The idea here is to eliminate those times when workers leather-glove a line behind an open disconnect without grounding. Too many situations have occurred in which workers had a circuit inadvertently energized by some unexpected source when they assumed they had it controlled by a switch. If your cardinal rule is only two methods, it’s either worked hot or worked at equipotential.
4. One of our consultants sent us several of his favorites. With these comes a lesson in implementing a culture approach to hazards. When you train on these topics, adopt a refrain – a phrase or sentence repeated constantly and consistently – as you instruct. The refrains are the cardinal rules. If you use this tactic every time your trainees approach these scenarios, they will hear the cardinal rules in the backs of their minds even when you aren’t around.
• Never touch two points of different potential at the same time.
• Use protective cover and rubber PPE (two barriers).
• Protective tagging (lockout/tagout).
• Always test potential before installing grounds.
• Phase test cables before connecting live conductors.
• Test personal protective rubber before each use.
• Grounds: first on, last off.
• Connecting: neutral first.
• Disconnecting: neutral last.
• Always wear fall arrest and restriction equipment as required for your job.
• Communicate your work and task with your team.
• Test atmosphere before entering confined spaces.
5. If we’ve never done it before, it’s more dangerous. The last rule is a result of years of incidents that occurred when a new problem was approached. This cardinal rule instructs the crew to stop and address the new task and the elements of the task. It forces them to ask the question: “Since we’ve never done this before, what is it about this task we don’t know and how can it hurt us?”