Incident Prevention Magazine

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 [email protected]
Jim Vaughn, CUSP

Train the Trainer 101: Telcom Workers Don’t Need FR – Or Do They?

The question that is the title of this installment of “Train the Trainer 101” originally came to me from a client during safety training for the company’s distribution employees. The client is a T&D contractor with a telecommunications (telcom) division. And yes, the question was regarding arc flash, which is not the same thing as FR. To utility workers, FR formerly meant “flash resistant.” The acronym FR was stolen from the utility industry by the road construction industry for traffic safety vests and now has come to stand for “flame resistant.” Flame resistance is the quality of a material designed for protection from exposure to fire or flame, not electrical arcs. OSHA, which does not use “FR” in the standards, requires that arc flash protective clothing also must be flame resistant to ensure clothing does not continue to burn after exposure to an electrical arc. In addition, flame resistance is required for the outer layer of clothing worn by an electrical worker who could be exposed to a heat source that could ignite that outer layer. There has been confusion, so it is important to recognize that use of the term “FR” on a traffic vest label does not mean the vest is arc protective; it is only flame resistant, meaning it has resistance to burning and will not continue to burn if the flame exposure is removed. It’s a habit to use the term FR when referring to arc flash protective gear, but we all need to understand the difference in labeling.

Now, back to the initial question. My first thought upon hearing it was that telcom workers are not required to use FR. After all, telcom is regulated by OSHA 29 CFR 1910.268, and 1910.268 does not require arc protective clothing like the 1910.269 standard does. But the answer doesn’t end there. So, if you are in the telcom business, don’t stop reading here. This is a lesson on interpretation of the standards as much as it is an answer to the question, who is required to wear arc flash protection?

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Jim Vaughn, CUSP

February-March 2019 Q&A

Q: We have crews working under a clearance on a de-energized circuit jointly controlled by two different utilities (employers). The concern is that the other employer’s personnel, wishing to bundle maintenance opportunities during the outage, are taking protective relays out of service on their end of the circuit. If a switch were inadvertently closed on their end, taking their relays out means no tripping protection since the other end of the circuit is open, too. Such an action could delay if not eliminate relay protection and raise current on the grounds protecting our workers. Is there an obligation between utilities to manage an outage under common rules?

A: There is an OSHA-based solution that comes in two parts. And even though your question is about grounding and tripping during inadvertent re-energizing, the solution to the issue actually lies ahead of grounding.

As you are aware, OSHA 29 CFR 1910.269(m) contains the rules for de-energizing lines and equipment for the protection of employees. That rule section is the pre-eminent means of ensuring no switch is ever closed without the permission of the employee in charge of the equipment or lines that have been de-energized and placed under their control. As you noted in your inquiry, we ground a circuit after the clearance process to ensure against any possibility of re-energizing. The grounding is based on an evaluation of relay trip settings to assure effective tripping to protect the crew under the clearance. Any change to the values or trip settings puts the crew at risk.

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Jim Vaughn, CUSP

Train the Trainer 101: Solving PPG – Without Electrical Math

This installation of “Train the Trainer 101” may have an odd title, but it was inspired by some recent conversations I’ve had. I’ve learned a lot about personal protective grounding (PPG) in the past 20 years, and I continually learn even more as others share their research and experiences. Some time ago I learned that much of the fundamental electrical math upon which electrical circuit theory is based does not adequately explain the risk from high currents imposed on grounded systems. That does not mean there are not theoretical explanations for all of the results in high-current fault testing. But the simple circuit math of Ohm’s law cannot explain the complex electrical physics that occur in a high-current fault, and that is partly what confuses the issue concerning EPZ.

What is simple is this fundamental of worker protection: It takes 50 volts to break the electrical resistance of a worker’s skin. If you can break the electrical resistance of the skin, current can flow, and the worker can be injured. However, if voltage cannot penetrate the skin, current cannot flow. You cannot eliminate system current by grounding; you can only divide it (i.e., send most of it through a different path) and hope for the best. But you can eliminate voltage in the worker exposure. You eliminate voltage potential by bonding. Once you’ve eliminated the voltage potential hazard, current no longer matters and thereby the risk is altogether eliminated.

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Jim Vaughn, CUSP

December 2018-January 2019 Q&A

Q: With all the talk about grounding, cover-up, EPZ and minimum approach distances, we have been debating the best practice for setting steel poles in energized 138 kV. A big question is, what class gloves should ground personnel wear while handling the pole? How can Class 3 or 4 gloves protect against 138 kV?

A: The short answer is that a Class 4 glove won’t protect against 138 kV. However, if you do it right, there is a very good chance you won’t be exposed to 138 kV even if you do get the pole in the 138. Here is how and why. At transmission voltages, we rely on planning, equipment setup, and precise/predictable control of the equipment and airspace to prevent contacts. We then take additional equipotential bonding actions to protect against a worst-case scenario like loss of control and pole contact with a circuit.

Here are some recommendations for those additional actions. Grade the work area. Grading the area flat around the pole hole gives the crew space for equipotential mats or grids. In best-case planning, it is ideal to stand the pole up with little hands-on contact until you get to the grabbers. If you are using portable mats, the prime location is at the stand-up/grabber location. During handling, the crew members on the pole butt will be in an EPZ. The pole then gets swung to the hole without crew contact. At the hole, mats are used to line the hole for crew who will handle the pole setting. Many crews are now using cattle panels as grids to create equipotential mats in the pole-setting areas. The panels are available at feed stores, constructed of welded #4 steel wire and bonded to the ground rod to create a large walking area around the pole-handling area that will be at equal potential with the pole.

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Jim Vaughn, CUSP

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.

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Jim Vaughn, CUSP

October-November 2018 Q&A

Q: We were recently sticking distribution for a small utility when the utilities inspector stopped us for not having safety latches on our hot hoist. We have now been told that OSHA requires safety latches, but we can’t find a rule for that in the OSHA 1910.269 standard. What are we missing?

A: This answer will surprise and confuse some safety folks, so we want to remind you that we are not necessarily advocating the information we provide – we are educating readers on the rules and best practices. In response to your question, you are not missing anything; there is no OSHA rule for our industry that requires safety latches on hooks. Latches make sense. With a latch, connections do not unexpectedly separate. However, hooks under strain do not unexpectedly separate either. Most hooks for hoists have a tab for installing a latch. Many come with latches, and many do not. In hot-sticking applications, it often is difficult to open a latch and remove a hook from a sling. OSHA does, however, have safety latch requirements for some vertical standards that have no effect on utilities.

Q: When does OSHA consider a pole hole an excavation requiring a barricade?

A: It depends on whether or how long the pole hole is open and/or unattended. The preamble has a discussion on pole holes in which OSHA, in a fit of practicality, agreed that if the hole is bored and the pole is set within a reasonable time – being tens of minutes – there is very little practical reason to install fall protection. However, if the hole is large enough that a worker could fall in even with the pole in place, then some measures should be taken. As a contractor, we would ensure spoils were stable and lay 6 to 8 feet of 12-inch scaffold board across the holes between pole and spoils to ensure stable footing and no void large enough that a person could fall through. The other issue is, a hole for what pole? Distribution is not an issue. Transmission starts to need activities for protection like the above. Some transmission holes are 50 inches for a pole that’s only 36 inches to allow for concrete ballast. Those are excavations. We know many contractors that have used half of a round hay-bale feeder from Tractor Supply Co. as a guardrail.

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Jim Vaughn, CUSP

Train the Trainer 101: The Value of a Site-Specific Health and Safety Plan

If you follow OSHA’s guidelines, you train your workers to perform hazard analysis. You probably have a tailboard process as well, although your company might have a different name for it. Tailboards and crew hazard analysis are fundamental leading indicators of a good safety program. But hazard analysis and tailboards are only two elements of what really makes a difference in a safe approach to work. A health and safety site-specific plan (HASSSP) and the HASSSP process bring with them innumerable benefits – not just prevention of unwanted incidents.

When I was a contractor safety manager, I wrote a site-specific plan for every project. I started doing so about 15 years ago, after a series of preventable incidents and conditions that wouldn’t have occurred if I had provided prevention information to the supervisor and crew prior to the events. It occurred to me that for all the planning our company did, we missed some pretty big issues – issues that cost us pain and treasure.

A health and safety site-specific plan is not just a contractor tool. Many utility projects will benefit from a HASSSP since the level of detail for the plan itself is relative to the type and complexity of the work. Contractor HASSSPs typically are more detailed and developed if the local area is new to the company and particularly if the contractor is hiring new personnel for the duration of the project. The HASSSP is the product of prework research and analysis of the worksite and conditions that can or will affect crew performance or success.

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Jim Vaughn, CUSP

August-September 2018 Q&A

Q: I am brand new to the safety side of contracting and need guidance on finding information about heat stress. There are lots of guides on assessing heat illness as it occurs, but what about industry practices to prevent heat stress? What do successful heat-stress prevention plans look like?

A: We have three recommendations for you. First, some state plan safety and health agencies – such as California’s – have mandatory program requirements that include trigger temperatures. When a worksite reaches such a temperature, certain site practices for heat stress must be employed. Section III, Chapter 4 of the federal OSHA Technical Manual (see www.osha.gov/dts/osta/otm/otm_iii/otm_iii_4.html) also has detailed information about heat hazard assessments and programs.  

Second, call your local hospital or favorite occupational medicine specialist and review your heat-stress prevention plan with them. In the past, I have offered to pay a fee to have a doctor visit a safety meeting to talk about prevention, although doctors usually will come to speak for free.

Third, do just as you have done: Ask questions, and share information with individuals and companies that have good, effective programs.

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Jim Vaughn, CUSP

Train the Trainer 101: Enforcement of Vehicle Weight and Load Securement Rules

In the past few months, I have received comments and inquiries from all over the U.S. regarding what appears to be stepped-up enforcement of both load securement and vehicle weight rules. It’s not unusual that these topics garner attention from the U.S. Department of Transportation when it comes to carriers, but this recent uptick seems to be for smaller commercial vehicles, mechanics trucks, pressure diggers, and bucket and digger derrick trucks.

Not all utility safety professionals may be up to date on this topic because DOT issues are not front-burner issues. Typically, the human resources department handles a driver’s qualification file and drug testing for the DOT. Drivers at utilities only spend a few hours a week on the road between calls and jobs, idling most of the workday. We recognize that there are utilities with rigorous DOT management programs for equipment and drivers, but generally we find a more lax daily inspection protocol among utilities and contractors than you would find with a carrier. That might be justified considering the time a utility truck spends in transit compared to a carrier that is preparing to put a rig on the road with two drivers for 20 hours a day over the next two weeks. But it’s not the rule, and mistakes or latitude over trucks can suddenly become a serious liability when one of those overlooked trucks loses a steering link as it is driven through a school zone full of first-graders.

Craft Worker Compliance
Recently there have not been any changes of note in the rules for vehicle weight and load securement; however, it appears that some of the latitude taken by utilities, if not given by the DOT, has caught the attention of those responsible for enforcement of the rules. 

In the last couple of years, state enforcement agencies used local media to inform local commercial businesses – that are not carriers – that they would be stopped if they did not appear to comply with loading and marking standards for their class of vehicles. In Arizona, New Mexico, Washington and Colorado, my colleagues and I began to hear of roadside stops involving lawn maintenance companies and small construction concerns that were pulling dual-axle, 5-ton trailers behind a Ford F-350, carrying loaders, backhoes and super lawn machines. That soon extended to power company trucks, especially those loaded with large wire reels. I even heard of one instance in which state enforcement set up scales in a shopping center parking lot on a well-known route out of a power company service center. Within 40 minutes they cited 22 vehicles for being overweight. You would think drivers would have warned others, but the DOT waved them into the parking area before they started weighing and inspecting the vehicles, so no one knew what to expect. It shouldn’t have been – but it was – a big surprise for that utility’s fleet management to learn what kind of loads lineworkers were putting on those trailers.

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Jim Vaughn, CUSP

June-July 2018 Q&A

Q: Whenever we see graphics for single-point grounding, it’s always a cluster, a connection to the neutral, a connection to a phase and a chain connecting to the other two phases. But when we check with other utilities or consultants, we see all kinds of arrangements, such as bracket grounds with a single point or two sets of single-point grounds bracketing the workspace. Where do we find the definitive arrangement, and why are there so many variations?

A: Under OSHA, the employer is solely responsible for determining how they will meet the requirements of 29 CFR 1910.269(n)(3), “Equipotential zone,” which requires that grounding of de-energized phases be installed in an arrangement that prevents employees from being exposed to differences in electrical potential. In addition to 1910.269(n)(3), there also is Appendix C to 1910.269, “Protection From Hazardous Differences in Electric Potential,” as well as IEEE 1048-2016, “IEEE Guide for Protective Grounding of Power Lines,” a consensus standard that may be considered the authoritative best practice. IEEE 1048 is filled with detailed electrical data – from modeling to application – to explain how to create equipotential protection and effective tripping of grounded circuits that may inadvertently be energized.

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Jim Vaughn, CUSP

Train the Trainer 101: Current in Grounds Can Kill

Over the past six months, three things have happened that I want to mention. First, I have answered numerous questions from clients and Incident Prevention readers regarding personal protective grounding (PPG). Second, the industry has experienced a rash of injuries and fatalities related to current in grounded circuits. The incidents most often have been associated with induction, but not always. And third, I have consulted with utilities and contractors, large and small, who are just now recognizing they have issues understanding PPG. It’s been hard to gauge the numbers – such as the frequency of incidents and especially comparing the seriousness of injuries – because there is no reliable clearinghouse for tracking incidents other than fatalities reported to the U.S. Department of Labor.

All of this is beside the real point, however, which is that there is no reason for any of these incidents to have occurred at all. Well, there is one: The utility industry is behind the curve in their understanding of the phenomenon of current in grounded conductors. There is an explanation for that, and it’s time to write about it again.

Let me be clear: The purpose of this article is to work toward solving the problem, not to find fault. To understand how we got to where we are, let’s first talk about industry awareness. Anyone who does research on the fundamentals of utility system grounding will notice that we have been struggling with PPG since as early as the 1950s. This has been documented in various papers from the IEEE archives of “Proceedings of the IEEE” – one of the first electrical industry journals, established around 1927 – and in “IEEE Transactions on Power Systems” since 1985.  

As the IEEE 1048 standard, “IEEE Guide for Protective Grounding of Power Lines,” points out in the introduction to the 2003 edition, “Protective grounding methods have often not kept pace with their increasing importance in work safety as the available fault current magnitudes grow, sometimes to as high as 100 kA, and as right-of-ways become more crowded with heavily loaded circuits, leading to growing problems of electric or magnetic induction.” Did you notice the date of the standard? The 2003 edition is a revision of the 1990 standard on protective grounding. As I stated earlier, we’ve been struggling with PPG since as early as the 1950s. Over 60 years is a long time to still not have figured it out.

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Jim Vaughn, CUSP

April-May 2018 Q&A

Q: Recently an event occurred during a trouble job that surprised us. We had an underbuild phase down that was broken midspan. Our crew was working from an insulated bucket, and we grounded both the feeder we were working on and the one above. While our crew was beginning to crimp the splice for the repair, an energized line a few spans away came in contact with the grounded phase our lineman was in contact with. The lineman was in an insulated bucket, but he still received a shock. He was not seriously injured. Can you help us understand this?

A: The explanation is simple. Grounded circuits will still have current flowing through them if they are energized. Where there are resistances in parallel paths with the grounded circuit, there will be a voltage drop and there will be current flow through the parallel path. The current level is limited by the resistance in the path. Insulated bucket trucks are not totally isolating. To confirm that, all you have to do is look at the electrical tests performed on insulating booms. The current flow on an insulating boom is limited to a value well below the current necessary to injure a worker. In your case, there was voltage drop in the gap between the grounded, energized phase and the insulating boom that was a path to ground. Your lineman bridged that gap when he was in contact with the phase while standing in the bucket. The voltage was high enough to penetrate his skin so that current could flow. He was protected from injury by the current-limiting function of the insulating boom. We know it takes about 50 milliamps of current through a worker to rise to the level of injury. Depending on the electrical integrity of the boom and the voltage involved, there were – and this is just a guess based on boom-test protocols – perhaps 50 microamps to 1 milliamp of current that could flow on the boom. That is well below the level of injury. Electrical integrity of the boom is paramount in protecting workers. That is why it is critical to wash and maintain the boom.

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Jim Vaughn, CUSP

Train the Trainer 101: Lessons from Puerto Rico

I read the menu board and placed my order through the drive-through speaker. In her native Spanish, the employee assisting me rapidly confirmed my order and asked several follow-up questions; I answered “yes” to each question even though I didn’t understand what she was asking me. In the end, the order totaled $9.62. When I opened the contents of the bag, it was like opening a Christmas present, since I had no idea what I had just ordered. And, well, it was Christmastime after all, even though I happened to be in Puerto Rico.

That experience was my first lesson as an American who only speaks English in a place where – although both Spanish and English are official languages – Spanish is the dominant language. Over the years I had wondered why non-English-speaking workers would indicate understanding during training when they didn’t understand. Now I realize it’s a case of assumptions. I thought I knew what the employee at the fast food restaurant was asking, but I was way off. I had never been on that end of the conversation, and now I have a fresh perspective on non-native English speakers and training in the U.S.

I also have a new appreciation for the people of Puerto Rico. While there recently, I was in daily contact with people who’d had no power for 12 weeks. And for some of them, they knew it would be many more weeks before they did have power – and that might be a little optimistic. Not one person was rude or even expressed aggravation at their plight. In contrast, I am aware of utilities that had their front-office glass shot up by angry customers three days after a storm passed.  

Even in Puerto Rico’s larger cities, such as San Juan in the northern part of the island and Ponce in the south, where some power has been restored, there are still few working streetlights or traffic signals. Driving outside of San Juan, where there is no working traffic control, has become a mix of jousting and bluff. The practice is to speed up to the intersection and see if anyone slows. If they do, you are in. If they don’t, you wait and surge forward at the next driver. Yet this contrived system of driving is absent the aggression and manic reaction you might expect. No one blows their horn, points a gun at you or even gestures. It’s how you get around, and everyone is simply working it out.

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Jim Vaughn, CUSP

February-March 2018 Q&A

Editor’s Note: This installment of “Q&A” addresses some common questions Incident Prevention receives throughout the year. Most are misunderstandings of the wording or intent of OSHA standards. From time to time iP has addressed the following scenarios – or similar ones – because they never seem to go away. In the following answers, the research or interpretation methods employed have been summarized to help readers become more familiar with interpretation and construction of the standards.

Q: Does OSHA 29 CFR 1910.269(l)(12), “Opening and closing circuits under load,” prohibit the use of non-load-break dropout fused switches or lifting of hot-line clamps to break loads? The rule reads as follows: “(i) The employer shall ensure that devices used by employees to open circuits under load conditions are designed to interrupt the current involved. (ii) The employer shall ensure that devices used by employees to close circuits under load conditions are designed to safely carry the current involved.”

A: This rule often is mischaracterized as prohibiting opening or closing under load using a non-load-break switch or a bare hot-line clamp. The rule does prohibit opening or closing a switch or hot-line clamp (“device”) under load if the employee performing the task could be injured by the act. If the employee can safely perform the act, there is no violation. To explain, there are two keys to properly interpreting this rule. One is the location of the rule; it is found in 1910.269(l), “Working on or near exposed energized parts.” The purpose of the paragraph is protection of employees, as stated in the section following the title: “This paragraph applies to work on exposed live parts, or near enough to them to expose the employee to any hazard they present.”

When OSHA reviews potential violations of the standard, they typically consider three issues: if there was a rule in place, if the employer knew about the rule and if an employee was exposed to danger by violating the rule. OSHA also will review consensus standards and best practices, as well as unadopted consensus standards, which sometimes are used in de minimis conditions and General Duty Clause violations. We know this because when we read public notice citations, we find unadopted consensus standard language used in the notice of violation without reference to the unadopted standard.

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Jim Vaughn, CUSP

Train the Trainer 101: No Windows

Two U.S. Navy ships recently were involved in collisions at sea. It seemed impossible that one event, involving the USS Fitzgerald, would even occur. Then, a second collision occurred in the same region. In fact, in the last year, the Pacific fleet has experienced four serious navigational awareness errors, which has raised a question: Could the Navy have become so slack in discipline and readiness that these events were destined to happen?

We all know that, just as in the military, frontline leadership in the utility industry has a direct bearing on performance in the field. Yet after-action analysis indicates that when the Navy incidents occurred, the front line performed above expectations, indicating their competency and competency in their training as demonstrated by the actions of sailors. As was expected of the military, a quick response by Command relieved the ships’ leaders of their duties, citing loss of trust. Was Command correct? Did the ships’ leadership lose trust, or was it something else?

Some speculation arose among naval defense analysts that hackers may have caused electronic mayhem. A naval ship’s protection system depends on its electronic eyes and ears. Systems have evolved greatly since the days of the direct-wired blip from the antenna to the screen interpreted by a trained radar man. Early radar sent out a specific frequency wave that was several meters wide. The return wave depended on density of mass to return a reflection of that same frequency wave. The blip was interpreted by a trained observer to differentiate between an enemy bomber and a flock of geese. Today’s electronic radar frequency wave shifts are as small as 1 millimeter. A radar reflection comes back as thousands of bits that are interpreted by a computer. The radar screen now delivers an information-laden message to the radar man, who reads and reports the information displayed to him – by the computer. Some reports suggest that contemporary radar used by the military can detect a suitcase-sized drone that is miles away. The same types of systems scan for other threats, such as missiles and warplanes. If a hostile force wants to disable such protection, hacking a ship’s digital protection capabilities would make it vulnerable.

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Jim Vaughn, CUSP

December 2017 Q&A

Q: I understand OSHA has made a final announcement on minimum approach distances. Can you explain the latest information?

A: On December 22, 2016, OSHA issued a memorandum to regional administrators regarding the enforcement of minimum approach distance requirements in 29 CFR 1910.269 and 1926 Subpart V (see www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=31079). The memorandum had an effective date of July 1, 2017. Readers will recall that concerns about the rising risks of transient over-voltages were the basis for the increased minimum approach distances published by OSHA in 2014. The bottom line is that OSHA has accepted an industry engineering analysis – an IEEE paper titled “Practical Approaches to Reducing Transient Overvoltages Factors for Live Work” that was delivered at IEEE’s 2016 ESMO conference – as a basis for the final guidance of the memorandum. The guidance for enforcement is simple, but it is divided for above and below 72 kV. Following are the choices spelled out in the memorandum.

New Transient Table
The IEEE paper established a new Table A with standard transient multipliers based on voltage. The employer may still calculate their own minimum approach distances utilizing an engineering analysis approved by the standard using transients published in the new Table A.

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Jim Vaughn, CUSP

Train the Trainer 101: Practical Aviation for Power-Line Applications

It was a little over 40 years ago that a Vietnam veteran helicopter pilot in Florida made the first live-line contact with a live transmission circuit, bringing a quantum leap for power-line applications using helicopter methods. The FAA regulates what they call “rotorcraft” work with specific qualifications for pilots, flight crews and the airships and auxiliary equipment used.

Many utilities and contractors think helicopters – or HCs, in flyers’ lingo – are for use on difficult projects because of the expense. But I have been working with contractors for the last 15 years who recognize the value of HCs in construction and use them as often as possible. An hour of HC time may cost the same as the monthly rental of a bucket truck, but when you can clip, space, dame and ball 20 times the structures in a day over bucket access, the expense really makes sense. I also am aware that some contractors and utilities think HC use raises risk. I know that some utility clients prohibit HCs on their properties while others actively assist their contractors by prequalifying HC companies.

The primary use of HCs has been to string rope or, in some cases, hard-line for pulling wire in transmission construction using HC blocks. These blocks are equipped with a spring-loaded gate at the top of the frame. The gate has extensions that guide the rope into the sheave, provided the pilot is good enough. It looks easier than it is. Since Mike Kurtgis of USA Airmobile put his ship on a hot line in Florida, skid and rope-suspended work, inspection and insulator washing have continued to advance as accepted work practices. The FAA refers to working from a skid or rope (short haul) as “human external load,” or HEL. By some it is called the most dangerous work method in the line industry. In fact, even the FAA has a sense of humor about it, as noted in their wording of a safety requirement in the HEL rules. In guidance document FSIMS 8900.1, Vol. 3, Ch. 51, the FAA provides examples of the types of persons that can be carried on an HC skid – they include movie camera operators and clowns as two of those examples. We always assumed that the lineman with the nerve to work from the skid was not the camera operator.

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Jim Vaughn, CUSP

October 2017 Q&A

Q: We have gotten mixed advice from our colleagues at other utilities and can’t decide whether or not civil workers digging a foundation by hand in a hot substation should be required to wear arc protective clothing. They are inside the fence but in a new area approximately 20 feet from the nearest distribution structure. Where do we find the requirements or OSHA guidance?

A: That depends. Sometimes it depends on the criteria in the statutes, and sometimes it depends on compliance with company policy. Normally, following the guidelines of OSHA 29 CFR 1910.269(l)(8) – which establish the criteria for arc flash protection – excavation in a substation would not produce the type of work exposure you described that could create an arc flash. The location of the work and the type of work would not bring a worker within any distance of an energized bus or apparatus that would be a threat. If that’s the case, there would not be a requirement for arc-rated clothing for civil workers in a substation.

We are aware that there are utilities that require all workers, no matter what their craft or task is, to wear arc flash protective shirts while in a substation because it’s a company policy. But in regard to your question, it’s all about exposure. No exposure, no requirement for shirts. It is obvious that it’s not quite that simple for policymakers and risk analysts, who often are the people who make these decisions. Utilities must decide how to protect employees, protect the company and comply with the standards. That goal sometimes results in a blanket requirement as opposed to writing detailed criteria for when workers must suit up. The rules held by some utilities raise this question: If workers must wear arc-rated shirts, why don’t they have to wear arc-rated face protection? In fact, most of the inquiries we’ve made would seem to indicate the decision to require arc protective clothing in substations is more about gut response to the spirit of arc flash protection for contractors and employees than the result of arc flash analysis. Processes and knowledge are still expanding in the industry. As most would say, it doesn’t hurt for civil workers to wear arc protective shirts unless there is an unacceptable heat stress factor involved. In fact, there are some pretty lightweight pullover tees in Cat 2 that may help relieve both arc flash and heat stress.

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Jim Vaughn, CUSP

August 2017 Q&A

Q: We are a contractor and were recently working in a manhole with live primary cables running through it. We were cited in an audit by a client’s safety team for not having our people in the manhole tied off to rescue lines. We had a tripod up and a winch ready for the three workers inside. What did we miss?

A: This question has come up occasionally, and it’s usually a matter of misunderstanding the OSHA regulations. The latest revision of the rule has modified the language, but following is the relevant regulation. Look for the phrases “safe work practices,” “safe rescue” and “enclosed space.”

1910.269(e)(1)
Safe work practices. The employer shall ensure the use of safe work practices for entry into, and work in, enclosed spaces and for rescue of employees from such spaces.

1910.269(e)(2)
Training. Each employee who enters an enclosed space or who serves as an attendant shall be trained in the hazards of enclosed-space entry, in enclosed-space entry procedures, and in enclosed-space rescue procedures.

1910.269(e)(3)
Rescue equipment. Employers shall provide equipment to ensure the prompt and safe rescue of employees from the enclosed space.

This rule deals with enclosed spaces, not other spaces referenced in 29 CFR 1910.269(t), “Underground electrical installations.” Enclosed spaces are not, as many think, spaces with energized cables inside. In fact, the definition of an enclosed space has no mention of energized cables. What it does have is the single criterion for an enclosed space: Under normal conditions, it does not contain a hazardous atmosphere, but it may contain a hazardous atmosphere under abnormal conditions.

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Jim Vaughn, CUSP

Train the Trainer 101: Training and Verification Requirements for the Safety of Electric Utility Workers

A number of years ago I investigated a pole-top flash that took place during a transfer. The flash occurred when an improperly installed blanket left a dead-end flange exposed on the backside of the metal pole-top. During untying, the tie-wire contacted the exposed flange. No one was hurt. The issue was the lineman’s selection and installation of the blanket. The foreman assumed the lineman was experienced and competent to perform the three-phase transfer with minimal instruction. The problem was the lineman had spent the last several years on a service truck, had little transfer experience and had never worked a steel distribution pole. The foreman’s assumption was based on the fact that the lineman came from the IBEW hall. Even though they had never met, he assumed the lineman was sufficiently experienced – and so the root cause for the incident was established.

Training and verification of training for new, already-trained employees is another subject that has caused headaches for those professionals charged with OSHA training compliance and the employer liability that goes with it. OSHA, just like CanOSH, the agency’s Canadian counterpart, knows that training plays a huge role in incident prevention. It should be obvious that training prevents incidents, but the investigation of incidents across the continent proves that is not so. I have long said that the quality of your safety program and all of the component procedures, rules and policies that go with it, no matter how innovative and well-written, are only as good as the training you provide to the workforce. A safety program is supposed to protect the workforce first and the employer second. How can that happen if the workforce doesn’t know what’s in the program? And if the workforce doesn’t know what’s in the program, how does the employer expect the safety program to protect the employer?

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