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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: 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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Jim Vaughn, CUSP

June 2017 Q&A

Q: We have a group reviewing our personal protective grounding procedures, and they are asking if we should be grinding the galvanized coating off towers when we install the phase grounding connections. What are your thoughts?

A: In addition to your question, we also recently received another question about connecting to steel for bonding, so we’ll address both questions in this installment of the Q&A. Your question is about the effectiveness of grounding to towers, and the other question is about the effectiveness of EPZs created on steel towers. We’ll discuss the grounding question first and then move on to the EPZ question.

As to grounding effectiveness, we have two thoughts here – one simple and one that likely will raise more questions than we can resolve in these pages.

The simple thought is this: Consider grounding to the circuit static. It’s difficult to reach but doing so makes it easier to create an electrical connection. Using the system static shares current with adjacent structures and reduces current on the structure being worked. Dividing current among adjacent structures also reduces ground potential’s risks to workers at the foot of the tower. See the following Q&A regarding EPZ if you are grounding to the static.

As to connecting to the tower, grinding off the galvanized coating opens the underlying steel to corrosion and would need to be replaced after the operation. We have asked how utilities make connections and found that most use a flat clamp to a brushed plate or insulator bracket, or a C-clamp to a brushed bolt or step. Either method is a good one. Others follow one of the recommendations in IEEE 1048, “IEEE Guide for Protective Grounding of Power Lines,” 9.2.1.1 for lattice using a ground cluster. The cluster serves two purposes: providing a clamping connection and keeping the clamps close together.

Fortunately, the structure connection can be installed by hand, making the cleaning and mechanical security of the connection pretty reliable. There are several considerations to discuss that should be part of the training provided to lineworkers who make these connections.

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Jim Vaughn, CUSP

Train the Trainer 101: Addressing Common Fall Protection Questions and Concerns

To begin this article, I want to offer a disclaimer. One of the reasons the “Train the Trainer 101” series was created is to examine the practical aspects of compliance as they relate to the utility industry. We do that by reading the statutes, looking at how OSHA interprets and enforces the rules, reviewing what the consensus standards state and then determining practical ways the employer can manage and comply with the rules. Sometimes I raise an eyebrow, but in working with the group of professionals who review every article published in Incident Prevention’s pages, we endeavor to ensure the advice given is not merely good but also compliant. With that said, in the following pages I am going to address some fall protection issues that iP has received many questions about in recent weeks. Several of them are driven by the latest OSHA final rule on walking and working surfaces, which contains some new language and expanded rules on fall protection.

Who is Responsible?
I get a lot of questions about fall protection that stem from a salesperson telling an employer they need to do a certain something in order to comply with OSHA. First, a nod to our partners in the industry: the vendors and manufacturers. They have done a great job meeting the needs of the employer by innovating, creating and often collaborating with the industry to get the tools we need into the field. Work with your vendors and manufacturer representatives, but be clear about your responsibilities in the relationship. Understand that there are no OSHA-approved devices for sale in any marketplace. OSHA does not approve equipment for manufacturers even though they may comment on a method of compliance if a written request is made by an employer. Even then, OSHA’s language to the employer often is something such as, “OSHA does not approve a particular device or piece of equipment, but the method you describe would meet the requirements of the standard.” And never forget that – no matter what the manufacturer’s rep says – you, as the employer, are ultimately responsible for how you comply with OSHA’s expectation. As I said, work with your vendors, but do your homework and educate yourself about the requirements. We aren’t just complying with standards – we’re protecting our employees and co-workers.

Common Misconceptions About Harnesses
I have often heard that you can’t arrest at the waist or chest. That is correct if you are truly arresting, which usually means the act of interrupting a fall from height by a personal fall arrest system attached to an anchorage limited to a distance of 6 feet. If you fall 6 feet, you must limit the fall arrest’s load, and the fall arrest’s load must be distributed across the body. That is why we use a full-body harness.

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Jim Vaughn, CUSP

April 2017 Q&A

Q: Our plant safety committee has a longtime rule requiring electrical hazard safety shoes for our electricians. We were recently told by an auditor that we have to pay for those shoes if we require employees to wear them. We found the OSHA rule requiring payment, but now we wonder if we are really required to use the shoes. Can you help us figure it out?

A: Sure, we can help. But first, please note that Incident Prevention and the consultants who have reviewed this Q&A are not criticizing a rule or recommending a rule change for any employer. What we do in these pages is explain background, intent and compliance issues for workers and employers in the workplace.

You mentioned a longtime rule that probably dates back to the early OSHA rules that required electrical hazard boots for electricians. We can’t remember exactly when, but there was a letter to administrators in the early 1990s and subsequent rule-making that changed the language on the use of electrical hazard shoes. Your auditor is right; if you require employees to wear them, you are required to pay for them because unlike regular safety shoes, the electrical hazard criterion makes the safety shoe a specialty shoe. Specialty shoes must be provided at no cost to the employee (see www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=29825).

Now let’s address the question, are the shoes required? Employers are required to perform a workplace hazard assessment and then use engineering or procedural controls to eliminate hazards. If a hazard cannot be eliminated by procedures or engineering, PPE is required. OSHA agrees throughout current literature that electrical hazard shoes are to be employed as part of a system of protection based on the hierarchy of controls. If you read the rule closely, you will see that the language is very particular. OSHA 29 CFR 1910.136(a) – edited here for clarity and space – states that the “employer shall ensure that each affected employee uses protective footwear … when the use of protective footwear will protect the affected employee from an electrical hazard, such as … electric-shock hazard, that remains after the employer takes other necessary protective measures.” Those other measures are the hierarchy first, PPE last.

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Jim Vaughn, CUSP

Train the Trainer 101: The New Walking-Working Surfaces Final Rule

OSHA’s final rule on 29 CFR 1910 Subpart D, “Walking-Working Surfaces,” is finally here. It’s 26 pages of nine-point font equaling 21,675 words, and I read them all. It’s big, and if you include the preamble in your analysis, it is also complicated. It was just as hard to write about as it was to read. I guess that shouldn’t be unexpected for a final rule that has been in the works since 1983. The original 1910 Subpart D was published in 1971. The first update was proposed in 1983, but it was never ratified. Proposals were again considered in either the Construction standard or the General Industry standard in 1990, 1994 and 2003. This edition of the final rule for 1910 Subpart D covers it all. OSHA should be congratulated for bringing almost all of the fall-related standards into one location, making it easier for the employer to find rules related to working surfaces under one subpart instead of having to search for those rules that may affect the employer’s workplace. This may be news to some novice safety professionals in the utility industry, but not all regulations affecting us are restricted to 1910.269 or 1926 Subpart V. Subpart D applies, so it is important to be familiar with it.

What’s New?
Preventing falls is almost the entire purpose of rules for walking-working surfaces. The surfaces are not always those spaces of aisles between walls. Most walking or working spaces in the workplace are not defined aisles; they are more likely to be incidental spaces about the work area. It is quite easy for those incidental spaces to be encumbered by tools, materials and process waste that create stumbling or tripping hazards. In addition, many of those working spaces are raised surfaces, from the tops of foundations to the tops of skyscrapers. That being the case, OSHA has brought into Subpart D the body of fall protection standards. You will now find a greatly expanded section on ladders; step bolts (towers) and manhole steps; scaffolds and rope descent systems (building maintenance); the duty to have fall protection; new and expanded requirements on fall protection equipment design; and some expanded language on the training of employees to recognize and prevent falls in the workplace.

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Jim Vaughn, CUSP

February 2017 Q&A

Q: We are a small, distribution-only municipal utility that has been looking into human performance. We are having some trouble understanding it all and how it could benefit us. Most of the training resources are pretty expensive. Can you help us sort it out?

A: We can. Human performance management (HPM) has been around in various forms and focuses since before the 1950s. Throughout the ’50s and ’60s, it seems the focus was on companies performing functional analysis and correcting issues that created losses, thereby promoting more efficient and error-resistant operations. In the ’60s and ’70s, much of the literature on HPM seemed to surround the nuclear power industry, and indeed the introduction of HPM into the transmission/distribution side of the utility industry appears to have come through the generation side. In the ’70s, researchers began to experiment and write about more closely analyzing the knowledge and skills of the performer. It took a while to sink in, but the safety industry began to research HPM as a culture analysis and risk prevention tool. It makes sense. Human performance – in particular knowledge, skills modes, decision-making modes and performance – affects all of every enterprise whether you have an HPM program or not. Organizations are made of people. HPM has identified and categorized commonalities in types of personalities that predict how people make decisions and perform tasks. Studying human performance also can help identify safety culture issues and risk behaviors. It’s not a big or expensive step to train your workforce on problem-solving and decision-making characteristics of the human mind. Soon they will understand their own processes and the limitations of the way they naturally think, allowing them to make adjustments toward better performance. So if we can take advantage of HPM to prevent incidents, why not do it? Most organizations start small. Pick a few key people to begin training on the basics of HPM, and then look at your organization to see where the initial undertakings can do the most good. There are several experts associated with Incident Prevention who will be glad to help should you need it. Additionally, on the iP website (www.incident-prevention.com) you can find numerous HPM articles in the iP archives as well as information and training sessions from past iP Utility Safety Conferences. HPM works. We hope you will pursue it.

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Jim Vaughn, CUSP

Train the Trainer 101: Understanding Canine Behavior for the Protection of Utility Workers: Part Two

In the last installment of “Train the Trainer 101” (see http://incident-prevention.com/ip-articles/train-the-trainer-101-understanding-canine-behavior-for-the-protection-of-utility-workers), I provided information to help utility personnel understand, in part, why dogs do what they do. In particular, I addressed the pack mentality, dominant and submissive behaviors, and when and why a dog may feel threatened and try to attack. In the conclusion to this two-part article, I will explain how best to respond to unfamiliar dogs and what to do if you are attacked, as well as discuss breeds that are more commonly involved in biting incidents.

How to Respond to Unfamiliar Dogs
A dog’s response to a stranger will vary depending on whether he is with a handler or alone. When the dog is with a handler, remember what you know about the dog and human family relationship. The dog will respond to his handler’s actions as well as his own interpretation of an encounter with an unknown human. If you are the unknown human, speaking in casual tones to the handler, as well as the handler responding in a casual tone, will immediately set the dog at ease.

Workers in residential areas often are attacked by dogs who never posed a threat to people in the neighborhood. One reason behind this may be that workers focused on their task don’t exhibit the same mannerisms as visitors to the home or the people who frequent the property. This “unusual behavior” raises a dog’s suspicion and consequently his alertness level.

If you are walking toward a dog and his handler, stop a few feet away. If you are jogging or moving briskly, that may signal aggression to the dog. Stopping and allowing the handler and dog to approach you tends to reduce the dog’s alertness level.

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Jim Vaughn, CUSP

December 2016 Q&A

Q: We hear lots of opinions on whether a lineworker can lift a hot-line clamp that has a load on it. There is a rule that says disconnects must be rated for the load they are to break. We’ve been doing it forever. Are we breaking an OSHA rule or not?

A: Incident Prevention has answered this question before, but it won’t hurt to revisit it and use the opportunity to explain how OSHA analyzes a scenario to see if it’s a violation. Most objections to operating a hot-line clamp (HLC) under load are based on OSHA 29 CFR 1910.269(l)(12)(i), which states that the “employer shall ensure that devices used by employees to open circuits under load conditions are designed to interrupt the current involved.” There are some utilities that prohibit operating HLCs energized, and there’s nothing wrong with that. Our purpose at iP is not to judge an employer’s operational rules but to enlighten and educate the industry.

On its face, the rule seems to prohibit use of an HLC to break load. Anybody could also argue, then, that any operation of an HLC must be dead-break since HLC manufacturers offer no load-break value at all. However, there are several facets to analyze in this scenario. First, if a non-rated HLC cannot be lifted under load, how about a drop-out switch? We operate those thousands of times a day without injury to the employee, although sometimes an ill-advised operation does smoke a pole top. There is nothing in the rules that prohibits an employer from making an engineering-based decision establishing criteria or protocols for operating HLCs or drop-outs under certain load conditions. Primarily, the employer’s determination would be based on risk to the employee and risk to the equipment. For OSHA, the primary consideration would be risk to the employee. Just as in the working alone rule, if the device is operated by a hot stick from a position that prevented injury to the employee, there would be no violation. Second, what would be the solution in the scenario? If the solution required installing a mechanical jumper and installing a load-break switch, would such an operation add risk exposure to the crew, and would adding the switch really enhance the safety of the operation? At the very worst case, the scenario – operating the HLC under load – could be ruled a de minimis violation. De minimis is the level of violation where OSHA recognizes that a direct rule was violated, but there was no other way, or no safer way, of executing the required task, and there was no risk to the employee.

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Jim Vaughn, CUSP

Train the Trainer 101: Understanding Canine Behavior for the Protection of Utility Workers

Utility personnel are going to find themselves in confrontations with dogs. It is the nature of our work. How a worker responds during that type of engagement will have consequences that can be good or bad. The best consequence is when the parties go their separate ways and no one is left bleeding. Frankly, bleeding is not the worst outcome of these situations. People sometimes die as a result of confrontations with dogs, and the dogs can be hurt or killed, too. As a dog person, I would choose to see everyone walk away if at all possible.

While there is no magic formula that can be used to prevent you and your employees from being attacked by dogs, there are many good training programs out there and many good companies that provide dog attack prevention training. I have witnessed many training sessions and one thing is certain, not all of them provide the same information or approach. A few years ago I decided to perform some research on my own and compare it to what I knew about dogs as a longtime dog owner, a former dog breeder, and someone who is experienced with trained canine service members in the military and on police duty. I should also mention that some of my experience comes from four or five up-close engagements with big, seriously aggravated dogs in the backyards and pastures of utility customers. I can assure you that the nature of those incidents squared well with what I have learned over the years.

Now I must offer this disclaimer: Dogs can’t read. They don’t have the benefit of the wisdom offered throughout this two-part article (check out part two in the December 2016 issue of Incident Prevention). No one can account for or predict every dog’s response. What you read during the course of both of these articles will help you understand, in part, why dogs do what they do. You may also find some practical ways you can improve your chances of having safe experiences with dogs, both those that are friendly and those that are not so friendly.

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Jim Vaughn, CUSP

October 2016 Q&A

Q: What is meant by the phrase “circulating current” as it pertains to transmission towers? Does it have something to do with the fact that there is no neutral?

A: We’re glad you asked the question because it gives us an opportunity to discuss one of the basic principles of the hazard of induction. More and more trainers are teaching with a focus on principles instead of procedures, and we often overlook some of these basic definitions. The concept of circulation is associated with what happens in any interconnected electrical system. Refer to the basic definition for parallel paths: Current flows in every available path inversely proportional to the resistance of the path. That means that current flows through every path, and the path with the least resistance has the most current flowing in it. Inversely, the path with the most resistance has the least current flowing in it.

When you ground a circuit to the structure, you are making an electrical connection to the tower. Current will flow in every available path. If there is any source for current, including induction, there will be current flow. The greater part of the current will flow in the lower-resistance pathways. If the tower is well grounded, the majority of the current will flow in the tower to ground. In a distribution system, the majority of the neutral current flows in the neutral. Pole bonds to ground rods have much higher resistance and therefore lower current that usually can’t be measured by a typical clamp current meter, so some people think there is no current flowing in them. There is, and under the right conditions – such as a fault or open in the neutral – the level of current flowing in a pole bond can be deadly.

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Jim Vaughn, CUSP

Train the Trainer 101: Practical Personal Grounding in Underground Work

Incident Prevention has been covering personal protective grounding (PPG) for many years. Most of the emphasis has been on overhead applications for transmission and distribution. Lately, however, iP and many consultants associated with the publication have been receiving more and more inquiries from utilities seeking to understand the issues related to PPG applications in underground.

Part of the issue with PPG is that, as I mentioned, most training and rules seem to coalesce around overhead applications. The majority of the written standards – both OSHA and consensus – are found in sections dealing with overhead scenarios. It’s anecdotal, but it seems that most of the injuries or accidents discussed in the industry are also related to overhead. Still, the OSHA standard has requirements for PPG that do not specify or exempt underground applications, such as 29 CFR 1910.269(n), “Grounding for the protection of employees.” Employers have recognized that the risks we are discovering related to current flowing in grounded systems exist in underground, too. As responsible employers, they are seeking information, and not all of the information out there is good.

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Jim Vaughn, CUSP

August 2016 Q&A

Q: We have heard that OSHA can cite an employer for violation of their own safety rules. How does that work?

A: OSHA’s charge under the Occupational Safety and Health Act is the protection of employees in the workplace. The agency’s methodology has always assumed the employer knows – or should know – the hazards associated with the work being performed in the employer’s workplace because that work is the specialty of the employer.

OSHA’s legal authority to use the employer’s own safety rules as a reason to cite the employer is found in CPL 02-00-159, the Field Operations Manual (FOM), which is published by the agency for compliance officers (see www.osha.gov/OshDoc/Directive_pdf/CPL_02-00-159.pdf). The explanation is in the FOM section about the elements required for a citation under the General Duty Clause, in particular Chapter 4, Part III, Section B, Entry 6(a). This part covers the required element of employer recognition. If there was no reasonable expectation that the employer could recognize the hazard to the employee, the employer cannot be cited for a violation. The FOM specifically states that employer awareness of a hazard “may also be demonstrated by a review of company memorandums, safety work rules that specifically identify a hazard, operations manuals, standard operating procedures, and collective bargaining agreements. In addition, prior accidents/incidents, near misses known to the employer, injury and illness reports, or workers' compensation data, may also show employer knowledge of a hazard.”

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Jim Vaughn, CUSP

Train the Trainer 101: Practical Recommendations for Wire Stringing

In the last installment of “Train the Trainer 101,” we discussed grounding when stringing in energized environments (see http://incident-prevention.com/ip-articles/train-the-trainer-101-grounding-for-stringing-in-energized-environments). Many readers responded with questions regarding the myriad issues they have faced during stringing. I learned a lot about this type of work during my first 25 years in the trade. In stringing hundreds of miles of conductor, I am proud to say I never dropped wire. I also have to say it’s most likely I have that record because I learned a great deal from other workers’ accidents. In fact, I am seriously afraid of dropping wire. Stringing incidents are some of the most dangerous in the trade, not only risking the lives and limbs of line personnel, but creating a serious risk to the public. Over the years I have heard of or investigated every kind of incident, including one in which a phase dropped during clipping, shearing off 26 side-post insulators before the carnage ended. Wire ended up across school driveways, shopping center parking lots and intersections. More than 40 cars suffered damage and dozens of people reported injuries. I’ve seen wire dropped across interstates and rivers, and it always happens at the worst time. You’d be surprised how much damage 1272 can do to a luxury boat. So, the remainder of this installment of “Train the Trainer 101” will focus on some recognized issues and tips that might help prevent future disasters when stringing goes bad.

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