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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

Arc Flash and Face Masks

Recently I have received numerous emails and phone calls regarding respiratory air-filtering masks rated for arc flash. I’m sure everyone reading this, no matter what country you’re in, is aware why that’s the case: the COVID-19 pandemic.

If you are a regular reader, you know it is my methodology to address topics by first citing the related safety standards in effect and then discussing the issue from a practical perspective typically related to the utility industry. This time is no different – for the most part.

Initially, the use of masks during the pandemic was limited as effective respiratory protection and still is for the public per the Centers for Disease Control and Prevention. As far as OSHA was concerned regarding workplaces, the only approved mask was the NIOSH-approved N95 filtering facepiece respirator (FFR). The N95 rating means that the mask meets the criteria for effective filtering of airborne particulates and moisture at 95%. The rating system also was established by NIOSH. It is important to understand that the N95 rating is based on the assumption that the masks are utilized by trained users meeting the OSHA respiratory protection worker training and fit-testing standard, which also can require a medical evaluation of the user.

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Jim Vaughn, CUSP

June-July 2020 Q&A

Q: Should we worry about beards in relation to arc flash? At our company, we think hair generally protects the body against extremes. Do you know of any evidence to the contrary?

A: Here is what we know: Human hair is protein fiber. It will burn when exposed to a flame but stop burning when the heat source is removed. Human hair does not melt; it becomes a fragile ash that turns to powder when crushed. This property is known as self-extinguishing. Hair is pretty much like cotton – it burns away. As such, it is not a hazard related to arc flash and actually provides some protection. OSHA does not address exposed hair any differently than the exposed body. It is up to the employer to decide if exposed hair increases employee risk as it pertains to arc flash hazards. If you were to analyze it from a practical perspective, you likely would agree with most of the safety experts we asked about it; they indicated that hair has a heat-insulating property and will not increase a burn hazard to the face provided workers abide by the appropriate arc flash standards of protection established by OSHA. However, there is an issue with some grooming products that may change the hair’s natural resistance to burning, which could be a problem for those lineworkers who use them.

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Jim Vaughn, CUSP

Train the Trainer 101: The ABCs of Grounding Mobile Equipment

Across our industry, I have found all kinds of policies for grounding trucks. I also have found that in many cases, employers’ rules for grounding trucks are not based on OSHA requirements and – even more concerning – are not based on sound principles of protection. I believe the grounding policies are well intentioned, but they fail to achieve two important goals: (1) meeting the OSHA standard and (2) protecting workers where electrical contact hazards exist. So, let’s take an ABCs approach to the issue because even though some detailed explanation is required, it really is that simple.

A Defensible Plan
You must be able to defend your plan or policy. This is the case for every plan or policy. Defense is built around establishing and accomplishing a goal, understanding the hazard, understanding the mitigation of the hazard, training at-risk employees, and conducting periodic audits to ensure the plan or policy is properly employed.

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Jim Vaughn, CUSP

April-May 2020 Q&A

Q: Recently we had an employee reference OSHA 29 CFR 1926.960(f) and 1910.269(l)(7), “Conductive articles.” The question is, can an employee work in an energized area while wearing jewelry, and earrings in particular? The rules discuss conductive articles such as watches, bands, rings and chains, but I do not see where it mentions earrings. 

A: When it comes to interpretation, it is good to confine a rule to the language used, but sometimes you also have to address the intent. The concern that drove the creation of this rule was whether jewelry, which is conductive, increases electrical contact risk. Those risks are twofold: (1) Does the jewelry make an electrical shock more likely, and (2) does the jewelry increase the damage or level of injury from an electrical contact? This rule does not fit well in the utility industry because its origin is the indoor electrical industry. Electricians rarely employ rubber gloves and were sticking their bare hands in energized panels in close quarters. Still, we can’t ignore the rule, but we can easily address it. As far as electric utilities are concerned, hands in close quarters to uncover bus or wire could cause a flash where jewelry goes to ground. You would get shocked anyway, but the jewelry could cause an arc flash, which increases injury levels with burned skin. That doesn’t really apply where we work unless your uncovered hands are in a meter can. The answer for either 1926 Subpart V or 1910.269 is in the wording of the rule, so look closely: “When an employee performs work within reaching distance of exposed energized parts of equipment, the employer shall ensure that the employee removes or renders nonconductive all exposed conductive articles, such as keychains or watch chains, rings, or wrist watches or bands, unless such articles do not increase the hazards associated with contact with the energized parts.”

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Jim Vaughn, CUSP

Train the Trainer 101: FMCSR Awareness

When analysts look at utilities, and to some extent utility contractors, they often see what’s referred to as “mission creep.” That occurs when the expertise of the utility should be focused on quality and continuity of service but begins to be compromised by focus on too many other areas. The opposite of mission creep is when business elements that are critical to successful progress toward the goal get overlooked because of focus on the goal. One business element that gets less attention than it deserves are big trucks and the Federal Motor Carrier Safety Regulations (FMCSR). Granted, 75% or more of the FMCSR do not apply to utilities, and many parts that do apply are difficult to implement. Implementation is tough because, even as employers with drivers and big trucks, we are not carriers, which is the target audience of the rules, but we still are regulated by those carrier-related standards. The key areas of compliance for utilities are driver qualification, record of duty status (RODS), safety equipment and load securement. There also are a couple of new initiatives that we should keep an eye on.

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Jim Vaughn, CUSP

February-March 2020 Q&A

Q: Where does OSHA’s switching and lockout/tagout policy draw the distinction between generating plants and the plants’ substations, particularly with metal-clad substations?

A: It depends more on the equipment used than a distinct line, and it has to do with OSHA’s intent, equipment design and practicality. Let’s look at this from the perspective of intent. OSHA intends that employers have an energy control plan that protects workers. LOTO was developed for that and has worked very well over the years. The data shows that LOTO has been directly responsible for a dramatic decline in severe and fatal incidents related to hazardous energy releases. The utility industry was ahead of OSHA with switching policies and procedures, and OSHA recognizes the effectiveness of that history.

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Jim Vaughn, CUSP

Train the Trainer 101: Know OSHA – or Pay the Price

There are two reasons why it’s problematic not to know OSHA. The first reason gets the employer in trouble. The other reason gets everyone in the utility sector in trouble. Let’s begin this installment of “Train the Trainer 101” with a discussion about the first reason and why it’s important to know OSHA from the perspective of rules and regulations.

There are some realities we need to acknowledge to understand the difficulties different employers face. These are generalities based on my experience; I do not seek to classify all sectors of the utility industry as the same. It is a reality that municipalities – and the contractors who work exclusively for municipalities – are more or less late to the OSHA table because OSHA has excepted government and subdivisions of government from complying with OSHA regulations. In the past, only municipalities in state plan states were under OSHA jurisdiction. As word and experience got out, more municipalities voluntarily expanded their safety programs, and municipal associations took a role in raising the awareness and safety consciousness of municipalities that were not accountable to OSHA. However, small contractors have a resource issue. Few small contractors with under 100 employees have full-time safety personnel, and many contractors with even larger workforces have no full-time safety personnel on their larger job sites. But lack of safety on job sites is not just reserved for smaller contractors. I see large utilities with roving safety personnel who are stretched so thin that their time is mostly spent getting ready for safety meetings and newly hired employees rather than auditing crews on work sites where threat meets flesh. For a safety program to work, there must be staff who are qualified to audit the workplace, know OSHA’s expectations for employers, develop compliance strategies and the related training and written procedures, and conduct safety training. There also must be site visits to audit performance and compliance, mentor crew leaders and members, assist in job planning, and review job site documentation like tailboards and work plans. If your safety department also keeps required Department of Transportation and safety training documentation, performs investigations, and keeps injury and incident documentation, that is another full-time layer of work.

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Jim Vaughn, CUSP

December 2019-January 2020 Q&A

Q: As a contractor doing transmission maintenance, we see many different constructions of statics at the tops of transmission poles and structures. They’re grounded, and we always thought they were safe to handle with leather gloves. Now we’re hearing that statics should be grounded temporarily for worker protection. What’s the explanation for that?

A: It’s called a “static,” but don’t forget that the voltage and current flowing on it is induction-coupled alternating current that will kill you. As an industry, there are a lot of utilities that have worked statics in leather gloves and have had no issues. There are others that had no issues for decades – right up until the day someone on their crew was injured by current on a static.

It’s not actually grounding that protects the worker; it’s bonding of the grounded static. Because of the hazard level associated with this discussion, we need to post a disclaimer here: Incident Prevention magazine publishes what it believes to be the best, most accurate advice available from industry experts, but the publication is not a training venue nor is it in the consulting business. It is the employer who is solely responsible for work methods employed in the field.

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Jim Vaughn, CUSP

Train the Trainer 101: Rigor and Discipline

The date was January 28, 1986. The event was the tenth and final flight of the Space Shuttle Challenger. Seventy-three seconds into flight, the booster rocket that was lifting Challenger into space exploded, killing all seven astronauts aboard.

When events like the Challenger explosion happen, you never forget where you were at the time. You remember the iconic photos and the national days of mourning for those lost. After the Challenger explosion, President Reagan appointed the Rogers Commission to investigate the disaster, and some of you may remember the news commentary on the Rogers Commission Report. If you didn’t study the reports from the incident, you likely aren’t aware of the stunning findings, the changes that were called for and, even more importantly, the effect the changes at NASA have had on industry – including the utility industry. It’s worth taking a look. You can read about lessons learned from the incident at https://ocw.mit.edu/courses/aeronautics-and-astronautics/16-891j-space-policy-seminar-spring-2003/readings/challengerlessons.pdf.

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Jim Vaughn, CUSP

October-November 2019 Q&A

Q: Are utilities required to have a written fall protection program that follows a written hazard analysis?

A: It’s not a bad idea because the process assures a fairly complete assessment of fall risks that makes training and protection of workers more effective. We know the source of your confusion because it’s a question we get often, and we’ve looked into it. It takes some deciphering, but here is how the confusion starts. We often hear of power and telcom companies reading OSHA 29 CFR 1910 Subpart D, “Walking-Working Surfaces”; seeing 1910.28, “Duty to have fall protection and falling object protection”; and begin writing complex compliance programs following the Walking-Working Surfaces rule. There is nothing wrong with a robust hazard analysis program that drives training, but if you are doing it to comply with a standard, you may not need to. If you read closely, you will find an exception for both telcom (see 1910.28(a)(2)(vi)) and electric power transmission and distribution (see 1910.28(a)(2)(vii)). The T&D exception relies on compliance with 1910.269(g)(2)(i).

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Jim Vaughn, CUSP

Train the Trainer 101: OSHA, Training and Certification

The occupational safety and health industry and civil authorities require that employers provide training to employees. In the U.S., OSHA mandates safety training related to tasks assigned to employees. The agency often also requires the employer to certify that the training has been completed. In fact, if you have an incident requiring OSHA notification, the first question that will be asked is, “Was the employee trained for the task?” The second inquiry will be a request for documentation of the training, usually followed by an enforceable subpoena for those training records.

Training and certification of training are important for two reasons. The first is that training has clearly been demonstrated to reduce incidents and injuries to workers. Second, OSHA will hold employers accountable for the training they conduct. The penalties for willful violation of training requirements are rarely discussed, and I hesitate to do it here, but the record shows that if an employer does not train, and OSHA can show the employer knew training was required, the penalties are based on willful violation. Penalties for willful violations that result in fatalities can include jail time for the employer. In addition, if OSHA wins a willful violation case, the employer can expect charges of negligence under both civil and criminal liability standards. Don’t take this training responsibility lightly. I, like OSHA, would prefer employers be compliant for the welfare of the workforce because they are ethical and care about their employees. But if the threat of prosecution works, we still accomplish the desired outcome: a safer workplace.

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Jim Vaughn, CUSP

August-September 2019 Q&A

Q: What is considered a forklift? We use wheel loaders equipped with accessory forks on our rights-of-way to unload and move poles and pole sections. We were told by our client’s safety inspector that the loader operators have to be certified as forklift operators because the loaders are equipped with forks. We have always used loaders and loader operators and never had an issue. Where do I find the information to resolve this issue?

A: OSHA refers to forklifts as powered industrial trucks or PITs, while the industry commonly calls them forklifts. OSHA’s construction standard has a section on material-handling equipment. The very last rule is 1926.602(d), “Powered industrial truck operator training.” The rule consists of a single note that states, “The requirements applicable to construction work under this paragraph are identical to those set forth at §1910.178(l) of this chapter.”

I have had people tell me that this rule means that operators of construction equipment using forks, like a loader, are required to be licensed or certified as a PIT operator. That is not the case. The PIT standard that contains forklift operation and training rules is found in the general industry rules. The second sentence of paragraph 1910.178(a)(1) states the following: “This section does not apply to compressed air or nonflammable compressed gas-operated industrial trucks, nor to farm vehicles, nor to vehicles intended primarily for earth moving or over-the-road hauling.” Wheel loaders are designed to move earth. They are not PITs even if they are equipped with forks.

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Jim Vaughn, CUSP

Train the Trainer 101: Manufacturer Warnings and OSHA-Compliant Safety Performance

Over the past few weeks I have received several inquiries regarding horizontal directional drilling (HDD). It’s not unusual in our industry for questions to make the rounds of utilities and contractors, generating interest and often controversy. I also have recently received several inquiries regarding OSHA allegedly canceling the digger derrick exemption in 29 CFR 1926 Subpart CC, “Cranes & Derricks in Construction.” OSHA hasn’t done that, but somebody said they did, and folks started asking around. Soon after, I received calls for clarification on the matter. In the digger derrick case, there was nothing to it; OSHA has not changed anything about the exemption. However, concerning HDD, there is an issue that raises an interesting question for those who administer compliance.

The point of the rest of this article is not to recommend or criticize any safety procedure associated with HDD. The point is to examine the role of manufacturer warnings and OSHA-compliant safety performance in the workplace. There is no doubt that I will get emails from HDD machine manufacturers and adherents of overshoe use, as well as overshoe sales or manufacturing representatives. I invite your response. To be clear, both Incident Prevention magazine and I are solely interested in providing an opportunity for perspective and analysis of a process that will help individuals learn how to deal with challenges in the workplace.

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Jim Vaughn, CUSP

June-July 2019 Q&A

Q: We experienced an event that has caused some confusion among crew and supervisors about what we thought we knew about grounding. We were working midspan on a de-energized 345-kV circuit. We drove a ground rod, grounded our trucks to it and grounded the phases to it. Almost immediately, we smelled hot rubber, and then tires started to smoke. Can you help us understand why this happened?

A: That was likely much more serious than hot tires. For the benefit of readers, we spoke with you on the phone, got details and shared opinions. Here is what happened: Your crew was in a right-of-way with very high induction. The ground rod you drove was very high resistance. When you connected your trucks, essentially you made a radial connection from phase to truck through the ground rod connection. In doing so, you loaded very high induction current onto the truck, which passed into the earth across the tires and outriggers. Many utilities by procedure use ground rods at midspans, and often it goes without problems. This is why we stress learning the principles of current flow in grounded systems. If you can ground phases to the very low-resistance static, the induction load is handled without much risk to workers on the ground. If you do have to ground your truck, and there is high induction, a well-driven rod isolated from the phase grounds might be a good choice. If grounding to the same ground electrode as the phases can energize the truck, as happened in your case, dangerous gradients can occur around the truck, and touch potentials between earth and truck can be deadly.

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Jim Vaughn, CUSP

Train the Trainer 101: Root Cause Analysis, Training and Lessons Learned

I’m not sure how I became an analyst. I don’t think it’s a career goal you necessarily plan for. My understanding of the analyst role is that it’s an individual who studies the elements of an event or occurrence. Analysts break down the elements of an event to learn how those elements are related. The purpose of analysis is to understand the nature of the event being studied. Through effective analysis, we ultimately create or assure desired outcomes and prevent or minimize the likelihood of undesired outcomes.

Over the past 10 years I have analyzed a half-dozen training accidents that occurred in apprentice training yards. Recently I also have seen a couple of videos of incidents involving apprentices in which no one was hurt; they were actually kind of funny to watch. But to an analyst, those videos have a lot more to offer than the lighthearted “been there” sympathy. Lineworkers often learn the hard way how not to do things. It’s that hard way that I want to eliminate because sometimes the hard way becomes the final act to what might have been a great life.

I was once engaged to write an opinion on a root cause analysis (RCA) that OSHA and a utility performed based on an incident that hospitalized three apprentices in a single event. OSHA only performs RCAs to identify where the employer may be at fault, but in this situation, the RCA listed all kinds of physical conditions and procedural mistakes that caused the incident. All of those items were causally related, but none were the real root cause. Before we move ahead in this edition of “Train the Trainer 101,” readers need to understand RCAs and how they fit into the lessons learned from training accidents.

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Jim Vaughn, CUSP

April-May 2019 Q&A

Q: OSHA’s digger derrick exception – found at 29 CFR 1926.1400(c)(4) – includes digger derricks when they are used for augering holes for poles carrying electric or telecommunication lines, for placing and removing the poles, and for handling associated materials for installation on, or removal from, the poles, or when used for any other work subject to 1926 Subpart V. Substations are included in Subpart V, so why do some people say setting steel or regulators is not covered by the exception?

A: You might try to justify substations as being in Subpart V – except for what the substation rules cover in Subpart V. OSHA 1926.966, “Substations,” is not about construction of substations. It is about working in substations. The rule covers minimum approach distances, guarding of live parts, switching and electrical safety. Steel erection, just like concrete work, falls under horizontal standards. 

The logical thinking of very reasonable people regarding this issue often is challenged for sensibility, mostly because of their perspective. For instance, if I can hang a capacitor on a wood pole with a digger derrick, why can’t I hang a beam and capacitor in a substation with a digger derrick? It’s the same thing, it’s a capacitor. The right perspective is that all construction-related lifting of loads by cranes is regulated under 1926.1400, except lifting poles and pole-mounted equipment that are installed using a truck specifically designed for digging and setting poles. 

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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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