Train the Trainer 101 Articles

Recently I have received numerous emails and phone calls regarding respiratory air-filtering masks rated for arc flash. I’m sure everyone reading this, no matter what country you’re in, is aware why that’s the case: the COVID-19 pandemic.

If you are a regular reader, you know it is my methodology to address topics by first citing the related safety standards in effect and then discussing the issue from a practical perspective typically related to the utility industry. This time is no different – for the most part.

Initially, the use of masks during the pandemic was limited as effective respiratory protection and still is for the public per the Centers for Disease Control and Prevention. As far as OSHA was concerned regarding workplaces, the only approved mask was the NIOSH-approved N95 filtering facepiece respirator (FFR). The N95 rating means that the mask meets the criteria for effective filtering of airborne particulates and moisture at 95%. The rating system also was established by NIOSH. It is important to understand that the N95 rating is based on the assumption that the masks are utilized by trained users meeting the OSHA respiratory protection worker training and fit-testing standard, which also can require a medical evaluation of the user.

Across our industry, I have found all kinds of policies for grounding trucks. I also have found that in many cases, employers’ rules for grounding trucks are not based on OSHA requirements and – even more concerning – are not based on sound principles of protection. I believe the grounding policies are well intentioned, but they fail to achieve two important goals: (1) meeting the OSHA standard and (2) protecting workers where electrical contact hazards exist. So, let’s take an ABCs approach to the issue because even though some detailed explanation is required, it really is that simple.

A Defensible Plan
You must be able to defend your plan or policy. This is the case for every plan or policy. Defense is built around establishing and accomplishing a goal, understanding the hazard, understanding the mitigation of the hazard, training at-risk employees, and conducting periodic audits to ensure the plan or policy is properly employed.

When analysts look at utilities, and to some extent utility contractors, they often see what’s referred to as “mission creep.” That occurs when the expertise of the utility should be focused on quality and continuity of service but begins to be compromised by focus on too many other areas. The opposite of mission creep is when business elements that are critical to successful progress toward the goal get overlooked because of focus on the goal. One business element that gets less attention than it deserves are big trucks and the Federal Motor Carrier Safety Regulations (FMCSR). Granted, 75% or more of the FMCSR do not apply to utilities, and many parts that do apply are difficult to implement. Implementation is tough because, even as employers with drivers and big trucks, we are not carriers, which is the target audience of the rules, but we still are regulated by those carrier-related standards. The key areas of compliance for utilities are driver qualification, record of duty status (RODS), safety equipment and load securement. There also are a couple of new initiatives that we should keep an eye on.

There are two reasons why it’s problematic not to know OSHA. The first reason gets the employer in trouble. The other reason gets everyone in the utility sector in trouble. Let’s begin this installment of “Train the Trainer 101” with a discussion about the first reason and why it’s important to know OSHA from the perspective of rules and regulations.

There are some realities we need to acknowledge to understand the difficulties different employers face. These are generalities based on my experience; I do not seek to classify all sectors of the utility industry as the same. It is a reality that municipalities – and the contractors who work exclusively for municipalities – are more or less late to the OSHA table because OSHA has excepted government and subdivisions of government from complying with OSHA regulations. In the past, only municipalities in state plan states were under OSHA jurisdiction. As word and experience got out, more municipalities voluntarily expanded their safety programs, and municipal associations took a role in raising the awareness and safety consciousness of municipalities that were not accountable to OSHA. However, small contractors have a resource issue. Few small contractors with under 100 employees have full-time safety personnel, and many contractors with even larger workforces have no full-time safety personnel on their larger job sites. But lack of safety on job sites is not just reserved for smaller contractors. I see large utilities with roving safety personnel who are stretched so thin that their time is mostly spent getting ready for safety meetings and newly hired employees rather than auditing crews on work sites where threat meets flesh. For a safety program to work, there must be staff who are qualified to audit the workplace, know OSHA’s expectations for employers, develop compliance strategies and the related training and written procedures, and conduct safety training. There also must be site visits to audit performance and compliance, mentor crew leaders and members, assist in job planning, and review job site documentation like tailboards and work plans. If your safety department also keeps required Department of Transportation and safety training documentation, performs investigations, and keeps injury and incident documentation, that is another full-time layer of work.

The date was January 28, 1986. The event was the tenth and final flight of the Space Shuttle Challenger. Seventy-three seconds into flight, the booster rocket that was lifting Challenger into space exploded, killing all seven astronauts aboard.

When events like the Challenger explosion happen, you never forget where you were at the time. You remember the iconic photos and the national days of mourning for those lost. After the Challenger explosion, President Reagan appointed the Rogers Commission to investigate the disaster, and some of you may remember the news commentary on the Rogers Commission Report. If you didn’t study the reports from the incident, you likely aren’t aware of the stunning findings, the changes that were called for and, even more importantly, the effect the changes at NASA have had on industry – including the utility industry. It’s worth taking a look. You can read about lessons learned from the incident at https://ocw.mit.edu/courses/aeronautics-and-astronautics/16-891j-space-policy-seminar-spring-2003/readings/challengerlessons.pdf.

The occupational safety and health industry and civil authorities require that employers provide training to employees. In the U.S., OSHA mandates safety training related to tasks assigned to employees. The agency often also requires the employer to certify that the training has been completed. In fact, if you have an incident requiring OSHA notification, the first question that will be asked is, “Was the employee trained for the task?” The second inquiry will be a request for documentation of the training, usually followed by an enforceable subpoena for those training records.

Training and certification of training are important for two reasons. The first is that training has clearly been demonstrated to reduce incidents and injuries to workers. Second, OSHA will hold employers accountable for the training they conduct. The penalties for willful violation of training requirements are rarely discussed, and I hesitate to do it here, but the record shows that if an employer does not train, and OSHA can show the employer knew training was required, the penalties are based on willful violation. Penalties for willful violations that result in fatalities can include jail time for the employer. In addition, if OSHA wins a willful violation case, the employer can expect charges of negligence under both civil and criminal liability standards. Don’t take this training responsibility lightly. I, like OSHA, would prefer employers be compliant for the welfare of the workforce because they are ethical and care about their employees. But if the threat of prosecution works, we still accomplish the desired outcome: a safer workplace.

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.

I’m not sure how I became an analyst. I don’t think it’s a career goal you necessarily plan for. My understanding of the analyst role is that it’s an individual who studies the elements of an event or occurrence. Analysts break down the elements of an event to learn how those elements are related. The purpose of analysis is to understand the nature of the event being studied. Through effective analysis, we ultimately create or assure desired outcomes and prevent or minimize the likelihood of undesired outcomes.

Over the past 10 years I have analyzed a half-dozen training accidents that occurred in apprentice training yards. Recently I also have seen a couple of videos of incidents involving apprentices in which no one was hurt; they were actually kind of funny to watch. But to an analyst, those videos have a lot more to offer than the lighthearted “been there” sympathy. Lineworkers often learn the hard way how not to do things. It’s that hard way that I want to eliminate because sometimes the hard way becomes the final act to what might have been a great life.

I was once engaged to write an opinion on a root cause analysis (RCA) that OSHA and a utility performed based on an incident that hospitalized three apprentices in a single event. OSHA only performs RCAs to identify where the employer may be at fault, but in this situation, the RCA listed all kinds of physical conditions and procedural mistakes that caused the incident. All of those items were causally related, but none were the real root cause. Before we move ahead in this edition of “Train the Trainer 101,” readers need to understand RCAs and how they fit into the lessons learned from training accidents.

The question that is the title of this installment of “Train the Trainer 101” originally came to me from a client during safety training for the company’s distribution employees. The client is a T&D contractor with a telecommunications (telcom) division. And yes, the question was regarding arc flash, which is not the same thing as FR. To utility workers, FR formerly meant “flash resistant.” The acronym FR was stolen from the utility industry by the road construction industry for traffic safety vests and now has come to stand for “flame resistant.” Flame resistance is the quality of a material designed for protection from exposure to fire or flame, not electrical arcs. OSHA, which does not use “FR” in the standards, requires that arc flash protective clothing also must be flame resistant to ensure clothing does not continue to burn after exposure to an electrical arc. In addition, flame resistance is required for the outer layer of clothing worn by an electrical worker who could be exposed to a heat source that could ignite that outer layer. There has been confusion, so it is important to recognize that use of the term “FR” on a traffic vest label does not mean the vest is arc protective; it is only flame resistant, meaning it has resistance to burning and will not continue to burn if the flame exposure is removed. It’s a habit to use the term FR when referring to arc flash protective gear, but we all need to understand the difference in labeling.

Now, back to the initial question. My first thought upon hearing it was that telcom workers are not required to use FR. After all, telcom is regulated by OSHA 29 CFR 1910.268, and 1910.268 does not require arc protective clothing like the 1910.269 standard does. But the answer doesn’t end there. So, if you are in the telcom business, don’t stop reading here. This is a lesson on interpretation of the standards as much as it is an answer to the question, who is required to wear arc flash protection?

This installation of “Train the Trainer 101” may have an odd title, but it was inspired by some recent conversations I’ve had. I’ve learned a lot about personal protective grounding (PPG) in the past 20 years, and I continually learn even more as others share their research and experiences. Some time ago I learned that much of the fundamental electrical math upon which electrical circuit theory is based does not adequately explain the risk from high currents imposed on grounded systems. That does not mean there are not theoretical explanations for all of the results in high-current fault testing. But the simple circuit math of Ohm’s law cannot explain the complex electrical physics that occur in a high-current fault, and that is partly what confuses the issue concerning EPZ.

What is simple is this fundamental of worker protection: It takes 50 volts to break the electrical resistance of a worker’s skin. If you can break the electrical resistance of the skin, current can flow, and the worker can be injured. However, if voltage cannot penetrate the skin, current cannot flow. You cannot eliminate system current by grounding; you can only divide it (i.e., send most of it through a different path) and hope for the best. But you can eliminate voltage in the worker exposure. You eliminate voltage potential by bonding. Once you’ve eliminated the voltage potential hazard, current no longer matters and thereby the risk is altogether eliminated.

We provide tools and equipment for our crews. Sometimes they are special tools, and sometimes they are generic tools necessary to support routine crew work. Sometimes they are accessories for trucks and equipment, and sometimes they are simply extra tools or equipment to make things easier on the people in the field. The question then is, are these tools approved?

The following is going to aggravate some readers, so let’s start with a reminder: I attempt to clarify and simplify compliance with this series. This is about making compliance easier and sometimes less expensive. So, here is an example.

About 20 years ago I was organizing a training school for a community college in Florida. I was recruiting utilities as clients. A visiting utility safety director saw that we had 40-foot-length retractables at the tops of the training poles. He said, “You are going to get into trouble with those yo-yos. They have to be mounted on approved davits.” My first question – and what should be your first question, too – was, approved by who? Without skipping a beat, the safety director responded, “OSHA.” We then went to his office where he had a similar device for which they had paid a little over $2,000. And just like he said, right there on the box was clearly printed “OSHA approved.” It only took me a few minutes on OSHA’s website to show him reference after reference and interpretation after interpretation in which OSHA stated to employers and manufacturers that it does not approve equipment. If an employer writes to OSHA and asks if they approve of having the employer’s employees in a specific type of exposure, and the employer intends to use a specific tool and equipment in a particular configuration, OSHA will respond that the agency does not approve equipment. The agency will then go on to state that in the situation described, using the equipment as described, OSHA believes the employer’s solution would – or would not – meet OSHA’s requirements.

If you follow OSHA’s guidelines, you train your workers to perform hazard analysis. You probably have a tailboard process as well, although your company might have a different name for it. Tailboards and crew hazard analysis are fundamental leading indicators of a good safety program. But hazard analysis and tailboards are only two elements of what really makes a difference in a safe approach to work. A health and safety site-specific plan (HASSSP) and the HASSSP process bring with them innumerable benefits – not just prevention of unwanted incidents.

When I was a contractor safety manager, I wrote a site-specific plan for every project. I started doing so about 15 years ago, after a series of preventable incidents and conditions that wouldn’t have occurred if I had provided prevention information to the supervisor and crew prior to the events. It occurred to me that for all the planning our company did, we missed some pretty big issues – issues that cost us pain and treasure.

A health and safety site-specific plan is not just a contractor tool. Many utility projects will benefit from a HASSSP since the level of detail for the plan itself is relative to the type and complexity of the work. Contractor HASSSPs typically are more detailed and developed if the local area is new to the company and particularly if the contractor is hiring new personnel for the duration of the project. The HASSSP is the product of prework research and analysis of the worksite and conditions that can or will affect crew performance or success.

In the past few months, I have received comments and inquiries from all over the U.S. regarding what appears to be stepped-up enforcement of both load securement and vehicle weight rules. It’s not unusual that these topics garner attention from the U.S. Department of Transportation when it comes to carriers, but this recent uptick seems to be for smaller commercial vehicles, mechanics trucks, pressure diggers, and bucket and digger derrick trucks.

Not all utility safety professionals may be up to date on this topic because DOT issues are not front-burner issues. Typically, the human resources department handles a driver’s qualification file and drug testing for the DOT. Drivers at utilities only spend a few hours a week on the road between calls and jobs, idling most of the workday. We recognize that there are utilities with rigorous DOT management programs for equipment and drivers, but generally we find a more lax daily inspection protocol among utilities and contractors than you would find with a carrier. That might be justified considering the time a utility truck spends in transit compared to a carrier that is preparing to put a rig on the road with two drivers for 20 hours a day over the next two weeks. But it’s not the rule, and mistakes or latitude over trucks can suddenly become a serious liability when one of those overlooked trucks loses a steering link as it is driven through a school zone full of first-graders.

Craft Worker Compliance
Recently there have not been any changes of note in the rules for vehicle weight and load securement; however, it appears that some of the latitude taken by utilities, if not given by the DOT, has caught the attention of those responsible for enforcement of the rules. 

In the last couple of years, state enforcement agencies used local media to inform local commercial businesses – that are not carriers – that they would be stopped if they did not appear to comply with loading and marking standards for their class of vehicles. In Arizona, New Mexico, Washington and Colorado, my colleagues and I began to hear of roadside stops involving lawn maintenance companies and small construction concerns that were pulling dual-axle, 5-ton trailers behind a Ford F-350, carrying loaders, backhoes and super lawn machines. That soon extended to power company trucks, especially those loaded with large wire reels. I even heard of one instance in which state enforcement set up scales in a shopping center parking lot on a well-known route out of a power company service center. Within 40 minutes they cited 22 vehicles for being overweight. You would think drivers would have warned others, but the DOT waved them into the parking area before they started weighing and inspecting the vehicles, so no one knew what to expect. It shouldn’t have been – but it was – a big surprise for that utility’s fleet management to learn what kind of loads lineworkers were putting on those trailers.

Over the past six months, three things have happened that I want to mention. First, I have answered numerous questions from clients and Incident Prevention readers regarding personal protective grounding (PPG). Second, the industry has experienced a rash of injuries and fatalities related to current in grounded circuits. The incidents most often have been associated with induction, but not always. And third, I have consulted with utilities and contractors, large and small, who are just now recognizing they have issues understanding PPG. It’s been hard to gauge the numbers – such as the frequency of incidents and especially comparing the seriousness of injuries – because there is no reliable clearinghouse for tracking incidents other than fatalities reported to the U.S. Department of Labor.

All of this is beside the real point, however, which is that there is no reason for any of these incidents to have occurred at all. Well, there is one: The utility industry is behind the curve in their understanding of the phenomenon of current in grounded conductors. There is an explanation for that, and it’s time to write about it again.

Let me be clear: The purpose of this article is to work toward solving the problem, not to find fault. To understand how we got to where we are, let’s first talk about industry awareness. Anyone who does research on the fundamentals of utility system grounding will notice that we have been struggling with PPG since as early as the 1950s. This has been documented in various papers from the IEEE archives of “Proceedings of the IEEE” – one of the first electrical industry journals, established around 1927 – and in “IEEE Transactions on Power Systems” since 1985.  

As the IEEE 1048 standard, “IEEE Guide for Protective Grounding of Power Lines,” points out in the introduction to the 2003 edition, “Protective grounding methods have often not kept pace with their increasing importance in work safety as the available fault current magnitudes grow, sometimes to as high as 100 kA, and as right-of-ways become more crowded with heavily loaded circuits, leading to growing problems of electric or magnetic induction.” Did you notice the date of the standard? The 2003 edition is a revision of the 1990 standard on protective grounding. As I stated earlier, we’ve been struggling with PPG since as early as the 1950s. Over 60 years is a long time to still not have figured it out.

I read the menu board and placed my order through the drive-through speaker. In her native Spanish, the employee assisting me rapidly confirmed my order and asked several follow-up questions; I answered “yes” to each question even though I didn’t understand what she was asking me. In the end, the order totaled $9.62. When I opened the contents of the bag, it was like opening a Christmas present, since I had no idea what I had just ordered. And, well, it was Christmastime after all, even though I happened to be in Puerto Rico.

That experience was my first lesson as an American who only speaks English in a place where – although both Spanish and English are official languages – Spanish is the dominant language. Over the years I had wondered why non-English-speaking workers would indicate understanding during training when they didn’t understand. Now I realize it’s a case of assumptions. I thought I knew what the employee at the fast food restaurant was asking, but I was way off. I had never been on that end of the conversation, and now I have a fresh perspective on non-native English speakers and training in the U.S.

I also have a new appreciation for the people of Puerto Rico. While there recently, I was in daily contact with people who’d had no power for 12 weeks. And for some of them, they knew it would be many more weeks before they did have power – and that might be a little optimistic. Not one person was rude or even expressed aggravation at their plight. In contrast, I am aware of utilities that had their front-office glass shot up by angry customers three days after a storm passed.  

Even in Puerto Rico’s larger cities, such as San Juan in the northern part of the island and Ponce in the south, where some power has been restored, there are still few working streetlights or traffic signals. Driving outside of San Juan, where there is no working traffic control, has become a mix of jousting and bluff. The practice is to speed up to the intersection and see if anyone slows. If they do, you are in. If they don’t, you wait and surge forward at the next driver. Yet this contrived system of driving is absent the aggression and manic reaction you might expect. No one blows their horn, points a gun at you or even gestures. It’s how you get around, and everyone is simply working it out.

Two U.S. Navy ships recently were involved in collisions at sea. It seemed impossible that one event, involving the USS Fitzgerald, would even occur. Then, a second collision occurred in the same region. In fact, in the last year, the Pacific fleet has experienced four serious navigational awareness errors, which has raised a question: Could the Navy have become so slack in discipline and readiness that these events were destined to happen?

We all know that, just as in the military, frontline leadership in the utility industry has a direct bearing on performance in the field. Yet after-action analysis indicates that when the Navy incidents occurred, the front line performed above expectations, indicating their competency and competency in their training as demonstrated by the actions of sailors. As was expected of the military, a quick response by Command relieved the ships’ leaders of their duties, citing loss of trust. Was Command correct? Did the ships’ leadership lose trust, or was it something else?

Some speculation arose among naval defense analysts that hackers may have caused electronic mayhem. A naval ship’s protection system depends on its electronic eyes and ears. Systems have evolved greatly since the days of the direct-wired blip from the antenna to the screen interpreted by a trained radar man. Early radar sent out a specific frequency wave that was several meters wide. The return wave depended on density of mass to return a reflection of that same frequency wave. The blip was interpreted by a trained observer to differentiate between an enemy bomber and a flock of geese. Today’s electronic radar frequency wave shifts are as small as 1 millimeter. A radar reflection comes back as thousands of bits that are interpreted by a computer. The radar screen now delivers an information-laden message to the radar man, who reads and reports the information displayed to him – by the computer. Some reports suggest that contemporary radar used by the military can detect a suitcase-sized drone that is miles away. The same types of systems scan for other threats, such as missiles and warplanes. If a hostile force wants to disable such protection, hacking a ship’s digital protection capabilities would make it vulnerable.

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.

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?

To begin this article, I want to offer a disclaimer. One of the reasons the “Train the Trainer 101” series was created is to examine the practical aspects of compliance as they relate to the utility industry. We do that by reading the statutes, looking at how OSHA interprets and enforces the rules, reviewing what the consensus standards state and then determining practical ways the employer can manage and comply with the rules. Sometimes I raise an eyebrow, but in working with the group of professionals who review every article published in Incident Prevention’s pages, we endeavor to ensure the advice given is not merely good but also compliant. With that said, in the following pages I am going to address some fall protection issues that iP has received many questions about in recent weeks. Several of them are driven by the latest OSHA final rule on walking and working surfaces, which contains some new language and expanded rules on fall protection.

Who is Responsible?
I get a lot of questions about fall protection that stem from a salesperson telling an employer they need to do a certain something in order to comply with OSHA. First, a nod to our partners in the industry: the vendors and manufacturers. They have done a great job meeting the needs of the employer by innovating, creating and often collaborating with the industry to get the tools we need into the field. Work with your vendors and manufacturer representatives, but be clear about your responsibilities in the relationship. Understand that there are no OSHA-approved devices for sale in any marketplace. OSHA does not approve equipment for manufacturers even though they may comment on a method of compliance if a written request is made by an employer. Even then, OSHA’s language to the employer often is something such as, “OSHA does not approve a particular device or piece of equipment, but the method you describe would meet the requirements of the standard.” And never forget that – no matter what the manufacturer’s rep says – you, as the employer, are ultimately responsible for how you comply with OSHA’s expectation. As I said, work with your vendors, but do your homework and educate yourself about the requirements. We aren’t just complying with standards – we’re protecting our employees and co-workers.

Common Misconceptions About Harnesses
I have often heard that you can’t arrest at the waist or chest. That is correct if you are truly arresting, which usually means the act of interrupting a fall from height by a personal fall arrest system attached to an anchorage limited to a distance of 6 feet. If you fall 6 feet, you must limit the fall arrest’s load, and the fall arrest’s load must be distributed across the body. That is why we use a full-body harness.

OSHA’s final rule on 29 CFR 1910 Subpart D, “Walking-Working Surfaces,” is finally here. It’s 26 pages of nine-point font equaling 21,675 words, and I read them all. It’s big, and if you include the preamble in your analysis, it is also complicated. It was just as hard to write about as it was to read. I guess that shouldn’t be unexpected for a final rule that has been in the works since 1983. The original 1910 Subpart D was published in 1971. The first update was proposed in 1983, but it was never ratified. Proposals were again considered in either the Construction standard or the General Industry standard in 1990, 1994 and 2003. This edition of the final rule for 1910 Subpart D covers it all. OSHA should be congratulated for bringing almost all of the fall-related standards into one location, making it easier for the employer to find rules related to working surfaces under one subpart instead of having to search for those rules that may affect the employer’s workplace. This may be news to some novice safety professionals in the utility industry, but not all regulations affecting us are restricted to 1910.269 or 1926 Subpart V. Subpart D applies, so it is important to be familiar with it.

What’s New?
Preventing falls is almost the entire purpose of rules for walking-working surfaces. The surfaces are not always those spaces of aisles between walls. Most walking or working spaces in the workplace are not defined aisles; they are more likely to be incidental spaces about the work area. It is quite easy for those incidental spaces to be encumbered by tools, materials and process waste that create stumbling or tripping hazards. In addition, many of those working spaces are raised surfaces, from the tops of foundations to the tops of skyscrapers. That being the case, OSHA has brought into Subpart D the body of fall protection standards. You will now find a greatly expanded section on ladders; step bolts (towers) and manhole steps; scaffolds and rope descent systems (building maintenance); the duty to have fall protection; new and expanded requirements on fall protection equipment design; and some expanded language on the training of employees to recognize and prevent falls in the workplace.