OSHA 29 CFR 1910.269(l), “Working on or near exposed energized parts,” requires employees to adhere to very specific rules concerning the exposure of unprotected body parts to energized conductors and equipment. I am amazed at the different interpretations of this one paragraph. I have thought about what work practices were being considered by the advisory panel that made the suggestions about how the standard should read when it was being written in the 1980s. The standard is very clear that two qualified employees are required to be on the job site when work is being performed that exposes an employee to minimum approach distances (MAD) on equipment or conductors with nominal system voltage of 600 volts or greater. Why? Is it due to the type of task being performed, or is the second person there for emergency rescue or fist aid? Depending on the task, there may be a legitimate safety reason to require the second employee. Does that second person need to be in the air in a two-person bucket or second bucket to assist, or should they be on the ground observing and available to assist in rescue? The answer depends on whom you ask. I sometimes wonder what the original committee intended.
Paragraph 1910.269(l)(2) describes how employees should approach and handle conductive items near energized equipment. I often ask myself why there isn’t equal emphasis on proper cover on differences of potential and energized parts and equipment. In paragraphs (l)(2) and (l)(3), the word “energized” is mentioned seven times while “different potential” is mentioned once. I suspect that much consideration was given to safe gloving procedures for 4 kV off the pole. For anyone who has ever gloved 4 kV from the pole, it is critical to properly cover all energized conductors and equipment. Standing on the pole, the employee is the ground and can’t risk any exposed part not being covered properly or being within reach. The worker should lean away from covered conductors and equipment. Also, a position should be taken below the conductor or equipment being worked on so a slip or unanticipated move would not cause the worker to fall into what is being worked on.
When the industry stepped off the pole into the bucket, the method of cover never changed. It was easier to select an improper position level with or above what was being worked on, putting workers in harm’s way if a flash were to occur for any reason.
Energized conductors were covered, but now the employee is standing on a dielectric platform and is no longer ground potential. The emphasis was still on energized conductors and equipment, but now it is easier to select that improper position and overreach rubber. There was no additional caution given about covering grounds and differences of potential. The method of installing cover was still energized. Most lineworkers today, if they are honest, have been buzzed while standing in the bucket and not adequately covering up the energized equipment. What really occurred then was an acid test of the bucket liner. Glad the test was good.
The industry experiences then and now are contacts with energized parts and differences of potential. Very few events are phase-to-phase contacts. Even the following rule in 1910.269(l) requires the use of gloves and sleeves, with two exceptions:
“1910.269(l)(3): ‘Type of insulation.’ If the employee is to be insulated from energized parts by the use of insulating gloves (under paragraph (l)(2)(i) of this section), insulating sleeves shall also be used. However, insulating sleeves need not be used under the following conditions:
“1910.269(l)(3)(i): If exposed energized parts on which work is not being performed are insulated from the employee and
“1910.269(l)(3)(ii): If such insulation is placed from a position not exposing the employee's upper arm to contact with other energized parts.”
Approximately 50 percent of the industry requires gloves and sleeves. Sleeves are not the answer to accidents resulting from inadequate cover-up. If contacts are occurring, it is simply because the company has not established a proper cover-up program and is not enforcing the cover-up policy and training procedure in the field.
An overestimation of workers’ ability to control and poor judgment are causal factors of the contacts. If workers fail to use adequate cover, they are just testing rubber while working. If a worker is willing to place a sleeved arm against a difference of potential – for example, an arm, a pole or a guy – they are testing the rubber. Sleeves have nothing to do with an effective distribution cover-up program.
In 1910.269(l)(6), “Apparel,” the performance standard states what shall not be worn while working on energized conductors and equipment. It does not state what to wear. Workers need to refer to the industry consensus standard, the National Electrical Safety Code, for this information. If you look back to the 2007 version, you will find that NESC Rule 410.A.3 states, “Effective January 1, 2009, the employer shall ensure that an assessment is performed to determine potential exposure to an electric arc for employees who work on or near energized parts or equipment. If the assessment determines a potential employee exposure greater than 2 cal/cm2 exists, the employer shall require the employee to wear clothing or a clothing system that has an effective arc rating at least equal to the anticipated level of arc energy."
Everyone needs to remember that the term “FR” doesn’t mean clothing is arc-rated unless the material has a hazard risk category or an arc rating in calories per centimeter squared. Any exposure above 1.2 requires arc-rated apparel to be worn within minimum approach. Material that passes the ASTM vertical flame test may not be arc-rated and will not protect as well in the event of an arc flash incident.
MADs are covered in the last section of paragraph L. Those numbers in the OSHA performance standard have been the same since the standard was issued in the early 1990s. In the 2002 edition, NESC changed the MAD on 25 kV to 31 inches; 15 kV is still the original 2 feet, 2 inches. Both are too close without proper cover in place.
OSHA 29 CFR 1910.269 has been under revision since 2006. Several changes are anticipated, but no one knows for sure when the release and enforcement dates will be. For now, all we have to work with is the 20+-year-old document. The sad fact is many in the industry don’t even follow the current version. A dear friend of mine recently called to tell me that they witnessed a crew performing energized work on primaries with not one piece of rubber on the conductors. Flashes, contacts and fatalities continue to happen to some of the most talented workers in the world. Just remember, safety excellence only comes by way of operational excellence. Follow all the rules all the time and stay safe.
About the Author: Danny Raines, CUSP, safety consultant, distribution and transmission, retired from Georgia Power after 40 years of service and opened Raines Utility Safety Solutions LLC, providing compliance training, risk assessments and safety observation programs. He is also an affiliate instructor at Georgia Tech Research Center OSHA Outreach in Atlanta. For more information, visit www.electricutilitysafety.com.
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