Jim Willis, CMAS

Rethinking Utility Security

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The names Nathan Baker, Zackary Randalls, Alex Boschert and William Froelich may not be familiar to you, but their stories are tragically important for utility workers. Nathan worked for East Mississippi Electric Power Association in Clarke County, Mississippi. Zackary was employed by Pacific Gas and Electric Co. (PG&E) in Fresno, California. And Alex and William worked for Laclede Gas Co. (LGC) near St. Louis. Except for Alex and William, who were employed by the same company, there is no evidence that these men knew each other or their paths ever crossed, so what thread binds them together? They were murdered while doing their jobs for their respective companies. In a horrible twist of fate, three of the men were killed within a week of each other in 2017.

In 2012, Nathan was making a routine collection/disconnect call at a residence when he was shot; his body was dumped in one location and his truck abandoned in another. In 2017, Zackary was sitting on the passenger side of a PG&E truck when a gunman walked up to the window and fired at him. A few days later, Alex and William were connecting a residential natural-gas line when a man, believed to be upset about his electricity bill, shot the two men and then turned the gun on himself.

Troubling Reminders
These stories are troubling reminders of a trend of violence aimed at utility workers. Utilities go to great lengths to ensure their employees have the skills and training necessary to safely do their jobs, but there has been less of a focus on utility worker security. This has to change. It is time to rethink utility security. From the front door of the office to the crews in the field, we must change how we go about protecting employees. Lives depend on it.

When you mention “utility” and “security” in the same sentence, many people think of cybersecurity or physical security of large-scale infrastructure sites. Many have heard about the cyberattack on the Ukrainian electricity grid in 2015 and know about the steps taken in the U.S. to secure the grid. Some conceptualize utility security as protection against attacks like the one on the PG&E Metcalf substation – a major transmission grid link – that occurred in 2013. Although these are critically important security issues, they are not the only ones. Safety managers and senior staff with safety and security responsibilities also should focus on improving the security posture of utilities at the local level. This means securing office complexes, warehouses and operational facilities; taking steps to target-harden local transmission and distribution; and improving the protection afforded to both office and field personnel, whether company or contractor.

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Rob D. Adams, CLCP, CUSP

Scenario-Based Fall Protection Solutions

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At least once in their career, nearly every safety worker in the utility business has been – or will be – faced with the need to use fall protection in an area where there is no place to tie off. In my role as a safety technician, I work with personnel in both generation and transmission business units; fall protection is needed in this line of work, but I have found that anchorage points can sometimes be few and far between. It’s a problem that clearly needs to be solved, and in this article I will share what my company has done to provide scenario-based solutions.

Scenario One
During an outage preparation meeting a couple of years ago, I was presented with some fall protection issues that employees had been dealing with. These issues specifically related to anchorage points for crews working on our main steam stop valves. Once the grating and I-beams were removed from the valve pit area, all potential anchorage points were eliminated, and thus no fall protection could be properly anchored and used in the valve pit area. Given this problem, I contacted a fall protection solutions group that came to visit our facility and gathered information regarding our anchorage concerns. While the solutions group was on-site, we also discussed possible recommendations to solve the anchorage problem. In a follow-up email after our initial meeting, the solutions group provided detailed information about the different types of equipment we could use to eliminate our anchorage issues on this particular project. The detailed equipment recommendations were then presented to our company’s personnel, and ultimately the decision was made to purchase the recommended equipment.

That recommended equipment was two advanced portable fall arrest posts, which allow us to provide overhead tie-off and utilize small self-retracting lifelines, or SRLs, so that workers in the valve pit are equipped with complete fall protection. Among the advantages of the portable fall arrest posts is how the posts are mounted. They offer several mounting applications that range from weld-on plates to beam clamps that are designed to fit 6-inch to 14-inch I-beams, meaning that we can use the posts in numerous locations throughout the company. Time and time again, the equipment has proven to be the solution to many of our fall protection needs in both generation and transmission work, including in Scenario Two below.   

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Bart Castle

Three Overlooked Processes for Increasing Safe Work Practice

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Have you ever seen or heard a restaurant, vehicle dealership or retailer claim, “We care little about service”? On the contrary, don’t many of these businesses – if not most – make bold claims about the quality of their services? How many, though, take the time needed to do the work, pay attention to the details, and become known for meeting or exceeding their claims?

Now, think for a moment. Have you ever seen or heard an electric utility organization of any variety claim, “We care some about safety performance”? I doubt it. If you look at 100 electric utility website landing pages, it’s likely you will see slogans about safety. Investigate those sites further and it is common to see safety listed as a company value or guiding principle. Yet just as some retail establishments tout their high-quality service while acting in ways that make it clear that “service” is more a buzzword than a business practice, so, too, are there electric utility companies and contractors that publicly state their concern for safety while their day-to-day actions don’t back up those claims.

Job descriptions, job safety analyses, tailboard meetings, PPE and training are important components of an effective safety program. But even for companies that are truly focused on providing a safe working environment for their employees, there are at least three other components that contribute to a consistently safe workplace, yet tend to get overlooked: effective interviewing, onboarding and mentoring processes.

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Pam Tompkins, CSP, CUSA, CUSP

How to Develop a Contractor Safety Management Standard

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Have you ever questioned whether a contractor or subcontractor was qualified to perform electric power work? If so, you should consider developing a contractor safety management standard. This type of standard defines minimum safety requirements that contractors must adhere to when they perform work for your company.

Years ago, many electric power organizations used contractual language and a hands-off approach to establish contractor safety responsibilities. In fact, organizations hired contractors to perform work they felt was unsafe because they knew the contractor would do whatever it took to complete the job. These work practices have significantly changed throughout organizations that recognize employers share responsibility for working conditions and safety at multiemployer worksites. Utilities and contractors are adopting a shared commitment to worker and system safety within their organizations.

Regulatory Requirements
In the preamble to 29 CFR 1910.269 – the electric power generation, transmission and distribution standard – OSHA states the following: “When OSHA promulgates new safety and health standards, it does so against this background principle that employers share responsibility for working conditions, and thus for OSHA compliance, at multiemployer worksites. Therefore, when the Agency issues a new safety or health standard, it is with the intention that creating, exposing, and controlling employers at multiemployer worksites will exercise their respective responsibilities to ensure that affected employees are protected as required by the standard.”

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Hugh Hoagland and Zarheer Jooma, BSEE, M.S.

Using Arc Protective Blankets as an Engineering Control Method

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While engineering controls are preferred over personal protective equipment for worker protection, many engineering controls, such as arc-resistant switchgear, require the purchase of new electrical equipment in order to fully implement them. When replacing equipment, this type of installation makes total sense, but it rarely can be the only company policy to mitigate arc flash in all facilities.

OSHA always prefers that organizations use the highest option possible on the hierarchy of controls. This is clear in the preamble to 29 CFR 1910.269, in which OSHA states the following: “NFPA 70E-2004 warned that ‘[d]ue to the explosive effect of some arc events, physical trauma injuries could occur’ … OSHA expects that the hazard analysis required by paragraph (g)(1) in the final rule will identify nonthermal hazards, including physical trauma hazards posed by flying debris, associated with employee exposure to electric arcs. … [OSHA requires] employers to address [these hazards] … [and] provide shields and barriers necessary to protect employees from physical trauma hazards. However, as noted by NFPA 70E, not all arc events pose physical trauma hazards from flying debris; therefore, this protection will not always be necessary …”

The 2018 NFPA 70E standard rightly took out the reference to 40-cal/cm² exposures posing a hazard from arc blast, since arc blast is more a function of containment and current than calories. In fact, our recent research surveyed the literature on arc blast pressure waves and found that many of the formulas did not come close to predicting our lab data from 4,000A to 12,000A (E. H. Hoagland, C. Maurice, A. Haines and A. Maurice, "Arc Flash Pressure Measurement by the Physical Method, Effect of Metal Vapor on Arc Blast," in “IEEE Transactions on Industry Applications,” vol. 53, no. 2, pp. 1576-1582, March-April 2017). New work continues to expand this knowledge and will be presented to the IEEE Electrical Safety Workshop this March in Fort Worth, Texas.

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Kate Wade

Chris Grajek Honored at 2017 USOLN Safety Award Ceremony

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On October 2, the Utility Safety & Ops Leadership Network (www.usoln.org) held its annual award ceremony at the iP Utility Safety Conference & Expo in Louisville, Ky. During the event, USOLN board members presented the John McRae Safety Leadership Award to Chris Grajek, CRSP, CUSP. Grajek currently serves as safety and work methods director for Allteck Line Contractors based in Burnaby, British Columbia.  

The John McRae Safety Leadership Award was created to honor McRae, a fourth-generation lineman who enjoyed a 42-year career before passing away July 27, 2010. He was active in the military reserves for nearly 30 years and instrumental in establishing the Massachusetts Municipal Lineman’s Association. McRae, a member of San Diego’s IBEW Local 465, spoke across the country about electrical training and went on to assist in the launch of Incident Prevention magazine.

“The John McRae award is a great honor, and even more so coming from an industry full of great leaders and professionls,” Grajek said after winning the award. “I never had the opportunity to meet John, but he sounds like an incredible leader and mentor. I take comfort in surrounding myself with those types of people whenever the opportunity presents itself.”

Grajek was selected to receive the award due to his commitment to the USOLN and its work. “Chris has dedicated himself to the Utility Safety & Ops Leadership Network by serving on the CUSP exam development committee and, more recently, the CUSP governing board,” said Carla Housh, USOLN executive director and publisher of Incident Prevention magazine. “He, along with other Canadian CUSP credential-holders, recognizes the benefits of the program and has worked to support and advance CUSP growth for Canadian utilities. Chris’ safety leadership knowledge, along with his passion for advancing the CUSP program, has had a significant impact on the success of the Northern program, and we are sincerely appreciative of his efforts.”

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Molly Hall

What Changes When You Put a Face on Safety?

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As an experienced lineman, Gary Norland was typical of many workers: big and strong, physically tough, unafraid of any challenge. That was before he came into contact with a 12,500-volt line. That’s when everything changed. He is not alone, as many others also have experienced serious electrical contacts on the job.

The well-known fact is electrical line work can be hazardous and potentially deadly. Based on high fatal work injury rates, the U.S. Department of Labor puts it in the top 10 high-risk occupations.

In the industry, there is continuous lineworker safety training, a heavy focus on OSHA regulations and requirements, and a variety of procedural checklists. With all this emphasis on ensuring safety knowledge, one might think the serious electrical contact and flash rate among lineworkers would be declining. Yet it appears to be moving in the other direction.

One utility insurer reported a 40 percent overall drop in OSHA reportable incidents from 2006 to 2016; however, lineworker electrical contacts, particularly serious injuries and fatal contacts, are increasing. In 2016, the number of lineworker contacts grew 23 percent compared to the previous year. The number of those that were serious incidents, characterized by a fatality or an injury costing more than $100,000 in medical expenses, went up by 50 percent.

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Hugh Hoagland and Stacy Klausing, M.S.

Secondary FR Garments: Practical Solutions for Protection

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Cleanup of potentially hazardous materials and flammable contaminants can sometimes be a part of an electrical job. When workers arrive on a scene, they cannot always be sure of the exposures or contaminants they will face. In electrical work, it could be oil that contains a small number of PCBs. This oil, and other contaminants, is flammable and can affect the flame-resistant properties of garments until it is washed from the garments. Working around flammable contaminants, as well as flame and thermal hazards like arc flash potentials and flash fire potentials, often requires a PPE safety system that can be difficult to balance. Some workers may need chemical protection, flame protection or both. Secondary protection used in such circumstances, like disposable garments, can create a fast and effective way to decontaminate and clean a scene – by removal and disposal – without soiling or degrading the primary protection underneath. Because of this, disposables often are useful over daily wear. Many workers and managers assume that a chem suit is a chem suit and use the common polyester/polyethylene suits to cover their arc-rated/flame-resistant (AR/FR) gear. This can be a disaster if one of the suits ignites, melts and continues to burn, or if part of the suit becomes molten and melts onto a worker’s hands or face.

In the AR/FR PPE industry, however, disposable garments are few and far between, and the standards aren’t quite in place to help make the distinction between garments that are truly flame resistant in specific hazards versus marketing. The lightweight, thin materials typically can’t pass some of the harsh requirements set forth for garments to be used as primary materials. And even though most are not intended for primary protection, there are limited standards to guide manufacturers on appropriate tests and claims for these types of products. This is especially true for those needing multihazard protection in the outermost disposable garment. There are disposable garments on the market that boast protection from a variety of hazards, like blood-borne pathogens, dry particulates and chemicals. When flame resistance comes into play, there are even fewer options on the market.

How Far Have We Come?
Disposables have come a long way in the past few years, but we are still lacking in standards on the AR/FR side. Initially, polyester spunlace disposable garments were used for chemical protection, and they revolutionized the industry in providing secondary, fast protection that could be doffed and disposed of without concern of contamination of primary clothing; these products add extra protection to the worker at a low cost. Later, coated and sealed-seam garments on the chemical protection side were made to withstand even higher-level exposures, including chemical warfare, an unlikely scenario in the workplace. Disposables for chemical protection worked well for chemical hazards, but they were not adequate or intended for the risks from flash fires or electric arcs. Flame resistance of disposable garments still hadn’t been adequately addressed from a standards perspective, and there were misunderstandings in the market regarding FR PPE, including PPE intended to be disposable.

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Michael Stremel, CUSP

Safety Concerns When Working In and Around Manholes and Vaults

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Some utilities – including electric, cable and communications providers – have had both underground and overhead applications for many years. However, more and more of these utilities now are either primarily installing their services underground or relocating overhead services underground, for a variety of reasons. These include reliability and protection from weather conditions, as well as minimizing exposure to equipment, vehicular traffic and farming operations. In addition to these safety concerns, utilities are installing services underground due to customer requests to improve the general appearance of the communities served by the utilities.

There are many beneficial reasons to install services underground, but there also are some downsides. Among them is the risk of personnel exposure to hazards when improper excavation practices are used. It is critical to adhere to OSHA 29 CFR 1926 Subpart P excavation practices as well as 811 and Dig Safe procedures. Another risk associated with underground facilities is that they often incorporate vaults or manholes that may be classified either as confined spaces or permit-required confined spaces. In either case, there are a number of safety concerns for which OSHA has implemented specific regulations that must be enforced to keep employees safe while working in these areas.

Safety should always be No. 1 on any job site. OSHA 1910.269(a)(2) states that all employees shall be trained in and familiar with the safety-related work practices, safety procedures and other safety requirements that pertain to their respective job duties. The agency goes on to say that employees who work in and around manholes must be trained on manhole rescue each year in order to demonstrate task proficiency. Proper documentation should be completed for the manhole training, as with any other training. The standard also states that the employee in charge shall conduct a job briefing or tailgate with all employees involved before the start of each job. At a minimum, the briefing should address the five areas required by the OSHA standard: hazards associated with the job, special precautions, energy-source controls, work procedures involved and personal protective equipment requirements.

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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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Danny Raines, CUSP

Voice of Experience: Distribution Cover-Up: Why Wouldn’t You Use It?

Over the next few installments of “Voice of Experience,” I’ll be reviewing some accidents that have taken place in the electric utility industry. I’ve had many requests for information about incident investigations and would like to share some details in hopes of preventing similar accidents in the future. Distribution cover-up will be the focus for this issue’s column.

Approximately half – or even more – of accidents that result in flashes and electrical contacts are the result of poor cover-up or total lack of rated protective cover. Why would a lineworker not take the time to install protective cover that would assure a safe work area? According to statistics and accident reports, the industry suffers an average of one contact or flash every week. That needs to stop.

Investigations into many accidents, some of which involved fatal contact with system or source voltages, have revealed that failure to cover up all differences of potential in the immediate work area was the common denominator in most flashes and contacts. If you are or your company is following the minimum requirements found in OSHA 29 CFR 1910.269(l), “Working on or near exposed energized parts,” it is simply not enough to ensure an employee is totally protected from differences of potential in the work area.

The human body essentially is a 1,000-ohm resistor in an electrical circuit. When a lineworker fails to cover energized parts as well as differences of potential in the immediate work area, as little as a 50-volt AC electrical source may enter the body. If the current path crosses the heart, as few as 40 to 50 milliamps can induce atrial fibrillation, cause the heart to stop sinus rhythm and electrocute the worker. The industry is quite familiar with medium-voltage contacts but many times lacks respect for low-voltage contacts that can be just as fatal.

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Brian Bourquin

Rope Access Work in Today’s Line Trade

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Rope has always been at the core of many operations and is the principal means of removing an injured person from a structure or manhole. In recent years, labor laws have revised and expanded expectations, particularly for worker fall protection on towers. The quest for methods to accommodate these rules has created opportunities for new applications of rope techniques, introducing wider use of rope access and rope descent technologies into the line industry.

Rope access describes rope-use techniques that have evolved from centuries-old rope applications incorporating maritime, construction and, in particular, mountain climbing or controlled descent methods. In the firefighting world, rescue using rope is referred to as “high-angle” or “technical” rescue. Rope access has been used for centuries in construction, and most readers today are familiar with scenes of lumberjacks, wind energy blade inspections, and dam and bridge inspectors suspended over the sides of structures.

In the line trade, we traditionally think of rope in terms of its use as a handline, which, in the event of an emergency, doubles as a rescue line. This rescue technique is still as relevant now as it was in the late 19th century, as the idea to plan your rescues is not a new one. Any differences between rope rescue today and rope rescue in the early days of power lines are primarily due to technological advances. One example of these advances is Buckingham Manufacturing Co.’s OX BLOCK, which is used for hurt-man rescue and self-rescue, as well as lowering, raising and snubbing loads.

To the employer researching rope access and controlled descent techniques for workers, it is important that line personnel be involved in the research process so that the techniques, tools and training that are adopted effectively match the needs of the workplace. Keep in mind that rope access is not a substitute for all work tasks – it is simply another tool. Both training and research are critical for employers and employees considering rope access techniques; this includes the review and assessment of tools and other items currently available on the market, including rescue-rated blocks and property-rated handlines.

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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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Lee Marchessault, CUSP

Making Sense of Protection Requirements for Open-Air Arc Flash Hazards

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Electric utility workers face complex, high-risk electrical hazards nearly every day. Information about shock hazards – which may come from impressed voltage, residual energy, induction, objectionable current flow in a grounding system or stored energy – has been taught to many of us for quite some time, as have the methods of assessing them.

On the other hand, arc flash hazard assessments are still relatively new to us. In the past, most of us knew that an arc flash could potentially occur during the course of performing our tasks, but the level of the flash and the PPE requirements – other than wearing 100 percent cotton – were not seriously considered in our day-to-day activities until approximately 15 to 20 years ago. To provide more concrete guidelines, OSHA published new regulations in April 2014, with more recent enforcement dates. Instead of making a best guess about PPE, the industry now has a reasonable approach to providing adequate PPE for utility employees who are tasked with performing open-air work. Once a utility completes the required arc flash analysis, develops a policy based on the analysis results and adequately conducts training for affected field personnel, the job of assessing risk and determining PPE levels can easily be incorporated into the daily job briefing. The goal is to make the assessment data easy to access and understand in order to provide effective protection for all workers.

Causes and Severity Levels of Arc Flash Events
An arc flash is the result of either a short circuit during which two energized parts of different potentials (phases) make contact, or a ground fault where an energized part and a grounded conductive part of a different potential make contact. An arc flash event may be caused by a failure of electrical apparatus, potentially due to lack of maintenance, or by worker error, perhaps due to an employee moving conductive parts near energized parts or leaving conductive tools in an energized work area. It’s important to note that differences in potential must always be effectively isolated by distance (air) or insulated barriers.

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Naira Campbell-Kyureghyan, Ph.D.

Injury Risks Associated with Climbing in the Wind Energy Generation Industry

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The growth of the wind energy generation industry in the U.S. has been phenomenal. According to the American Wind Energy Association, at the end of 2016 there were over 52,000 utility-grade wind turbines operational in more than 40 states, with a total capacity of 83,000 megawatts. The Global Wind Energy Council’s latest report shows that the U.S. has the second-largest wind power capacity, after China, with 16.9 percent of the world total, and employs over 100,000 people directly or indirectly. As the number of wind turbine towers grows, so does the number of people involved in their maintenance and repair. In 2015, the U.S. Bureau of Labor Statistics projected that employment of wind turbine service technicians would grow 108 percent between 2014 and 2024. There were approximately 4,400 wind turbine service technician jobs as of 2014.

Wind turbine tower heights also are increasing, with the tallest tower currently in the U.S. measuring 379 feet hub height, and even taller towers have been installed elsewhere in the world. While some towers are outfitted with service lifts, in the majority of towers personnel must climb fixed ladders to perform both routine and unusual operations. The increasing numbers and heights of towers mean more workers climbing ever greater distances.

Research studies conducted at the University of Wisconsin-Milwaukee (UWM) that have specifically investigated the renewable energy sector, including wind power generation, along with data from OSHA and the Bureau of Labor Statistics, have identified multiple risks to workers as a result of climbing fixed ladders. Strains and sprains, falls, overexertion and even fatalities were reported to be possible direct consequences of climbing and working at heights during both the construction and maintenance of wind turbines. Indirect risks also were identified, including potentially being electrocuted from contact with high-voltage cables and being struck by an object or caught between objects. Although power generation injury statistics are not separated by fuel source, 2015 Bureau of Labor Statistics’ data indicates that there were three fatal falls in the power generation industry, and 550 falls with nonfatal injuries. Data from the United Kingdom shows 163 total accidents in the wind power industry in 2016, including five fatal accidents. This data generally is assumed to vastly underreport the actual numbers, which may be 10 times higher.

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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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Danny Raines, CUSP

Voice of Experience: Qualified and Task-Specific Electrical Worker Training

The revised OSHA 29 CFR 1910.269 standard has now been in place for three years. In making the revisions, OSHA replaced older, passive language that left much to be understood with more objective language that clarifies the meaning and intent of the regulation. The standard is now easier to understand and sets the expectations for employers and employees.

There were some major changes made to the standard, as we all know. Several more subtle changes also were included and have been discussed much less, but they still have had a significant impact on the regulation. In this installment of “Voice of Experience,” I want to focus on one of these more subtle changes that I believe has a tremendous effect on the training requirements found in 1910.269(a)(2). The 1910.269 standard published in 1994 was straightforward, describing what was required in order for an employer to determine that an employee was a qualified worker. By and large, the industry believed that if an employee had the required training, he or she could be determined to be qualified. Now, per paragraph 1910.269(a)(2) of the revised 2014 standard, all employees performing work covered by the section shall be trained as follows:
• Each employee shall be trained in, and familiar with, the safety-related work practices, safety procedures, and other safety requirements in this section that pertain to his or her job assignments. (1910.269(a)(2)(i)(A))
• Each employee shall also be trained in and familiar with any other safety practices, including applicable emergency procedures (such as pole-top and manhole rescue), that are not specifically addressed by this section but that are related to his or her work and are necessary for his or her safety. (1910.269(a)(2)(i)(B))
• The degree of training shall be determined by the risk to the employee for the hazard involved. (1910.269(a)(2)(i)(C))

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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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Tony Barton

Confined Space Training: It Has to Be Done Right the First Time

Confined Space Training: It Has to Be Done Right the First Time

Entering and working in confined spaces is serious business. In the years I’ve been a safety professional, I’ve been involved with several hundred confined space entries, including overseeing entries into most of the confined space examples listed in the scope of OSHA’s “Confined Spaces in Construction” standard. A number of times I’ve been called to the scene of a confined space entry where the entrants had been evacuated because of alarms from direct-reading portable gas monitors. Some of these alarms were caused by degradation of atmospheric conditions, while others were due to operator error. Thankfully, I’ve never been called to a scene involving a worker who was down and overcome in a confined space, but I must admit that where confined space entries are involved, such a situation is my worst nightmare.

Over the last few decades, part of my work also has included training hundreds of workers in confined space entry. Typically training covers two major components: teaching trainees the regulatory requirements of the standard for confined space entry, and training them about their employer’s specific processes and procedures for conducting confined space entries in compliance with the standard. However, as Jarred O’Dell, CSP, CUSP, noted in his February 2016 Incident Prevention article, “Trenching by the Numbers” (see http://incident-prevention.com/ip-articles/trenching-by-the-numbers), “This is a great approach but perhaps an incomplete one. Truly impactful safety training typically includes a third component: sharing of personal experience.” In this article, I want to share some of my personal experiences and goals as they relate to training workers on the topic of confined space entry, with the hope that I can offer some useful takeaways to other trainers and utility safety professionals.

A Major Motivator
I’ve always been passionate about teaching confined space entry, and my major motivator is this: If workers aren’t properly trained to enter confined spaces, they might not be able to go home at some point. I end every training session I conduct, regardless of the topic or skill level of those I’m training, by explaining to the trainees that the most important thing they will do each and every day is to safely go home to their families, their friends, their plans, their dreams – their lives.

I want my trainees to know that the reason we have confined space procedures, training, permits, direct-reading portable gas monitors and non-entry rescue equipment is because people can die in confined spaces. I also want them to know that many people who have died in confined spaces weren’t even the entrants. Nearly half of those who have died in a confined space situation were would-be rescuers. I want my trainees to care enough about safely going home at the end of the day that they will perform the necessary confined-space tasks correctly the first time, based on the training they have received, because I’ve found a way to make this training important to them on a personal level.

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Connie L. Muncy, CIH, CUSP, MS, REM

Shining a Light on Ventilation Systems and Surveys in the Electric Power Industry

Shining a Light on Ventilation Systems and Surveys in the Electric Power Industry

It takes a wide variety of activities – some obvious and others not so obvious – to keep electric utility operations humming along. With maintenance facilities and power plants in particular, there are sometimes unidentified exposures that grow as the facilities grow. In other scenarios, our understanding of exposures or emerging regulations requires the need for a professional hygienist to assess and remediate exposures. Ventilation surveys, which can detect ventilation system failures, are a critical but often overlooked tool that should be used to maintain safe, healthy operations, whether those are power generation operations, transmission and distribution operations, or peaker operations during which power is produced during periods of peak usage. All of these operations require appropriate ventilation to control atmospheric hazards. Failure to recognize the importance of maintaining and periodically checking ventilation systems may impart substantial hidden risk to personnel, facilities and operations.

However, it is not uncommon to see operations that lack the needed systems; are serviced by jury-rigged systems that do not meet operational needs; or are serviced by well-engineered systems that over time have fallen into disrepair due to a lack of ventilation surveys and preventive maintenance.

How is it that these matters fall between the cracks?

It is easy for occupational health to take a back seat to occupational safety or other priorities. Poor change management can be blamed if a new system is installed and there is either no follow-up or incomplete follow-up for hazard control concerns. A simple lack of subject matter expertise within an organization could be the problem; perhaps there is no knowledgeable industrial hygienist on staff and an overwhelmed safety professional wearing multiple hats gravitates away from his area of lesser expertise. In some cases, chemical exposures take years to become evident and manifest symptoms. As such, they are a lower priority than more high-visibility issues, like falls from height or arc flash. Or, it may be that ancillary activities are out of sight and out of mind, and not recognized as a priority for hazard control.

Regardless of the reason, occupational health and safety cannot be maintained without appropriate attention to ventilation matters. The purpose of this article is to shine a light on these matters and encourage organizations lacking the needed expertise to learn to handle them appropriately.

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