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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

June 2016 Q&A

Q: Is a transmission tower leg considered a lower level? And is there an exception for hitting a lower level when someone is ascending in the bucket truck to the work area? Our concern is that the shock cord and lanyard could be long enough that the person could hit the truck if they fell out of the bucket prior to it being above 15 feet.

A: The February 2015 settlement agreement between EEI and OSHA addresses both of your questions, which, by the way, were contentious for several years until this agreement. The settlement agreement includes Exhibit B (see www.osha.gov/dsg/power_generation/SubpartV-Fall-protection.html), which explains how the new fall protection rules will be enforced or cited by OSHA. Employers should review the entire document.

Section A of Exhibit B states that no citation will be issued because a fall arrest system could permit the employee to contact a lower level while the bucket is ascending from the cradle or to the cradle position, provided that the fall protection is compliant in all other respects, the bucket is parked with brakes set and outriggers extended, and there are no other ejection hazards present.

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Jim Vaughn, CUSP

Train the Trainer 101: Grounding for Stringing in Energized Environments

A few years ago I came upon a crew using 6-inch chocks to hold back a 38-ton crane truck. I told the crew I was happy that they were making an effort at compliance, but I had to ask them, “Why do we place chocks under a truck’s wheels? Is it to comply with our safety rules or to keep the crane from running away?” It was obvious to me that the short chocks would not hold the crane. The driver proved my assumption true a few minutes later. From the cab, with the transmission in neutral, he released the parking brake. The crane easily bounced over the chocks and, unfortunately, hit my pickup truck.

Sometimes I ask similar questions about grounds installed during stringing. That’s because it seems we do not pay as much attention to the value of grounding as we do to the perceived value of an act of compliance. Grounding during stringing plays a very important role in protecting workers; however, that’s only the case if we know why we are grounding and then install grounding so it does what we want it to do.

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Jim Vaughn, CUSP

April 2016 Q&A

Q: What is an employer’s affirmative defense relative to an OSHA charge and how does it work?

A: In simplified legal terms, an affirmative defense is the act of an accused party putting forth a set of alternative claims or facts. The purpose of the accused party doing this is to mitigate the claim against him, or at least the consequences of the claim, even if the facts of the claim are true. Following is an example of a fairly common scenario in which an affirmative defense is claimed by an employer. OSHA investigates an incident that resulted in an injury to an employee and finds the employer responsible. The agency subsequently issues a citation for violation of a certain rule. Most successful affirmative defenses have shown that the employer’s safety manual rule would have protected the employee if the rule had been followed; that the rule was communicated to the workforce via training; that supervisors and employees were trained to comply with the rule; that supervisors enforced the rule; and that a disciplinary program effectively remediated noncompliance. If the employer successfully puts forth that defense, he can claim the employee violated the rule outside of the control of the employer. The employer showed due diligence and cannot be held responsible for a condition over which he had no control, such as employee misconduct.

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Jim Vaughn, CUSP

Train the Trainer 101: Safety Cops and the Continuum of Safety

Words have power. We confirm that every day when we examine why people do what they do. Communication is often the root cause of accidents, particularly how the receiver interprets what he or she hears. That communication is not always something said in the moments before an incident; it can occur days, weeks or months in advance. I have discussed this issue with behaviorists on a number of occasions, and I am convinced that some of the words I – and many others – have repeatedly heard over the years have served to limit our success in the quest for a strong, positive safety culture.

The real problem is that what we say to soften our approach and encourage safe work has the exact opposite effect of our intention. Many of us – and yes, I have done it, too – don't want to be criticized or worse when we ask crews to do something differently. Sometimes we think our request is going to sound accusatory or like an insult to their professional skill level. Other times we know from past experience that the issue that needs to be addressed is contentious. Maybe we worry that our message is going to be challenged, or perhaps we are not confident in our delivery. There are any number of reasons, but it boils down to this: Safety professionals are human, and humans don't want to be challenged or rejected. Therein, as they say, lies the problem.

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Recent Comments
Guest — Karen Phelps
This is Karen. Testing the comments.
Friday, 19 February 2016 11:46
Guest — Jim Vaughn
So it does! great Article by the way!
Friday, 19 February 2016 11:57
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Jim Vaughn, CUSP

February 2016 Q&A

Q: I work for a small utility and am new to my safety role. Recently I have been wading through the Federal Motor Carrier Safety Regulations (FMCSR) in an attempt to understand my responsibilities with regard to testing CDL drivers. Can you briefly explain these responsibilities?

A: FMCSR 391.31 requires the employer to ensure a driver is competent by means of road testing. The FMCSR allows a valid commercial driver’s license as evidence of competency (see FMCSR 391.33). If the employer accepts the evidence of the driver’s competency, the employer does not have to road test the driver. Rule 391.33(c) allows the employer to conduct a road test if they so choose even if the driver has a current license and certificate of competency. If the employer intends for the driver to haul double or triple trailers, they are required to conduct a road test. The road test criteria are listed in FMCSR 391.31(c).

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Jim Vaughn, CUSP

Train the Trainer 101: Practical Underground Safety: Handling Neutrals and Rescue

Over the years I spent as a lineman, I did my share of underground installation and maintenance work. During my years in safety, I have seen the expansion of safety processes associated with underground, especially in response to the most recent OSHA changes. Not all of the changes have been effective, and that’s why we’re now going to spend some time addressing several underground safety questions Incident Prevention frequently receives. We’ll look at the rules and practices and what works from a practical perspective.

Handling URD Neutrals
This will not come as news to most of you, but for more than 60 years we have been splicing URD concentric neutrals during underground repairs without isolating the neutral or bonding across the open neutral in the ditch. That is something no lineworker would do on an overhead neutral, yet hardly any readers will be able to recall a time when someone was injured making neutrals in URD. Now, as OSHA’s language and expectations are more defined regarding grounding for personal protection, industry better recognizes current flowing in grounded systems, and employers are looking for ways to create equipotential and grounding during underground maintenance. For the most part, it’s not going well. The two questions I hear most are, why should we ground and how do we do it?

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Jim Vaughn, CUSP

December 2015 Q&A

Q: I’ve been reading ASTM 855, IEEE 1048 and the National Electrical Code, and I’m a little confused by the practice of grounding through a switch. Can you help me better understand this?

A: In transmission/distribution applications, there is no issue with grounding through a switch. To explain, we always have to ask whether the issue is grounding through (in the path) a switch or grounding (by way of closing) a switch. The application may sound the same, but it depends on which standard you read. Our subject matter experts think the confusion lies in the well-known NEC rules, which require permanent installations to have a connection-free path for the ground electrode conductor at the service entrance of an electrical system. According to the code, grounds – except in some specialty connections – cannot be disconnected through operation of a switch or breaker contact. ASTM 855 is an equipment manufacturer's standard that has no application to utility practices in the field other than being used as a guide for shop construction, sizing, rating and assembly of personal protective grounds. IEEE 1048 does address the value of having the grounding switches closed when de-energizing a system for work; that ground switch is a very low-resistance path to earth at the feeder or transmission bus source that will lower fault current in an accidental or inadvertent energizing of the source. The ground switch in the station is also a path to ground that will divide and help reduce the amount of induction current on a circuit. Closing the switch can help reduce induction current at a work location, depending on how far apart the work location and the ground switch are.

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Recent Comments
Guest — Brian Ergga
I believe the question relates to grounding through a switch. Another words, working on one side of a switch when the other side i... Read More
Friday, 01 January 2016 17:16
Guest — Jim Vaughn
I think we agree, we certainly agree with your observation. Grounding is for the purpose of tripping a protective device. Equipo... Read More
Monday, 04 January 2016 09:52
Guest — Brian Erga
Question on OSHA's requirements for leather gloves. OSHA 1910.269(l)(8)(v)(A) state: "Arc-rated protection is not necessary for th... Read More
Friday, 01 January 2016 17:32
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Jim Vaughn, CUSP

Train the Trainer 101: Practical MAD and Arc Flash Protection

Author’s Note: Before we get to the article, I want to thank the members of Incident Prevention’s editorial advisory board for their help in assembling this installment of “Train the Trainer 101.” They help me keep my head on straight, especially when I have ideas that are way outside the box. Even though I am also on the board, they still hold me to high standards of accountability and accuracy. These folks are a great asset to iP and make better writers of everyone who contributes to the publication.

Over the past year, iP subject matter experts have fielded many questions about how to meet the minimum approach distance (MAD) and arc flash (AF) rules published by OSHA in the 2014 final rule regarding 29 CFR 1910.269 and 1926 Subpart V. The questions about MAD came from a variety of perspectives, but they were primarily submitted by contractors trying to facilitate the information transfer now required by 1910.269(a)(3) and 1926.950(c). Without information about a system’s fault characteristics, the contractor cannot determine MAD, either by calculation or via the tables in 1910.269 Appendix B and Appendix B to 1926 Subpart V. That means the contractors must fall back on the sometimes absurd provisions of alternative tables R-7 through R-9. In my work for a contractor, we have found that those alternative tables can make some work – particularly transmission work – very difficult, if not impossible, especially when faced with compact lattice structures or old construction standards on wood poles. For AF programs, that lack of information may be overcome effectively by experienced guesswork, but compliance by guesswork cannot be defended when the compliance safety and health officer asks how you determined the AF compliance requirements.

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Jim Vaughn, CUSP

October 2015 Q&A

Q: Is equipotential grounding now a personal protective grounding method required by OSHA?

A: The answer is yes, even though OSHA doesn’t specifically say so in terms we easily understand. The terminology isn't OSHA's fault. As an industry, we adopt certain familiar ways of describing or discussing things and simply don't recognize what OSHA is trying to communicate unless we do some diligent research. In 29 CFR 1910.269(n)(3), OSHA requires arrangement of grounds to protect employees without using the word “equipotential.” The title of the rule, however, is “Equipotential zone.”

The full text of 1910.269(n)(3) states, “Temporary protective grounds shall be placed at such locations and arranged in such a manner that the employer can demonstrate will prevent each employee from being exposed to hazardous differences in electric potential.” By definition, that is equipotential grounding.

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Jim Vaughn, CUSP

Train the Trainer 101: Practical Personal Protective Grounding

In the last 10 years I have consulted on dozens of induction incidents, eight of which resulted in fatalities. There were commonalities in each one. Just about every Incident Prevention reader will agree that one of the topics that receives the most attention across the power industry – in writing, training and conversation – is personal protective grounding (PPG). Not a week goes by that I don't email or talk to someone about PPG and, in particular, about dealing with induction.

At iP we discuss and share information as well as news about incidents involving induction, and yes, they do occur at an alarming rate. I can't point to any empirical evidence, but my colleagues and I think we, as an industry, are the reason for the confusion over PPG issues. We have been slow to evolve from grounding for the purpose of stabilizing electrical systems and protecting equipment, to grounding for the protection of workers. Even the language of the OSHA standard, to some, seems vague, contradictory or too technical. The ANSI standards establish sound procedures for protective arrangements, but they are not training resources for craft workers. Now, as infrastructure loads and system voltages continue to increase, there are corresponding hazards that were not even discussed just a generation ago. Those hazards are resulting in incidents and, worse, preventable incidents that risk the lives of power-line workers.

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Jim Vaughn, CUSP

August 2015 Q&A

Q: I'm wondering about an issue with a third-party safety analysis required by one of our clients. We are required to satisfy their safety requirements, including creating programs and safety manual changes worded to meet their criteria. I have issues with the required changes because they don't fit into our safety program.

A: You are not alone in your concerns. OSHA issued a warning about this exact topic, and it was a reason for changing the language in the proposed rules from June 2005. In the proposed rule, 29 CFR 1926.950(c) required contractors to follow a utility’s work rules as if they were statutory OSHA rules. Further, in the preamble to the proposed rules, OSHA clearly indicated the intent of the new rule’s language was to leverage utilities under the Multi-Employer Citation Policy in order to improve contractor safety. All of this created a concern for utilities that gave rise to third-party evaluations. The purpose seems to be both a means of qualifying the contractor and also providing a buffer between the contractor’s performance and the utility’s newly proposed responsibilities. For those readers who are not familiar with this process, the third party signs on to represent the utility in the evaluation of contractors. The utility also signs on to the process. The utility’s contractors, or proposed contractors, pay to join the third-party program and work to attain an acceptable rating for their safety program.

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Jim Vaughn, CUSP

Train the Trainer 101: Back to Basics: ‘Gentlemen, This is a Football’

I recently spent several weeks studying an incident, trying to understand how it had happened and – more importantly – how it could have been prevented. Maybe the answer was associated with human performance, or maybe culture, or it could have been procedures, or ... well, maybe it could have been associated with any number of things. In other words, even with all of my experience and training, I had a hard time finding the singular root cause. This dilemma made me recall a question I missed on an engineer-in-training exam I took in the 1970s. The question had ladder diagrams and loop schematics and required me to determine why indicator light I-107 was off. After a long study of the supporting documents and employing all of my superior intellect, I proudly answered the question 100 miles off. Why? The correct answer was, “The lamp was burned out”; this is probably why I never became an engineer.

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Jim Vaughn, CUSP

June 2015 Q&A

Q: Are there any changes to steel-toe boot requirements for lineworkers in the recently revised OSHA 1910.269 standard?

A: OSHA still leaves it to employers to decide whether hard-toe or protective footwear is required. As with all other PPE, the decision should be made based on risks and history. Wearing safety footwear is not required by the PPE rule. However, what is required in OSHA 29 CFR 1910.136, “Foot protection,” is a mandatory assessment of the work environment. The rule states that the employer “shall ensure that each affected employee uses protective footwear when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, or when the use of protective footwear will protect the affected employee from an electrical hazard, such as a static-discharge or electric-shock hazard, that remains after the employer takes other necessary protective measures.”

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Recent Comments
Guest — Eddie Taunton
I believe the question on grounding through a switch is derived from the note in 1910.269(n) which states: Note to paragraph (n)(4... Read More
Thursday, 09 July 2015 14:07
Guest — Jim Vaughn
Eddie, thanks for the suggestion and I apologize for not getting to this comment earlier. There is no issue with grounding throug... Read More
Wednesday, 09 September 2015 11:39
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Jim Vaughn, CUSP

Train the Trainer 101: The OSHA-EEI Subpart V Settlement

In February of this year, Edison Electric Institute (EEI) circulated an agreement with OSHA. This agreement – which can be viewed at www.osha.gov/dsg/power_generation/SubpartV-final-settlement.html – ended the petition for review filed over several new provisions of the April 11, 2014 final rule affecting the general and construction industry rules for transmission, distribution and line clearance work. The agreement as delivered consisted of the final agreement and four exhibits that specified the agreed-upon terms. Exhibit A is a series of 46 questions and answers reflecting more detailed terms of new enforcement dates and general terms of agreement found in exhibits B and C. Since the Q&A in Exhibit A and the scope clarification for line clearance tree trimming in Exhibit D are pretty straightforward, we won't treat them here, but we will attempt to simplify and illuminate as best we can the terms found in exhibits B and C. At the time of this writing, the agreements were not signed by all parties, but we hope and assume the agreement will go forward as written.

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Jim Vaughn, CUSP

April 2015 Q&A

Q: We are a 100-year-old municipality and we have discovered some wood tools and a baker board in a long-overlooked storage area. The tools are rotted and termite-damaged, but the situation raised a question: Is it permitted to use wood hot sticks?

A: We did some checking with manufacturers and most agree that wood tools were first replaced by fiberglass-reinforced plastic (FRP) in the 1950s when utilities started transmission voltages over 240 kV. The first published FRP manufacturing standard was for fiberglass tools in the 1960s. We don't currently know of any consensus standards for wood tools, but the 2009 version of IEEE 516 states that some wood may still be in use. Additionally, OSHA still has a voltage withstand test for wood tools, so we assume that means that it is not prohibited to use wood tools that meet the standard for both electrical and physical integrity.

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Jim Vaughn, CUSP

Train the Trainer 101: Addressing Anchorages

With the new OSHA 29 CFR 1910.269 rules have come many questions, and one that Incident Prevention often receives is how to define an appropriate anchorage. There will be forthcoming interpretations as employers ask questions of OSHA, but the April 4, 2014 preamble, or “Summary and Explanation of the Final Rule,” does provide a good basis for interpreting the rules. You can read the preamble at www.osha.gov/dsg/power_generation/.

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Jim Vaughn, CUSP

February 2015 Q&A

Q: The issue of multiple snaphooks in a single D-ring and Incident Prevention’s stance on it have received a lot of attention, and we are pleased to address this topic once more in the Q&A section.

A: iP received two notable responses to our guidance regarding manufacturer approvals and OSHA’s requirement that prohibits the use of two snaphooks in a single D-ring unless (1) the snaphook is a locking type and (2) the snaphook is specifically designed for certain connections.

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Jim Vaughn, CUSP

Train the Trainer 101: Substation Entry Policies

Every utility and every contractor that works for a utility should have a substation entry training program. These programs are primarily written for non-electrically qualified workers, but there are many line personnel who do not have substation training or who do not understand the risks inherent in a substation. Hazard awareness training for substation entry is necessary for anyone who enters electrical substations to perform work tasks. Following are some recommendations for the type of content that might be appropriate for an entry awareness program. This material may not be all-inclusive and some information may not apply to your stations. Most of this content is necessarily basic, but it is also suitable as pre-entry hazard review and training for experienced electrical workers.

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Jim Vaughn, CUSP

December 2014 Q&A

Q: In regard to work boots and arc flash protection, what does OSHA mean by “heavy-duty work shoes or boots” in 29 CFR 1910.269(l)(8)(v)(B)? Are boots made of synthetic material acceptable if they are work boots?

A: As with all OSHA rules, it is up to the employer to understand the risks and the necessary protections. In many cases the consensus standards give guidance that can be used to satisfy the OSHA standard. Even though NFPA 70E exempts utilities, OSHA has clearly used the NFPA as a source of material to assist utility employers in protecting employees, and the clothing standards in 70E may be a good place to start. NFPA 70E is not an adopted standard, but as OSHA stated in an October 18, 2006, letter to Michael C. Botts (see www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=interpretations&p_id=25540), “A national consensus standard … can sometimes be relevant to a general duty clause citation in the sense that the consensus standard may be used as evidence of hazard recognition and the availability of feasible means of abatement.” In Table (C)(10), NFPA 70E requires leather boots as needed.

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Jim Vaughn, CUSP

Train the Trainer 101: Stringing in Energized Environments

Stringing wire in any environment can quickly go wrong. Dropped conductors can wreak havoc if precautions are not taken. In an energized environment, the result of losing control or dropping conductors has a greatly magnified risk.

Guard structures are the first type of protection conventionally used to prevent contact with energized lines. Ideally, guard structures are positioned so that whether it’s the unexpected loss of stringing tension or something as major as a dropped conductor, the conductor being pulled will not make contact with the energized lines. There are other requirements, too, one being non-automatic setting of breakers for the lines being crossed if it is not possible to de-energize and ground them.

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