Voice of Experience Articles

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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Guest — Chad Roscoe, CHST, STSC
Danny, great article and thank you for the insight into this subject. You are right, there hasn't been a lot of talk about this is... Read More
Thursday, 25 August 2016 07:47
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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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Danny Raines, CUSP

Voice of Experience: Working On or Near Exposed Energized Parts

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.

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Danny Raines, CUSP

Voice of Experience: Incidents and the Failure to Control Work

Flashes and contacts continue to happen throughout the electric utility industry. All sectors, from the smallest contractor to the largest investor-owned utility, report incidents every day. I have seen reports that one contractor working a 23-kV circuit locked out the breaker twice in one day. Other reports now indicate that 2013 is trending even higher than last year for the first four months of the year. The industry is on course to meet the average of 24 to 28 fatalities documented in the utility and contractor North American Industry Classification System codes reported to U.S. Bureau of Labor Statistics.

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Danny Raines, CUSP

Voice of Experience: Training for the Qualified Employee

Training is required by OSHA and all employees should follow proper training, but the unfortunate truth is that doesn’t always happen, resulting in accidents, contacts and fatalities. OSHA is very specific about defining what qualifies employees to work on and near energized conductors and equipment energized at greater than 50 volts. To be qualified to work on systems considered primary voltages greater than 600 volts, the mandated training is markedly more intense because of the requirements for such things as knowledge of component specialization, procedures such as insulate or isolate, and the personal protective measures and personal equipment used, among others. The ideal trainer is OSHA-authorized and intimately familiar with federal standards and expectations, and has industry experience as well as a broad knowledge of consensus standards and contemporary practices related to the topics being covered. Electric utility employees are a tough group, and they will be tough on an instructor who has no utility experience. Instructors should not deliver training material simply via PowerPoint presentations or similar delivery methods. Examples and accident histories should be incorporated into the training. Additionally, OSHA requires field observations in order for employees to prove their proficiency in the training subject. After training is complete and an employee has proven proficiency, the employer can state the employee is qualified for the task.

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Danny Raines, CUSP

Voice of Experience: The Cost of Business

Sadly, accidents in our industry continually occur even though they are avoidable. I have spent the better part of 46 years teaching safe work practices, rules and regulations in an effort to prevent accidents from happening. However, in all the time I spent on the job, from my start as a helper on a line crew until I was promoted to line crew supervisor, I never really considered the costs of injuries or property damage. Due to the culture of the industry, the costs were seen as just part of doing business. In this article, I want to take a few minutes to share with you the costs of accidents.

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Danny Raines, CUSP

Voice of Experience: The Definition of Personal Protective Equipment

I can remember a day when I would ask employees to name the five topics of a job briefing and why personal protective equipment (PPE) is the fifth point on the list of topics. Since the second part of the question was always a greater challenge for everyone to understand, I’d like to take some time to discuss the differences between protective equipment and PPE. Employees sometimes consider PPE to be system safety grounds, cover-up equipment, traffic vests and other equipment. As you can see in the excerpt below, 29 CFR 1910 Subpart I defines and identifies PPE as well as the body parts that are required to be protected while performing work.

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