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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

A Practical Review of the ANSI A92.2 Standard

This is a review of ANSI/SAIA A92.2-2015, “American National Standard for Vehicle-Mounted Elevating and Rotating Aerial Devices.” As a consultant, investigator and auditor, I have been surprised time and again that people who should know this standard do not know it that well. Most fleet managers are familiar with the rules, which is important because the A92.2 standard obligates owners of aerial lifts to be held liable for equipment they sell in certain scenarios. On the employee side, a working knowledge of A92.2 can prevent incidents and loss of life. In fact, a recent live-line barehand training class was what inspired this topic. We found that a bucket truck had the leasing company’s logo sticker adhered down both sides of the insulating boom section. That bucket truck was designed and rated for barehand use at 500 kV, yet a vinyl-plastic printed logo installed by the leasing company, spanning two-thirds of the insulation length, could have had some serious implications for the safety of that boom.

In this article, we are going to review some of the information covered in the A92.2 standard. Readers should recognize that ANSI/SAIA consensus standards are protected by copyright, so we will not directly reproduce the text of the standard itself. The A92.2 standard can be purchased directly from the ANSI website (https://webstore.ansi.org).

The target audiences of this review are the owners and users of aerial lifts (bucket trucks) as well as safety departments, with the goal of familiarizing those parties with both the safety aspects and owner responsibilities regarding aerial lifts. Unlike many consensus standards, A92.2 has been incorporated by reference into the OSHA standard, meaning that certain parts of the A92.2 standard are enforceable by compliance officers. In addition, the incorporated parts of the standard essentially are “living” – they have been published in the Federal Register and made available to the public so that updates to the A92.2 standard are automatically part of the legally enforceable federal OSHA standard. Now that we have the applicability of the standard covered, let’s take a look at what the standard requires.

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Jim Vaughn, CUSP

October-November 2020 Q&A

Q: We have a crew performing pole change-outs with the line energized. They are suspending phases with a link stick and digger derrick to provide more clearance between phases to install new poles and hardware. The question is, can the operator leave the controls with the phase lifted? We thought they could, but it seems there has been a change to OSHA 29 CFR 1926.1417(e).

A: The good news is that you cited the wrong rule. Pole change-outs fall under the 1910.269 operation and maintenance rules. You cited the rule for construction (OSHA 1926). The operation and maintenance rule – found at 1910.269(p)(1)(iv) – states the following: “The operator of an electric line truck may not leave his or her position at the controls while a load is suspended, unless the employer can demonstrate that no employee (including the operator) is endangered.”

Of course, it’s not as simple as that. The likely intent of both the operation and maintenance rule and the construction rule is to give an operator a break from the seat for inclement weather exposure or water or bathroom breaks. The issue with the construction rule is that the lift must meet “all of the following,” which are these requirements: no other duties for the operator, the operator stays next to the lift equipment, the equipment is stabilized and locked down, and barricades block the fall zone. Those requirements reflect the Cranes and Derricks in Construction standard (1926.1417(e)). The only requirement with the operation and maintenance rule is assuring no one is at risk.

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Jim Vaughn, CUSP

A Practical Review of the C2-2017 National Electrical Safety Code

In the June-July 2020 issue of Incident Prevention magazine, I made a mistake in the Q&A. I stated that there is no consensus on a particular procedure when, in fact, there is. It is new in the most recent edition of the National Electrical Safety Code, but I missed it when it was published in 2017. In light of my error, I decided I should take a closer look at the most recent revision of the standard and present my findings here for the benefit of iP’s readers.

The NESC is one of the consensus standards that I regularly recommend as an important resource – every safety professional should have a copy of it in their library. Here’s some important information about the use of consensus standards: First, the standards are more procedural than the OSHA performance language. “Performance language” means that a rule is written in a format that tells the reader what must be accomplished. Procedural language, on the other hand, tells the reader how to accomplish something. Second, OSHA classifies consensus standards into two categories, adopted and referenced. Consensus standards that are adopted are incorporated into the OSHA standards by references listed in 29 CFR 1926.6 for construction and 1910.6 for general industry. Referenced standards are adopted into the OSHA rules with the force of law and can be cited in compliance actions against employers. Consensus standards that are referenced are helpful to the employer, as OSHA puts it in the introduction to Appendix G of 1910.269. OSHA defines “recognized” consensus standards as “helpful in understanding and complying with the requirements contained in § 1910.269. The national consensus standards referenced in this appendix contain detailed specifications that employers may follow in complying with the more performance-based requirements of § 1910.269.” You will find the same referenced standards in Appendix G to the 1926 Subpart V construction standards.

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Jim Vaughn, CUSP

August-September 2020 Q&A

Q: I read what was written about an air gap for worker protection in the June-July 2020 issue of Incident Prevention magazine, but one of our engineers who sits on a National Electrical Safety Code advisory committee brought something to my attention. NESC C2-2017 444.2 states,  “Air gaps created (e.g., cut or open jumpers) for de-energizing equipment or lines for the purpose of protecting employees shall be tagged and meet minimum clearances as specified in Table 444-1 or separated by a properly rated insulator.” What are your thoughts on this matter?

A: Thanks for your question. Our thought is that your colleague is right regarding the table and we missed it.

To remind iP’s readers, in the June-July 2020 Q&A, we addressed what constitutes an air gap and stated that some utilities build their gap rules around minimum approach distance. We pointed out that MAD is a combination of minimum air insulation distance (MAID) and unexpected movement, which is 24 inches for distribution. We gave the example of a dropout switch that has an 8- or 10-inch-plus gap being acceptable where the MAID in a 15-kV distribution exposure is fewer than 2 inches for phase to ground. We could have worded it better, so we hope we didn’t give anyone the idea that MAID is all that’s necessary. In any case, we don’t want anyone to be misled by what we publish. 

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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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