Over the past few weeks I have received several inquiries regarding horizontal directional drilling (HDD). It’s not unusual in our industry for questions to make the rounds of utilities and contractors, generating interest and often controversy. I also have recently received several inquiries regarding OSHA allegedly canceling the digger derrick exemption in 29 CFR 1926 Subpart CC, “Cranes & Derricks in Construction.” OSHA hasn’t done that, but somebody said they did, and folks started asking around. Soon after, I received calls for clarification on the matter. In the digger derrick case, there was nothing to it; OSHA has not changed anything about the exemption. However, concerning HDD, there is an issue that raises an interesting question for those who administer compliance.
The point of the rest of this article is not to recommend or criticize any safety procedure associated with HDD. The point is to examine the role of manufacturer warnings and OSHA-compliant safety performance in the workplace. There is no doubt that I will get emails from HDD machine manufacturers and adherents of overshoe use, as well as overshoe sales or manufacturing representatives. I invite your response. To be clear, both Incident Prevention magazine and I are solely interested in providing an opportunity for perspective and analysis of a process that will help individuals learn how to deal with challenges in the workplace.