Utility Safety PPE Articles

Danny Raines, CUSP

Voice of Experience: Fundamentals of Underground Padmount Transformers

In recent months Incident Prevention has received several questions about underground (UD) padmount transformers, so in this installment of “Voice of Experience,” I’d like to take the time to cover the general aspects of these types of transformers.

To begin, there are a few different types of single-phase and three-phase UD padmounts: live front with exposed live primary parts, 600-amp bolt-on elbows and loop feed with bushings and elbows. All of these transformers are available in several voltage ranges.

The proper PPE must be worn when an employee is opening, entering and working on energized transformers. This includes a rated hard hat, eye and face protection, rubber gloves, heavy leather boots and arc-rated FR clothing. Additionally, all PPE must be worn by any employee exposed to energized equipment and cables until the transformer has been de-energized and checked for the absence of voltage, and all exposed parts have been properly grounded.

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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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Ed Hunt, CUSP

The Roller-Coaster Life Cycle of IEEE 1307

The Roller-Coaster Life Cycle of IEEE 1307

IEEE 1307 is a little-known work group that is part of a larger IEEE subcommittee known as ESMOL, which stands for Engineering in the Safety, Maintenance and Operation of Lines. Both IEEE 1307 and ESMOL fall under the umbrella of the IEEE Transmission and Distribution Committee. IEEE 1307 is also the title of a utility fall protection consensus standard that has existed since the early 1990s. In light of the recent OSHA changes to fall protection, it seems appropriate to spread the knowledge about this industry standard.

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Allen L. Clapp, P.E.

The Importance of Matching Evidence Marks in Accident Investigations

I have personally investigated more than 800 incidents involving serious permanent injury, death, equipment failure and structural failure. Time after time, we were pulled in late to assist with investigations in which early investigators had failed to properly investigate the incidents. They had jumped to erroneous conclusions, thus resulting in incorrect admissions, strategies or other actions in the related litigations. When properly analyzed, each incident was shown to have occurred differently than originally assumed, and often a different party or action was the precipitative cause. Finding this out late in the game really hampered effective defense or prosecution, resulting in higher litigation and settlement costs, and even in improper jury decisions because the jury believed the earlier, confusing conclusions.

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Hugh Hoagland and Stacy Klausing, M.S.

Recent PPE Changes and 2015 Trends

Recent PPE Changes and 2015 Trends

2014 was a year of changes in electrical safety. The new OSHA 29 CFR 1910.269 standard has moved arc-rated (AR) clothing and PPE to the forefront, unlike the 1994 changes. Additionally, for facilities covered by NFPA 70E, the new 70E standard has added a level of complexity to PPE. This article will review changes in PPE as well as trends to expect this year.

NFPA 70E Changes
In the 2015 edition of NFPA 70E, the term “Hazard Risk Category” (HRC) has been replaced by “PPE level” or “arc rated PPE category” (ARC). As a result, manufacturers may start using “ARC” instead of “HRC” on labels to indicate their level of performance in an arc. One PPE manufacturer is also considering using “CAT” (category) with a level. Expect to see more emphasis on the cal/cm² rating in 2015 and less on categories as NFPA, OSHA, NESC and IEEE move toward matching the protection to the hazard and move away from categories of protection. The incident energy that defines the ARC levels will remain the same, but HRC 0 – natural fiber clothing – was eliminated and now PPE is required to be AR.

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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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Danny Raines, CUSP

Voice of Experience: The Importance of Job Briefings

As I write this article, I am reflecting on 2014 and thinking about how many contacts and fatalities the electric utility industry suffered last year. There were fewer than in 2013, but the improvement was only slight. At present, the most accurate count for 2014 is approximately 40 fatalities and 45-50 electrical contacts. One serious injury or fatality is too many, and all of them can be avoided by planning and the proper use of training, tools, time and teamwork.

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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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Danny Raines, CUSP

Voice of Experience: Flame-Resistant Apparel is Now PPE

It’s official: Flame-resistant clothing is now considered PPE, and employers are required to furnish it to employees when there is a chance that they may be exposed to electric arcs or flames. This change has been a long time coming as the industry has been in limbo for years. A number of forward-thinking companies have been furnishing arc-rated FR clothing to their employees for some time, while others have waited for regulations to require them to do so. The company from which I retired as well as other large investor-owned utilities have uniform policies that incorporated arc-rated FR clothing years ago.

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Jim Vaughn, CUSP

October 2014 Q&A

Q: I can't seem to clarify what U.S. Department of Transportation hours-of-service rules apply to utility workers. Are we exempt from the rules?

A: The university studies and experience of the Federal Motor Carrier Safety Administration that prompted the hours-of-service rules do have some value to us as an industry with drivers. The data used to form the rules shows that fatigue affects performance. This is a model that can help us to establish safe practices with our drivers. However, there is good reasoning for exemptions when the work we do ensures electrical service for users that helps keep them safe and healthy. And because of this reasoning, there are utility exemptions for driver logs as well as hours of service, which include time behind the wheel as well as other work performed by a driver. By the way, FMCSA clarifies that when calculating hours of service, line work or any other work for the employer – including work not associated with driving – is classified as on-duty not driving time.

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Jim Vaughn, CUSP

Train the Trainer 101: Fall Protection and the New Rule

With the publication of OSHA’s new final rule regarding 29 CFR 1910.269 and 1926 Subpart V, the fall protection rules have changed – somewhat. Both the general and construction industries have had fall protection rules in place since the advent of workplace safety rules, including the duty to have fall protection found in 1926.501. However, provisions specific to the industry have enabled utilities and their contractors to operate under fall protection exemptions for poles and similar structures. That is no longer the case.

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Danny Raines, CUSP

Voice of Experience: OSHA Eye and Face Protection Standards

In this installment of “Voice of Experience,” we will take a look at the wording in OSHA 29 CFR 1910.133, “Eye and face protection.” A review of this standard is a great opportunity to gain a better understanding of what OSHA requires of both the employer and employee in order to properly protect these vital body parts in the workplace.

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Jim Vaughn, CUSP

The Final Rule

We have been expecting it since 2005. It's here, and it's big. The OSHA final rule regarding 29 CFR 1910.269 and 1926 Subpart V was announced April 1, popularly known as April Fools’ Day. The significance couldn't have been missed by those at the U.S. Department of Labor. Who says they have no sense of humor? The unofficial PDF version published April 1 has 1,607 pages. The official version – published April 11 in the conventional three-column Federal Register format – has a mere 429 pages. The final rule becomes effective July 10.

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Jim Phillips, P.E.

NFPA 70E Arc Flash Protection for Nonexempt Industry Workers

NFPA 70E Arc Flash Protection for Nonexempt Industry Workers

Editor’s Note: As defined in the scope of NFPA 70E, electric utilities, with the exception of certain commercial electrical installations, are exempt from the standard. If, as a safety professional, you have installations covered under OSHA 29 CFR 1910 Subpart S, “Electrical,” you are subject to NFPA 70E.

In the recently published 1910.269 and 1926 Subpart V final rule, OSHA prominently mentions NFPA 70E as a beneficial informational resource for employers regarding arc flash programs. NFPA 70E is referred to numerous times throughout the final rule’s preamble, demonstrating that even as an exempt industry, the 70E standard has an effect. OSHA makes reference to the value of the arc flash incident energy calculation methods as well as ways to protect employees from arc flash hazards (see Federal Register, Vol. 79, No. 70, page 20324).

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Jim Vaughn, CUSP

June 2014 Q&A

Q: Can you help us with regard to fall protection practices while working on top of a roof or in areas near substation transformers? We are aware of the exceptions for qualified climbers in OSHA 29 CFR 1910.269. How does that affect us?

A: Most utilities will tell you that they don't require fall protection to work a weatherhead on a roof. Many have no fall protection requirements or programs for working on top of transformers. I am aware that some utilities use the definition of a working surface issued by OSHA – at least once every two weeks or for a total of four man-hours or more during any sequential four-week period – as proof that a roof or transformer top is not a work surface and therefore an exception. (See December 18, 1997, OSHA interpretation letter to Niagara Mohawk Power Corp. at https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22508.)

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Hugh Hoagland and Mikhail Golovkov

Addressing Comfort and Contamination in Arc-Rated Clothing

With the revised OSHA 29 CFR 1910.269 standard slated to soon be released, the last utility companies holding out on moving to arc-rated clothing will soon be compelled to do so as a matter of law. The new standard is likely to have the same language as the National Electrical Safety Code (NESC) and will require arc flash calculations for both primary and secondary voltages. NESC 2007 excluded secondary voltages, but the 2012 edition includes a requirement to perform arc flash calculations and does not discriminate against primary or secondary voltages. To follow calculations per the updated 1910.269 standard, worker apparel will be required to have an arc rating equivalent to the hazard. Most of the PPE will be 4, 8, 12, 20, 40 and 60 cal/cm² as described in the NESC.

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Jim Boyd, CUSP

Transitioning to FR Clothing

Transitioning to FR Clothing

Since Tacoma Power’s creation in the 1890s, its employees have worked on or around energized conductors and have been exposed to the hazards of electrical arcs and flames. For most of that time, electrical workers wore natural fiber clothing to reduce the risk of injury if involved in a situation that could result in an arc flash. Injuries from burning clothing can lead to permanent disabilities and death.

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Scott Margolin

Keys to Evaluating and Comparing Arc-Rated and Flame-Resistant Fabrics

Keys to Evaluating and Comparing Arc-Rated and Flame-Resistant Fabrics

When determining what type of protective clothing to purchase, the first thing specified by a significant number of safety professionals is the flame-resistant (FR) or arc-rated fabric brand. The number, type and source of these fabrics have expanded dramatically in the last few years as new offerings chase profits in an expanding market. There have also recently been significant failures, making it more critical than ever to thoroughly research and select trusted, market-proven brands. These failures can occur on several levels; one recent issue involved the failure of a fabric to be flame resistant when new, while another involved FR failure after laundering. Other failure modes include huge numbers of garments that had to be removed from service within months instead of years due to very high shrinkage, and a dire situation in which the fabric itself was toxic, resulting in the hospitalization of more than 100 lineworkers in Australia.

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