Danny Raines, CUSP

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

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

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

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

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

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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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Danny Raines, CUSP

Voice of Experience: OSHA Record-Keeping Requirements

OSHA record-keeping has long been an administrative challenge to businesses required to keep OSHA logs. In this installment of “Voice of Experience,” I’ll cover some changes that have occurred over the years as well as some essentials that all employers and employees must understand in order to maintain compliance with OSHA requirements.

When the change from the OSHA 200 log to electronic record-keeping was made in 2002, it was a relief to many. At that time, all issues involving first aid were resolved; a list of first aid treatments was identified and took any doubt out of the requirement to report medical attention beyond first aid.

The addition of a hearing loss column to OSHA’s Form 300, “Log of Work-Related Injuries and Illnesses,” in 2004 helped identify hearing loss for those businesses covered by OSHA 29 CFR 1910.95(c), “Hearing conservation program.” Previously, hearing loss often was considered an illness rather than an injury.

Today, the number of logs a business must maintain is determined by the number of premises operated by the business. A log is required to be maintained for each location with an address unless there are multiple facilities at the same address. Centralized electronic record-keeping is acceptable if the records can be provided within four business hours upon request by an OSHA officer. The request must be made in the location of the corporate office where records are kept, even when it is in a different time zone.

An injury must be reported to a record-keeper for logging within a maximum of seven days from the time of the accident; this requirement has not changed. The supporting forms required to document the log entry also remain the same. OSHA’s Form 301, “Injury and Illness Incident Report,” or an acceptable state workers’ compensation form must accompany any orders written by a licensed health care provider (LHCP). All documentation must be retained and kept available in case of an audit. The number of days away or restricted days must be recorded and may be capped at 180 days. The current year and the last five years of OSHA 300 logs must be available for audit or inspection upon request by approved officials. OSHA’s Form 300A, “Summary of Work-Related Injuries and Illnesses,” must be posted no later than February 1 of the year following the year covered by the form, and it must remain posted in the establishment for 90 days in conspicuous locations that are frequented by employees.

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Danny Raines, CUSP

Voice of Experience: Inspection, Maintenance and Fall Protection Guidance for Bucket Truck Use

OSHA 29 CFR 1910.67 is the performance-based standard that covers requirements when using vehicle-mounted elevating and rotating work platforms, including the bucket trucks we use in the electric utility industry. There are many types of buckets, and the task to be performed will determine what type of bucket is required. This standard even covers noninsulated work platforms, sometimes referred to as JLGs, used in civil construction. For clarification, a mobile platform covered under 1910.68, “Manlifts,” is not covered under the 1910.67 standard. Mobile platforms are considered mobile scaffolding and require standard guardrail protection. Additional fall restraint normally is employed depending on the type of work and availability of fall protection attachment points.

Although today our industry is better trained than ever, it wasn’t so long ago that one of the most violated standards was the requirement to fly the booms every day before employee use. According to paragraph 1910.67(c)(2)(i), “Lift controls shall be tested each day prior to use to determine that such controls are in safe working condition.”

The fall protection requirements for utility bucket trucks are currently covered under 1910.269(g), “Personal protective equipment.” The users of bucket trucks now have options for fall protection, including a personal fall arrest system, fall prevention or a retractable lanyard. Fall protection equipment is much more user-friendly and lightweight than ever before.

In the remainder of this article, I want to focus on bucket truck inspections and maintenance required by OSHA, manufacturers and others. This information is critical but sometimes is not followed by employers or employees, which has led to a number of catastrophes.

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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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Danny Raines, CUSP

Voice of Experience: OSHA’s MAD Changes and a Missed Opportunity

In the 2014 OSHA update to 29 CFR 1910.269 and 1926 Subpart V, major changes were made regarding apparel and minimum approach distance (MAD) calculations. And yet I believe the agency missed an opportunity related to distribution voltages and gloving of energized conductors and equipment. For all intents and purposes, other than the MAD updates, few changes occurred in 29 CFR 1910.269(l) regarding working position. A new requirement removed any implied obligation that an employer is accountable for ensuring employees do not approach or take any conductive objects within the MADs found in tables 6 to 10 of 1910.269. The standard now clearly and without any doubt requires an employer to calculate and provide MADs to all employees and contractors working on energized systems.

Paragraph 1910.269(l)(3)(i) now states that the “employer shall establish minimum approach distances no less than the distances computed by Table R-3 for ac systems or Table R-8 for dc systems.” And the updated standard also now requires an engineering analysis on voltages greater than 72.5 kV to allow for transient overvoltages that occur due to system operations, breakers, capacitors or lightning. Ironically, the MAD found in the 2002 National Electrical Safety Code for 25-kV systems was 31 inches, 12 years before it was changed in OSHA’s update to 1910.269.

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Danny Raines, CUSP

Voice of Experience: OSHA Requirements for Step Potential Protection

When OSHA updated 29 CFR 1910.269 and merged almost all of its requirements with 1926 Subpart V, the requirement to protect employees from step potential was enhanced. In the months following the publication of the final rule, this change was rarely mentioned in the major webinars conducted by several prominent utility industry groups, so I want to take this opportunity to cover what you need to know.

First, let’s talk a bit about the basic fundamentals of Ohm’s law and Kirchoff’s law of current division in order to ensure you understand the seriousness of step potential hazards. Ohm’s law states that electricity will take any and all conductive paths, and Kirchoff’s law of current division states that the amount of current flow is dependent on the resistance and impedance in the current path.

As I travel around and conduct training, I find that many electric utility employees – much like me in the 1970s – do not understand these and other basic laws of physics that determine the number of hazards we face. The human body is not much more than a 1,000-ohm resistor when put into an electrical circuit. If a human body is placed in an electrical path/circuit, the amount of electricity that enters the body is about 50 volts AC. During this type of occurrence, the soles of normal work boots and shoes will provide an employee a small amount of protection, but if the employee were to kneel down and touch a vehicle grounded to a system neutral, or place a hand on a grounded object, the amount of protection would be significantly reduced.

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Danny Raines, CUSP

Voice of Experience: OSHA Citations and Informal Conferences

OSHA fines will increase for the first time in 25 years under a provision in the recently signed U.S. congressional budget deal.

The Federal Civil Penalties Inflation Adjustment Act of 1990 exempted OSHA from increasing its penalties to keep pace with inflation. But a section of the new budget signed in November by President Barack Obama – referred to as the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 – strikes the 1990 exemption.

Now, OSHA is directed to issue an interim final rule adjusting its penalties to account for current inflation levels, which would raise proposed fines by about 80 percent. This means the maximum penalty for a willful violation would rise from the current $70,000 to about $127,000. Additionally, OSHA fines for serious and other-than-serious violations could increase from $7,000 per violation to approximately $13,000 per violation. The penalty adjustment must take effect before August 1 of this year. In subsequent years, employers should expect to see OSHA fines increase by January 15 of each year as the agency makes adjustments based on the annual percentage increase in the consumer price index.

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Danny Raines, CUSP

Voice of Experience: Hand and Skin Protection for Electric Utility Workers

With the recent changes to the OSHA standard, many employers are working on what rules apply – the arc flash standard or the PPE standard – and how to comply with them. Part of the issue is determining how many types of protection are needed and what types of protection are appropriate.

To begin, OSHA’s requirements for all personal protective equipment can be found in 29 CFR 1910 Subpart I. Rules specific to hand protection can be found in 1910.138. They read as follows:

1910.138(a)
“General requirements. Employers shall select and require employees to use appropriate hand protection when employees' hands are exposed to hazards such as those from skin absorption of harmful substances; severe cuts or lacerations; severe abrasions; punctures; chemical burns; thermal burns; and harmful temperature extremes.”

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Danny Raines, CUSP

Voice of Experience: PPE Regulatory and Consensus Standard Requirements

OSHA 29 CFR 1910 Subpart I and 1926 Subpart E cover the requirements of personal protective and lifesaving equipment. With the publication of OSHA’s final rule in April 2014, the general industry and construction standards are now essentially the same for electric utilities, and there are few if any differences in the PPE required by each standard.

In addition to OSHA’s regulatory standards, there are ANSI/ASTM and other consensus standards that govern the manufacturing, type and ratings for all PPE. These consensus standards change as the industry evolves and PPE improves. All PPE should meet the most recent standard requirements. In the remainder of this article, we will examine OSHA’s PPE requirements for electric utility workers, as well as some of the latest consensus standard requirements.

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Danny Raines, CUSP

Voice of Experience: Clearing Up Confusion About 1910.269

It’s now been 18 months since OSHA’s final rule regarding 29 CFR 1910.269 and 1926 Subpart V was published. For the most part, the dust has settled and the industry has started to adjust to the requirements of the new standard. However, questions still abound regarding certain issues, and I’d like to address two of them – employee training and host-contractor information transfer – in this installment of “Voice of Experience.”

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Danny Raines, CUSP

Voice of Experience: Power Generation Safety and the OSHA Update

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.

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Danny Raines, CUSP

Voice of Experience: Fundamentals of Underground Padmount Transformers

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.

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Danny Raines, CUSP

Voice of Experience: OSHA Updates to Arc-Rated FR Clothing Requirements

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.

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Danny Raines, CUSP

Voice of Experience: The Importance of Job Briefings

As I write this article, I am reflecting on 2014 and thinking about how many contacts and fatalities the electric utility industry suffered last year. There were fewer than in 2013, but the improvement was only slight. At present, the most accurate count for 2014 is approximately 40 fatalities and 45-50 electrical contacts. One serious injury or fatality is too many, and all of them can be avoided by planning and the proper use of training, tools, time and teamwork.

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Danny Raines, CUSP

Voice of Experience: How Does the Employer Ensure and Demonstrate?

As all of you now know, the updates to OSHA 29 CFR 1910.269 and 1926 Subpart V have been out for several months, and the October 31 enforcement date extension has come and gone. There were some anticipated changes to the standard that the industry was expecting, but the more subtle revisions I’ve seen may be the ones that are more difficult to implement. The industry was given extra time to understand and clarify some of the changes, and extensions in a few areas may be granted once again.

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Danny Raines, CUSP

Voice of Experience: Flame-Resistant Apparel is Now PPE

It’s official: Flame-resistant clothing is now considered PPE, and employers are required to furnish it to employees when there is a chance that they may be exposed to electric arcs or flames. This change has been a long time coming as the industry has been in limbo for years. A number of forward-thinking companies have been furnishing arc-rated FR clothing to their employees for some time, while others have waited for regulations to require them to do so. The company from which I retired as well as other large investor-owned utilities have uniform policies that incorporated arc-rated FR clothing years ago.

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Danny Raines, CUSP

Voice of Experience: OSHA Eye and Face Protection Standards

In this installment of “Voice of Experience,” we will take a look at the wording in OSHA 29 CFR 1910.133, “Eye and face protection.” A review of this standard is a great opportunity to gain a better understanding of what OSHA requires of both the employer and employee in order to properly protect these vital body parts in the workplace.

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Danny Raines, CUSP

Voice of Experience: Understanding Enclosed and Confined Spaces

What is the difference between an enclosed space and a confined space? Many companies do not acknowledge 29 CFR 1910.269(e), “Enclosed spaces.” Instead, they handle all spaces as confined under 1910.146, “Permit-required confined spaces,” and a few companies even handle them all as permit-required spaces. There may be some confusion and there certainly is much industry discussion about the spaces in which employees are asked to work. In this article, I will highlight several of the major differences between the spaces, as well as provide an overview of each of the OSHA standards.

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Danny Raines, CUSP

Voice of Experience: OSHA 300 Record-Keeping Rules

Every supervisor and manager should know who keeps the OSHA 300 log and what is required to document an entry. Every employee should receive awareness training about how entries are documented and what is looked for during an audit. The mystery behind the OSHA 29 CFR 1904 record-keeping standard is a result of its complexity and the confusing ways it is sometimes interpreted. I have been teaching record keepers for more than 25 years, dating back as far as the OSHA 200 days. I find it one of the most entertaining topics to learn about and teach, but it can also be challenging to fully understand. We need to remember that OSHA record keeping is a federal program. All workers’ compensation cases are not OSHA recordable, but all OSHA recordable cases are workers’ compensation cases. Due to the depth and breadth of this topic, I won’t be able to cover every detail in this article, but I will highlight areas that tend to create the most confusion for those who work in our industry.

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