Incident Prevention Magazine

Edward Morson and Mark Green

Innovative Fire Suppression Solutions for System and Worker Safety

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For over 100 years, PECO – a Pennsylvania utility and member of the Exelon utility family – has been supplying electricity and natural gas to customers across southeastern Pennsylvania, including those in Philadelphia and its surrounding suburbs. PECO has hundreds of miles of utility poles and thousands of circuit miles of medium-voltage distribution cables installed in conduit and manhole systems.

With all this infrastructure, it is only natural that wear and tear will occur, which can have an impact on the distribution system. Over the decades, PECO has experienced numerous failures of distribution system components, some of which developed into fires that were difficult to combat due to poor weather conditions. Unfortunately, local volunteer fire departments typically are not equipped to deal with these types of fires, and even city fire departments, whose workers receive training on electrical fires, sometimes have a difficult time extinguishing them.

Regulations and Extinguishing Agents
Another issue PECO employees have had to deal with is the type of fire extinguishers available in their work vehicles. For utilities that have service fleets and operate under federal guidelines, the U.S. Department of Transportation requires those fleet vehicles to carry fire extinguishers. Per Federal Motor Carrier Safety Regulation 393.95, “Emergency equipment on all power units,” each extinguisher must have a gauge to indicate if the extinguisher is fully charged and a label that displays its UL rating. Extinguishers also must be securely mounted and readily available and accessible for use at all times. In addition, a vehicle transporting hazardous materials must be equipped with an extinguisher with a UL rating of 10 B:C or more. If the vehicle is not transporting hazardous materials, it must carry one extinguisher with a rating of at least 5 B:C, or two extinguishers, each with a rating of 4 B:C or more.

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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

October 2017 Q&A

Q: We have gotten mixed advice from our colleagues at other utilities and can’t decide whether or not civil workers digging a foundation by hand in a hot substation should be required to wear arc protective clothing. They are inside the fence but in a new area approximately 20 feet from the nearest distribution structure. Where do we find the requirements or OSHA guidance?

A: That depends. Sometimes it depends on the criteria in the statutes, and sometimes it depends on compliance with company policy. Normally, following the guidelines of OSHA 29 CFR 1910.269(l)(8) – which establish the criteria for arc flash protection – excavation in a substation would not produce the type of work exposure you described that could create an arc flash. The location of the work and the type of work would not bring a worker within any distance of an energized bus or apparatus that would be a threat. If that’s the case, there would not be a requirement for arc-rated clothing for civil workers in a substation.

We are aware that there are utilities that require all workers, no matter what their craft or task is, to wear arc flash protective shirts while in a substation because it’s a company policy. But in regard to your question, it’s all about exposure. No exposure, no requirement for shirts. It is obvious that it’s not quite that simple for policymakers and risk analysts, who often are the people who make these decisions. Utilities must decide how to protect employees, protect the company and comply with the standards. That goal sometimes results in a blanket requirement as opposed to writing detailed criteria for when workers must suit up. The rules held by some utilities raise this question: If workers must wear arc-rated shirts, why don’t they have to wear arc-rated face protection? In fact, most of the inquiries we’ve made would seem to indicate the decision to require arc protective clothing in substations is more about gut response to the spirit of arc flash protection for contractors and employees than the result of arc flash analysis. Processes and knowledge are still expanding in the industry. As most would say, it doesn’t hurt for civil workers to wear arc protective shirts unless there is an unacceptable heat stress factor involved. In fact, there are some pretty lightweight pullover tees in Cat 2 that may help relieve both arc flash and heat stress.

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Danny Raines, CUSP

Voice of Experience: De-Energizing Lines and Equipment for Employee Protection

Lately there has been a rash of incidents involving flashes and contacts with primary voltage. The incidents occurred due to improperly written switching orders or missed switching steps, none of which were recognized by the workers involved with the tasks. These types of errors have long been a problem and continue to result in numerous injuries and fatalities.  

In April 2014, OSHA’s revised 29 CFR 1910.269 standard was published. This was the first revision to the standard in 20 years, and one paragraph in particular that was clarified was paragraph (m), “Deenergizing lines and equipment for employee protection,” which addresses system operations. As of the OSHA update, the employer is now obligated to appoint an employee to be in charge of the clearance issued by the system operator; this employee will have control over and oversight of all switching that affects the performance of the system.  

Specifically, OSHA has promulgated the following rules.  

1910.269(m)(2)(i)
If a system operator is in charge of the lines or equipment and their means of disconnection, the employer shall designate one employee in the crew to be in charge of the clearance and shall comply with all of the requirements of paragraph (m)(3) of this section in the order specified. 

1910.269(m)(3)(ii)
The employer shall ensure that all switches, disconnectors, jumpers, taps, and other means through which known sources of electric energy may be supplied to the particular lines and equipment to be deenergized are open. The employer shall render such means inoperable, unless its design does not so permit, and then ensure that such means are tagged to indicate that employees are at work. 

Electric utilities must establish a clearance – also referred to as an “open air gap” – on all known sources of the system and source voltages. A clearance also should be used to disable all automatic switchgear to ensure that all system voltage has been isolated from the work area. This procedure is regulatory language and required to protect employees. Tags shall be applied to all open points to indicate that employees are at work and nothing shall be re-energized.

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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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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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Peter Tyschenko and Michael Meathe

Using Thermography for Underground Worker Safety

Using Thermography for Underground Worker Safety

For more than 100 years, Commonwealth Edison – commonly known as ComEd – has been powering the lives of customers across Northern Illinois, including those in Chicago, a city that has thousands of circuit miles of medium-voltage distribution cables installed in conduit and manhole systems.

Over the decades, ComEd’s underground cable splicers have experienced failures of distribution cable system components, including cables, joints and terminations, while employees were working in manholes and vaults. A large number of cable system failures occurred at cable joints in underground manholes. Some of these failures were due to degradation of the electrical connection inside these joints.

One of the hazards associated with a cable system failure is the risk of employee exposure to an electrical arc flash. This type of event can result in temperatures in excess of 35,000 degrees Fahrenheit, producing a blinding flash and causing aluminum and copper cabling components to instantly expand. If an employee is working adjacent to equipment affected by the blast, the heat generated can cause third-degree burns, and the pressure wave can damage hearing and throw the worker into the surrounding structure.

A Culture of Safety
Past experience at ComEd has demonstrated that thermal issues with joints are centered on mechanical connections, typically those that are crimped. Such mechanical connections are used in pre-manufactured joints.

According to OSHA 29 CFR 1910.269(t)(7)(i), “hot localized surface temperatures of cables or joints” are an abnormality that may be indicative of an impending fault. Unless the employer can demonstrate that the conditions could not lead to a fault, “the employer shall deenergize the cable with the abnormality before any employee may work in the manhole or vault, except when service-load conditions and a lack of feasible alternatives require that the cable remain energized.” However, “employees may enter the manhole or vault provided the employer protects them from the possible effects of a failure using shields or other devices that are capable of containing the adverse effects of a fault.”

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Danny Raines, CUSP

Voice of Experience: Switching and Working on UD Systems

I was recently asked to provide information about the challenges and opportunities found when working on direct-buried underground distribution (UD) systems. In light of that request, I’ll address those topics in this installment of “Voice of Experience.”

My first opportunity to work on UD systems was as a truck driver operating a trencher in the late 1960s. UD systems were fairly new at the time; lineworkers were learning new techniques, using different types of tools to terminate cables and installing switchable elbows. In that day, some elbows were non-load-break. Back then the work was all about proper use of tools, identifying equipment and following the minimum rules. There were no OSHA regulations. We learned many techniques and work practices the old-fashioned way: through the school of hard knocks.

The challenges that workers faced back then are much the same as they are today, with two exceptions: The industry has more experience installing and operating UD systems, and equipment is now much more technically sophisticated and reliable. For many years, maintenance of UD systems was nonexistent. The common approach was to dig a ditch and put cable in the ground, and industry workers believed everything would last forever. That belief was short-lived; within a few years, external concentric neutrals began oxidizing, and radial and loop-fed systems suddenly became single-conductor, earthen-ground return systems. Driven ground rods at transformers split coil for secondary voltages. There was no neutral conductor for return currents or fault current flow.

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Chris Grajek, CRSP, CUSP

Underground Electrical Vaults: Safety Concerns and Controls

Underground Electrical Vaults: Safety Concerns and Controls

There are hundreds of thousands of man-accessible vaults in North America, with potentially tens of thousands of utility worker entries into those vaults each year. And it’s likely that every worker who enters a vault appreciates the safety procedures that govern the work. The combination of high-voltage electrical cables and aging infrastructure can exponentially complicate even the most routine vault-related task. In addition, many utilities across North America continue to report electrical vault failures, some of which lead to violent explosions.

For the most part, utility owners have a good understanding of the risks of entering man-accessible vaults and conducting work inside of them. There are many stories and equally as many opinions as to the safety and stability of the underground electrical network. The intent of this article is to summarize some known conditions your employees may face during execution of work in underground vaults. Although explosions may constitute the bulk of catastrophic events, thorough consideration of all hazards should be included in risk analyses.

The Vault
There is no uniform standard pertaining to vault configurations, but utilities regularly have an engineering standard. Man-accessible spaces can be as shallow as 8 feet deep with 340 cubic feet to approximately 30 feet deep with 3,000 cubic feet. Each vault is connected to others in the underground system through ducts and can have one to several high-voltage cable circuits passing through it. Some cables pass through directly while others contain splices, connections, transitions and some high-voltage switchgear or similar equipment. Most common cables are cross-linked polyethylene – often referred to as XLPE – or lead cable circuits. There is the potential for other systems to be present in spaces associated with lower voltages and communication cables. Some vaults have standard manhole lids while others have latch plates. The number of combinations is endless, but hazard exposure in these spaces is similar and can be categorized into exposure tables. When conducting your risk assessments, it is generally accepted in most jurisdictions to group your spaces by similar configurations of space and type. This will help organize information, reduce the volume of documentation and provide your field crews with clear data to safely perform their work.

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Jarred O'Dell, CSP, CUSP

Tricks of the Trade to Improve the Trenching Environment

Tricks of the Trade to Improve the Trenching Environment

This is the final installment in a four-part series on trenching and excavation. “Trenching by the Numbers” (http://incident-prevention.com/ip-articles/trenching-by-the-numbers), the first article in the series, presented a simple method for recalling OSHA’s trenching and excavation requirements. The second article focused on soil mechanics (http://incident-prevention.com/ip-articles/soil-mechanics-in-the-excavation-environment), taking an in-depth look at the behavior and characteristics of different soil types and their relationships with water and air. In the June 2016 issue of Incident Prevention, I covered “Protective Systems for Trenching and Excavations” (http://incident-prevention.com/ip-articles/protective-systems-for-trenching-and-excavations). To close out the series, I will present techniques for creating a safer, more productive trenching environment, and then provide some food for thought about how to sell these techniques to management.

Dewatering Using Well Points
It’s no secret that water can greatly contribute to the success or failure of any trenching and excavation activity. OSHA requires that employers take steps to keep workers from being exposed to standing water conditions. One of the more proactive approaches to dewatering a site is to install well points. A hole is augured into the ground, and a perforated pipe is inserted into it. Then, a submersible pump is placed inside the pipe. This technique can be especially effective in sandy soils.

However, there are two caveats to keep in mind with this technique. First, it works best when performed three to five days before excavating begins. This is because water is self-leveling; thus, when a void is created by the pump, the water in nearby soil leeches into the work area. If excavation activity takes place too soon after the well point is installed, one could misguidedly conclude that well points make conditions worse when, in reality, poor planning and a misunderstanding of the process are to blame.

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Jim Vaughn, CUSP

Train the Trainer 101: Practical Personal Grounding in Underground Work

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

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

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Jarred O'Dell, CSP, CUSP

Protective Systems for Trenching and Excavations

Protective Systems for Trenching and Excavations

This is the third installment of a four-part series on trenching principles. “Trenching by the Numbers” (http://incident-prevention.com/ip-articles/trenching-by-the-numbers), the first article in the series, presented a simple method for recalling OSHA’s trenching and excavation requirements. The second article focused on soil mechanics (http://incident-prevention.com/ip-articles/soil-mechanics-in-the-excavation-environment), taking an in-depth look at the behavior and characteristics of different soil types and their relationships with water and air. In this article, we will discuss the four different protective systems described in OSHA 29 CFR 1926 Subpart P, “Excavations”: engineered design, timber shoring, shield systems, and sloping and benching. Each system has its own unique strengths and weaknesses. Thus, depending on the environment and the circumstances of the work to be done, one system may be a better fit than the others. Let’s take a closer look at all four systems.

Engineered Design
Engineer-designed protective systems typically are not used in utility operations. Instead, this type of system is more likely to be seen on large-scale building foundation work, and it may also be used on complex construction projects, such as around waterways. In any case, some activities – like those that involve deep, poured-in-place vaults or occasions when a duct bank has to pass beneath water and sewer – may benefit from an engineer-designed system customized for the situation. The need for engineered design may be rare, but knowing what it is and why it is used is necessary information for project and safety planners.

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Jarred O'Dell, CSP, CUSP

Trenching by the Numbers

Trenching by the Numbers

By and large, organizations directly provide the training and other resources needed for the development of their foremen and crew chiefs. Such training tends to be built around two components: following the standards set forth by OSHA and other regulatory agencies, and adhering to organizational policies and procedures.

This is a great approach but perhaps an incomplete one. Truly impactful safety training typically includes a third component: sharing of personal experience. For instance, I once observed a training session in which the instructor drew from his experiences during a discussion about how to troubleshoot problems that can likely be anticipated in the field. Often, this type of training is held in higher regard by trainees than that which simply outlines a standard. Furthermore, workers are more likely to become active participants in training sessions that highlight proven, real-world work practices that they can use to more safely and efficiently execute their tasks.

With this in mind, I began crafting a series of four articles that focus on trenching and excavation techniques and practices. My goal is to present advanced material – injected with my own on-the-job experiences as a safety director and instructor – to the seasoned foremen and crew chiefs who already have some practice working in and around trenching environments.

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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

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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Carla Housh

Preventing Underground Damage

Construction professionals understand the importance of not damaging buried utilities while performing any type of new construction and maintenance work. Even so, accidental strikes of underground utility lines continue to interrupt essential services, cause millions of dollars in damage, result in serious injuries, and in some cases, loss of life.

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Jim Vaughn, CUSP

Notes From the Underground

In the May/June 2005 issue of Incident Prevention the cover article, "Why Single-Point Grounding Works," generated a lot of inquires about single-point worksite grounding in underground installations. The most frequently asked question was, "How do we create an equipotential zone for underground worksites?" I received inquiries from California to Maine, North Dakota to Florida. There were so many that IP asked if I could immediately address underground protective grounding for employees in this issue.

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