Utility Safety Management Articles

When it comes to following health and safety standards, nearly every worker tries to do the right thing. And when workers deviate from standards and best practices, it is typically due to lack of knowledge and proper training. One industry topic that is not yet fully understood and continues to be heavily debated is the N95 filtering face piece, in particular its uses and program requirements. In response, this article seeks to assist those who are involved with the development and enforcement of their organization’s voluntary respiratory protection policy.

To begin, there are two reasons why N95 face pieces are especially relevant to readers right now.

First, OSHA is currently in the process of revising the standard on crystalline silica dust, which is a common utility and construction industry hazard that is oftentimes mitigated by N95 face pieces. OSHA’s fact sheet on crystalline silica (see www.osha.gov/OshDoc/data_General_Facts/crystalline-factsheet.pdf) describes the substance as “a basic component of soil, sand, granite, and many other minerals” that workers may encounter when sandblasting, jackhammering, drilling rock or working with concrete. Clearly, many utility industry workers are exposed to most of these activities – if not all of them – on a recurring basis.

It’s estimated that between 2 million and 4 million utility poles are replaced annually in the U.S., and in almost every region of the country, many of those replacement poles are now made of steel. In fact, more than 1 million steel distribution poles have been installed by electric utilities across the country in the last decade. That number is expected to rise considerably as utilities strive to keep up with the need for new lines, replace aging and damaged poles and harden existing lines.

The increased use of steel utility poles in distribution lines has created a need for new training and coursework for student, apprentice and journeyman lineworker programs nationwide. For years, the Steel Market Development Institute (SMDI) has developed training standards and guidelines, and in 2013 it teamed with several respected leaders in utility safety and line work training to update and bring new materials to the trade. Among the organizations SMDI collaborated with are the Institute for Safety in Powerline Construction (ISPC), based in Alexandria, La., and Metropolitan Community College (MCC) in Omaha, Neb., which offers a leading utility line technician program. Through these partnerships, steel pole training programs have become well-established, and both coursework and program participation continue to evolve.

Over the past 20 years I have had the great opportunity to travel the country observing everyday safety practices in the utility industry. During this time it has become clear to me that, more often than not, employees are practicing inadequate rigging techniques that put them and their co-workers at risk on a daily basis. These poor practices are being perpetuated from one generation of riggers to the next. Employees who learned improperly from previous trainers go on to train new employees in the same fashion. It seems that a number of workers have bought into the dangerous idea that unsafe practices are acceptable as long as they don’t result in a serious accident. This cycle of carelessness and endangerment is unacceptable and can only be stopped through adequate training and reinforcement of proper rigging techniques. We must revisit the most fundamental principles of rigging safety to build the foundation necessary to change our current culture. In this article I will discuss three of the most basic aspects of rigging – equipment selection, inspection and proper use – and I look forward to continuing the conversation when I present “Basic Rigging Fundamentals” on September 30 at the iP Utility Safety Conference at ICUEE.

On April 11, 2014, OSHA issued the final rule regarding 29 CFR 1910.269 and 1926 Subpart V. The final rule included modifications that address minimum approach distances, fall protection systems and hazards of electric arcs. Since the publication of the rule, there have been an extensive number of articles published that detail changes to 1910.269 and 1926 Subpart V. Those articles focus on explaining the changes but most lack information about arc flash mitigating technologies.

This article focuses on current technologies available to minimize and prevent exposure of workers to arc flashes. Employers must ensure workers are provided the necessary protection against these flashes, as it can mean the difference between life and death. According to NFPA 70E, arc flash incidents occur five to 10 times each day and account for 400 fatalities each year. Additionally, the Electrical Safety Foundation International has reported that more than 2,000 workers are treated annually for flash-related burns. The severity of a flash and the related severity of injury primarily depend on the magnitude of the arcing current and the duration of exposure. A typical three-cycle circuit breaker will interrupt fault currents in 50 milliseconds. Exposure to a temperature of 205 degrees Fahrenheit for 100 milliseconds may cause a third-degree burn, which will cause skin to fall off and may result in death.

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.

I have never worked in a generation plant, but I have visited many plants during my years of working with utilities. My experience has been in safety and skills training for transmission and distribution systems. I have also worked with generation employees on OSHA and DOT projects, and I am now in the process of helping a company revise their OSHA 1910.269 training program, including the portion that addresses 1910.269(v), “Power generation.” I have to say, I was surprised by the absence of changes to 1910.269(v) in the 2014 OSHA update. The revised section reads almost word for word the way it did in the original 1994 standard. As far as the changes that were made, they consist of a few clarifications and the addition of “the employer shall ensure” to several paragraphs. That language, which is found throughout the entire 2014 1910.269 standard, removes any implied directives and expectations. It also helps to ensure the employer’s accountability and responsibility for employee safety and safe work practices.

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.

Are your employees performing work on or near electric power generation, transmission or distribution facilities? If so, whether they are performing electrical or nonelectrical work, electrical training is required. The training provided must ensure employees can identify electrical hazards and employ safe work methods to remove or control the hazards for their safety.

Covered Work
To simplify the application of OSHA 29 CFR 1910.269 and 1926 Subpart V, many companies use the term “covered work,” which includes work areas with electrical system hazards. For example, the construction of a power plant is the same as general building construction until the plant begins startup and commissioning. Once electrical systems are started, the job tasks become covered work due to the additional electrical system hazards.

Another example is the construction of a substation. Substation construction is similar to general building construction until the substation becomes energized or is being built in an area with transmission lines. Consider the difference between a substation built in an open field with no transmission lines and a substation built under transmission lines. Although each substation has hazards, the substation under the transmission lines has electrical hazards that would not be found in the substation built in an open field. The substation built under transmission lines is considered covered work due to the electrical system hazards.

It is an undisputed and well-known fact that workers’ use of manual tools increases repetitive movement, introduces awkward working postures and elevates the risk of ergonomic injuries and illnesses. Throughout the past decade, the utility industry has done a great job of recognizing these ergonomic safety issues, and a number of utility tool manufacturers have responded by developing new battery-operated tools and tool features that address them. Slowly but surely, ergonomic safety is increasing in the workplace as investor-owned utilities, contractors, cooperatives and municipalities make the switch from manual to battery-operated tools.

However, even with the progress that’s been made, there are many workers who are still using manual cutting and crimping methods on job sites across the country, which means those individuals face a greater likelihood of carpal tunnel syndrome, tendonitis, sciatica, sprains, strains, soft tissue damage and other injuries.

According to the most recent data available from the U.S. Bureau of Labor Statistics, among upper body injuries involving the repetitive use of tools, approximately 61 percent involve injury to the hands and wrists, 20 percent involve injury to the shoulders, 10 percent involve injury to the arms and 9 percent involve injury to the trunk and back. Signs of these of musculoskeletal disorders include decreased range of motion, decreased grip strength, swelling, cramping and loss of function. Other symptoms of these injuries include numbness, pain, tingling and stiffness.

When the original version of the OSHA 1910.269 standard was published, flame-resistant (FR) clothing wasn’t even mentioned. The dangers associated with electric arcs were known, but the standard only required that an employer not allow an employee to wear clothing that, when exposed to flames or electric arcs, could increase the extent of injury sustained by the employee. This was covered under 1910.269(l)(6)(iii). The rule eliminated the use of garments constructed with synthetics such as polyester, nylon, rayon and acetate, which could melt and drip, and led to the adoption of clothing made with 100 percent cotton. The problem was that non-FR cotton – once exposed to thermal energies beyond its ignition point – will ignite and continue to burn, thus adding to an injury.

Now that the much-anticipated revisions to the 1910.269 standard have been published, they have introduced a number of new challenges to the electric utility industry and those entrusted with their employees’ safety. Specifically, page 20317 of the final rule (see www.gpo.gov/fdsys/pkg/FR-2014-04-11/pdf/2013-29579.pdf) states that the “new provisions for protection from electric arcs include new requirements for the employer to: Assess the workplace to identify employees exposed to hazards from flames or from electric arcs, make reasonable estimates of the incident heat energy to which the employee would be exposed, ensure that the outer layer of clothing worn by employees is flame resistant under certain conditions, and generally ensure that employees exposed to hazards from electric arcs wear protective clothing and other protective equipment with an arc rating greater than or equal to the estimated heat energy.”

On a clear, sunny day following a fierce thunderstorm the night before, Mark drove off to work. The schedule for the day was busy with repairing downed lines in several heavily trafficked neighborhoods followed by some scheduled maintenance at a router station. Mark met up with his crew, reviewed the schedule and then the team headed out for what they expected to be a long day. The crew was experienced, though, so Mark felt confident they would be able to complete their list of tasks.

In the driver’s seat of the crew cab on the way to repairing the downed lines, Mark thought about the task ahead; it would pose a challenge, but he and his team knew the drill and felt comfortable navigating to the assigned areas. In fact, he had grown up in one of the neighborhoods on their route and knew a few shortcuts. They were somewhat off the mapped routes, but Mark and the rest of the crew felt they could save some time by following the shortcuts. Indeed, the crew did save some time and found themselves a bit ahead of schedule.

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.

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.

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.”

The revisions to OSHA 29 CFR 1910.269(a)(3) and 1926.950(c) regarding information transfer have brought many changes to the relationship between host and contract employers in the utility industry. As OSHA noted in the preamble to the revised standard, the existing Multi-Employer Citation Policy is insufficient to ensure workplace safety, and hence the agency has implemented a host-contract employer information transfer standard. The following article will shine light on what information must be communicated by which employer as well as how it should be communicated.

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.

Established in 1891 by a royal charter from King David Kalakaua, today Hawaiian Electric provides electric service to 95 percent of the state of Hawai‘i. The company has approximately 1.4 million customers on five islands, with Hawaiian Electric providing service to O‘ahu; subsidiary Maui Electric providing service to Maui, Moloka‘i and Lana‘i; and subsidiary Hawai‘i Electric Light providing service to Hawai‘i Island.

The state of Hawai‘i is located in the middle of the Pacific Ocean, about 2,000 miles away from the coast of the continental United States. This isolated geographic location, combined with the state’s clean energy initiatives, continues to pose unique challenges to Hawaiian Electric as the company strives to meet the demands of customers and the state’s Public Utilities Commission for lower bills and increased levels of renewable energy.

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.

Over the last few months I have delivered several presentations and webinars on the recent revisions to OSHA 29 CFR 1910.269. During these sessions, attendees asked for clarification on a variety of topics, particularly arc-rated flame-resistant (FR) clothing. This month’s “Voice of Experience” is devoted to helping readers understand more about the impact of OSHA’s changes on this subject.

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.