Utility Worksite Safety Articles

Apprenticeships in the utility and construction fields often serve as a transition point for individuals from sedentary or light work to heavy or very heavy jobs. As more individuals seek jobs in the trades, many may have little to no experience with regular physical activity. Injury-free performance of heavy or very heavy job tasks strongly corresponds to an individual’s physical abilities and health habits. While the electrical utility industry strives to engineer the risk out of jobs, many tasks still require a minimum amount of strength, endurance and flexibility.

Strength and conditioning principles have long been used in sports to ensure that would-be players achieve the specific demands of their desired position while also optimizing performance. Similarly, hiring managers, training specialists and safety professionals can implement these same principles into apprenticeships to enable new employees to achieve the physical ability needed to perform their work safely. This creates a win-win scenario that helps to prevent workplace injuries and increase the health and wellness of employees.

A news helicopter circled overhead as the two ambulances left the job site. The deputy sheriff looked at the superintendent and said, “Tell me again, how did this happen?” The superintendent removed his safety glasses with a sigh as he surveyed the devastation left behind by the 345-kV contact. “Well, we had to set up for work directly under these lines because some local environmentalists wanted the wildflowers protected,” he said. “So, we did what we were asked. If you notice over there, those flowers are still looking beautiful, but it seems that the now-deceased landowner still didn’t like us being here, so he ran onto the right-of-way and tried to climb up onto the boom truck to stop our work. This must have caught our groundhand off guard, because instead of just stopping the work and notifying his supervisor, he attempted to intercept the man. All this commotion distracted the operator, causing him to contact the line. Once that happened, 345 kilovolts of electricity killed the landowner instantly, and our ground worker was severely shocked by what we call step potential.”

Although the preceding paragraph is an extreme worst-case example of how right-of-way (ROW) distractions and conflicts can impact our job sites, it’s not unrealistic. In this article, we will look at how members of the public and our own workers can create distractions and conflicts that jeopardize our ability to do our jobs well, and we will also consider safe ways to handle these types of distractions and conflict.

When you think of people who have changed our lives with their inventions, you may think about Thomas Edison and his lightbulb or Alexander Graham Bell and his telephone. Not many of us would think to include Edward W. Bullard on that list, but 100 years ago – in 1919 – he invented the hard hat, which today is one of the most recognized safety products in the world and is responsible for saving thousands of lives over the past century.

To truly trace the heritage of the hard hat, we have to go back even further to 1898, when Edward Dickinson Bullard founded E.D. Bullard Co. in San Francisco. The company originally supplied carbide lamps and other mining equipment to gold and copper miners in California, Nevada and Arizona. Then, when Bullard’s son, Edward W. Bullard, returned from serving in World War I, he went to work for Bullard Co., combining his understanding of customer needs with his experiences with his doughboy army helmet to design protective headgear for miners.

The young Bullard called his protective headgear design the Hard Boiled Hat because of the steam used in its manufacturing process. The original Hard Boiled Hat was made of steamed canvas, glue, a leather brim and black paint. This invention revolutionized mine and construction worker safety. Edward W. Bullard then took his Hard Boiled design one step further by building a suspension device into the hat, and that became the world’s first commercially available industrial head-protection device.

On May 3, 2018, Hawaii Electric Light Co., the company I work for, discovered we had a problem. Lava flows were popping up in the middle of a residential neighborhood in our service territory. This wasn’t the first time Hawaii Electric Light had experienced a volcanic eruption, but it was the first time one had begun in the middle of a densely populated area. We wondered, how would we keep our employees safe during this event? How would we keep the lights on in the affected area? These were the questions that had to be answered very quickly given the circumstances.

Hawaii Electric Light is the electric utility that serves the island of Hawaii, the biggest of all the Hawaiian Islands. Of the five volcanoes on the island, the three that are considered active are Hualalai, which last erupted in 1801; Mauna Loa, which last erupted in 1984; and Kilauea, which has been continuously erupting since 1983 and was the volcano that erupted in May.

In the Hawaiian culture, Kilauea is the home to Madame Pele, the goddess of fire and volcanoes. As the legend goes, from her home in Halema’uma’u Crater at the summit of Kilauea, Madame Pele determines when and where the lava flows. She is the goddess who shapes the sacred land. Hawaiians say that she has a reputation for being as fickle as she is fervent. She proved many times during the May 2018 eruption that she was indeed in charge.

Preventing accidents in utility work, where safety is paramount, starts with establishing protocols for personnel and equipment. Creating task-based and specific work assignments is an affordable way to establish realistic parameters for work to be performed. Using this method enables crew leaders to develop consistency and reliability in assigning tasks by distinguishing between trainees and qualified personnel. Work is assigned based on skill proficiency, which in turn leads to risk mitigation and accident prevention.

The concept of grouping teams of workers by specific work assignment is nothing new. Success stories outside of the utility industry include military and police forces trained to respond to emergencies, trauma surgery teams, astronauts in space, NASCAR pit crews and the University of Alabama football team. Whether you are an Alabama fan or not, Coach Nick Saban’s formula for a championship team involves drilling and honing skills of individual players. The result is a team that works together cohesively for outstanding performance.

In the same way, utility workers with the same job title and general responsibilities – lineworkers – come to the job with different years of experience, types of training and skills. Supervisors who recognize these differences can create outstanding crews by establishing parameters for skills that each person on the crew must have in common, as well as knowing who possesses task-specific talent.

To create a proficient team that performs as a cohesive unit, it’s critical to first determine the skill, knowledge and ability of each individual crew member. These measurements define a baseline of strengths, weaknesses and gaps to fill. Not everyone on the crew needs to have the exact same skill level, but the crew’s collective ability should instill confidence that the crew can work under pressure in adverse conditions without injury. If there are gaps in the collective ability, then you must plan to train and practice so that skills, techniques and technology meet your previously established protocols.

Sunflower Electric Power Corp. is a generation and transmission cooperative located in Western Kansas. We have approximately 2,600 miles of overhead transmission lines, which we patrol annually using vehicles. While you may have heard stories about Kansas being flat as a pancake, they are not true. Several areas of our service territory feature deep ravines, water crossings, washouts and rock outcroppings that make line patrols challenging and hazardous. In the past, patrol vehicles used by our line technicians were either pickup trucks or standard-equipped side-by-side all-terrain vehicles (ATVs). After enduring a few ATV-related accidents that caused damage to both workers and equipment, we knew it was time to evaluate our line patrol program to see what we could do to make it safer.

Our most recent injury, which occurred in 2016, resulted in facial injuries that required reconstructive surgery after an employee hit his face on the steering wheel of the side-by-side ATV he was operating. Following is a summary of the accident.

A line technician was patrolling by himself and came upon an area of grass that was close to 4 feet tall. He did not see the depression in the ground in front of him and dropped the front end of the ATV he was driving into a washed-out area that was approximately 4 feet deep and 6 feet wide. Upon entering the depression, the ATV came to an abrupt stop and the line technician’s face made contact with the steering wheel. This caused multiple fractures of his nose. The line technician was wearing the standard seat belt, which consisted of a lap belt and shoulder strap, but it didn’t lock up fast enough on impact to prevent injury. Fortunately, the technician was able to get himself out of the ATV and walk approximately one-eighth of a mile back to the main road, where his pickup was parked. He then called other crew members for assistance; they transported him to the local hospital, where he was treated for his injuries. Unfortunately, the technician had to have follow-up surgery to repair his broken nose.

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.

For over 100 years, PECO – a Pennsylvania utility and member of the Exelon utility family – has been supplying electricity and natural gas to customers across southeastern Pennsylvania, including those in Philadelphia and its surrounding suburbs. PECO has hundreds of miles of utility poles and thousands of circuit miles of medium-voltage distribution cables installed in conduit and manhole systems.

With all this infrastructure, it is only natural that wear and tear will occur, which can have an impact on the distribution system. Over the decades, PECO has experienced numerous failures of distribution system components, some of which developed into fires that were difficult to combat due to poor weather conditions. Unfortunately, local volunteer fire departments typically are not equipped to deal with these types of fires, and even city fire departments, whose workers receive training on electrical fires, sometimes have a difficult time extinguishing them.

Regulations and Extinguishing Agents
Another issue PECO employees have had to deal with is the type of fire extinguishers available in their work vehicles. For utilities that have service fleets and operate under federal guidelines, the U.S. Department of Transportation requires those fleet vehicles to carry fire extinguishers. Per Federal Motor Carrier Safety Regulation 393.95, “Emergency equipment on all power units,” each extinguisher must have a gauge to indicate if the extinguisher is fully charged and a label that displays its UL rating. Extinguishers also must be securely mounted and readily available and accessible for use at all times. In addition, a vehicle transporting hazardous materials must be equipped with an extinguisher with a UL rating of 10 B:C or more. If the vehicle is not transporting hazardous materials, it must carry one extinguisher with a rating of at least 5 B:C, or two extinguishers, each with a rating of 4 B:C or more.

Most utilities and contractors that perform work on energized conductors use some form of cover-up program or process. Culture plays a big part in how we currently cover for protection. When a new lineworker joins the crew, that person learns the ways of senior members of the crew, and later that knowledge is passed on to the next new person. Having control of what we work on also has played a significant role in how we cover. If you have control of the energized conductor or equipment you are working on, you may not need as much cover for protection, right? The problem is, in numerous cases, something unexpected has occurred, resulting in a flash or contact event.

There also are other reasons why we continue to have flash and contact events. Today, there is more work to do than there are qualified lineworkers available to perform the work, so sometimes companies advance lineworkers through the ranks faster than they would have in the past so those employees can perform energized work. In addition, we don’t have the luxury of doing as much de-energized work as we once did. Sadly, according to the U.S. Bureau of Labor Statistics, over a period of five years – from 2011 to 2015 – there were 62 fatalities related to electrical contact.  

So, what does all of this information point to? Simply put, it is time for us to take what we have learned from the past and train today’s employees on how to insulate (cover) for those times when things could go wrong. Then, if they lose control of what they are working with, no injuries will occur.

That’s easy to say, but changing a company or department’s culture is not an easy thing to do, especially when the company or department employs longtime workers who have found repeated success with the control-and-cover method. Many companies have spent countless hours and dollars to improve their cover-up processes – and many times observations and audits indicate their crews are working just fine – yet events continue to occur. It’s no secret that lineworkers deal with differences of opinion about how cover should be applied.

Knowing bucket capacity and understanding how to read a jib load chart are two critical elements of aerial device operation. While both tasks are fairly straightforward, it is crucial to stay within the allowable capacity of the unit. The platform capacity and material-handling capacity provided by the manufacturer are not recommendations – they are absolute maximum capacities that ensure the machine is not overloaded. Overloading equipment can result in overturning or boom failure. Equipment damage also may occur, resulting in costly repairs and a shortened usable life for the aerial device.

A fully equipped lineworker with PPE plus tools and materials for typical line maintenance can quickly add up to 700 pounds or more for distribution work, and upward of 1,000 pounds for transmission work. Bucket capacity is identified on the ID plate and inside of the basket on most aerial devices. In addition, be aware of dual-rated buckets with different capacities based on configuration and use as a material handler; these types of buckets are available from some manufacturers. Before climbing in, lineworkers should verify that their weight – in addition to the platform liner, if used, and all of their tools and equipment – doesn’t exceed the bucket’s capacity.

“Don’t forget to account for boots, harness, tools and any components you may add to the bucket once you are elevated,” said Kyle Wiesner, aerial products engineering manager for Terex Utilities. “Tools such as phase lifters, crimpers, hydraulic drills or chain saws all add up. Weight of personal clothing can change with the weather, so don’t forget to recalculate come winter. If a component is in the bucket while work is being performed, that weight needs to be factored in as well.”

On an invigorating and beautiful late-spring Sunday afternoon, Frank decides to take his young family for a drive in his brand-new van. Frank, his wife and their two young daughters are cruising along with a scenic view of the mountains. He is enjoying this priceless quality time with his family. While listening to some good music on the radio, the van approaches a tight curve on the road. Suddenly, Frank notices a large wooden utility pole ahead that is carrying lots of wire and leaning excessively toward the road. Frank jams on the brakes, but he cannot stop in time. He hits the pole, and the impact splits the pole and damages the van. All wires are hanging low, but they’re not touching the van or the ground. Frank parks on the side of the road and then checks on his family. Thankfully no one is hurt. However, Frank gets a headache just thinking about the deductible he is going to have to pay his car insurance company to fix the vehicle.

Later, police and emergency personnel arrive on the scene. Frank’s family is taken to the nearby hospital for checkups. Everyone is OK. The police summon the local electric utility to the accident site. The utility responds immediately and assigns the emergency to Bob’s crew. Bob is a foreman with many years of experience; he is known to be tough and demanding yet compassionate. Over the years, his co-workers have nicknamed him “By-the-Book Bob” and “S&P Boss” – “S&P” standing for “safety and productivity.”

Bob assembles his crew and instructs them on the situation. He then reminds them of his basic “CSS” rule that applies while any utility employee is behind the wheel. The three components of the rule are as follows:

• Cellphone use is banned while driving.
• Seat belts must be worn when the engine is running.
• Speed limits must be obeyed.

Outdoor workers – including lineworkers and communications technicians – routinely work in hazardous environments. Most of these hazards are well-recognized and understood by the workers and their management, but that is not always the case with cold-weather injuries, such as hypothermia and frostbite. Until workers receive specific and relevant training from medical professionals with cold-weather experience, they may lack the basic understanding of just how suddenly cold weather can kill.

Although there are numerous types of cold-weather injuries, this article will address the most common one: hypothermia, or the human body’s attempt to manage a drop in its core temperature. The core includes the brain, heart, lungs and neck. When managing body core temperatures, keep in mind that more blood flows closer to the skin in the neck than anywhere else in the human body.

Any drop in the temperature of the core blood will trigger a response from the hypothalamus in the brain, which is responsible for all body thermoregulation. The hypothalamus has three separate and unique methods that it will use, in sequence, to respond to a lowered core temperature, referred to as stage 1, stage 2 and stage 3. Failure to recognize the differences between the stages can immediately be fatal to a hypothermia victim.

The Three Stages
Stage 1 hypothermia occurs when the body’s core blood temperature first drops. The hypothalamus initiates two major responses to this temperature drop, only one of which the victim is aware. The first response is the hypothalamus triggering the major muscle groups – those in the arms, legs and face – to shiver. This is mild at first but then progresses to severe and uncontrollable shivering. The second response, which the victim is unaware of, is the brain triggering the release of larger quantities of sugars and insulin into the bloodstream. This is necessary to support the hard muscular work involved in shivering.

The utility industry has high expectations for employing safe work practices and readily invests in equipment and training. Maintaining a workforce with the right skills is a herculean task. Crane operation and rigging skills development presents greater challenges than some other areas because these skill sets typically are not part of the routine work schedule. Individuals with crane operator certification may have fewer than 100 hours of actual operating time in a year, or go more than a year with no seat time or hands-on practice time.

OSHA requires employers to ensure that crane operators are trained and competent without exclusion for any industry. Even while safe crane operation and rigging are critical to utilities, the lack of seat time and skills maintenance is a growing concern among utility safety departments. A strategic approach to developing those skills across business units is essential to maintaining the industry’s above-average safety record.

However, utilities, like most large, complex organizations, battle the 5 C’s: complex corporate culture causing complications. Different groups within the utility may, out of necessity or for other reasons, operate as silos, with little shared knowledge or resources. Construction groups, T&D and emergency response crews have different needs when it comes to crane operation skill levels. The differences between operating boom trucks or digger derricks and large telescopic or lattice boom cranes must be recognized when training individuals for typical or emergency response work environments. Yet the reality of maintaining skill levels may require staff and budget that conflict on the surface with corporate cultures that thrive on efficiencies.

To maintain qualifications in the various areas of responsibilities, utilities need to plan for and schedule practice time with cranes and rigging to reinforce and verify skill ability. Relying on a weeklong refresher training course once every five years is not sufficient for retaining competent crane operation skills.

Q: We have gotten mixed advice from our colleagues at other utilities and can’t decide whether or not civil workers digging a foundation by hand in a hot substation should be required to wear arc protective clothing. They are inside the fence but in a new area approximately 20 feet from the nearest distribution structure. Where do we find the requirements or OSHA guidance?

A: That depends. Sometimes it depends on the criteria in the statutes, and sometimes it depends on compliance with company policy. Normally, following the guidelines of OSHA 29 CFR 1910.269(l)(8) – which establish the criteria for arc flash protection – excavation in a substation would not produce the type of work exposure you described that could create an arc flash. The location of the work and the type of work would not bring a worker within any distance of an energized bus or apparatus that would be a threat. If that’s the case, there would not be a requirement for arc-rated clothing for civil workers in a substation.

We are aware that there are utilities that require all workers, no matter what their craft or task is, to wear arc flash protective shirts while in a substation because it’s a company policy. But in regard to your question, it’s all about exposure. No exposure, no requirement for shirts. It is obvious that it’s not quite that simple for policymakers and risk analysts, who often are the people who make these decisions. Utilities must decide how to protect employees, protect the company and comply with the standards. That goal sometimes results in a blanket requirement as opposed to writing detailed criteria for when workers must suit up. The rules held by some utilities raise this question: If workers must wear arc-rated shirts, why don’t they have to wear arc-rated face protection? In fact, most of the inquiries we’ve made would seem to indicate the decision to require arc protective clothing in substations is more about gut response to the spirit of arc flash protection for contractors and employees than the result of arc flash analysis. Processes and knowledge are still expanding in the industry. As most would say, it doesn’t hurt for civil workers to wear arc protective shirts unless there is an unacceptable heat stress factor involved. In fact, there are some pretty lightweight pullover tees in Cat 2 that may help relieve both arc flash and heat stress.

In the electric utility business, we have highly trained employees who are proud that they have learned the skills to be able to safely work around high voltage. However, a phrase we hear too often is “Hey, it’s only secondary,” which implies that secondary is not as hazardous as primary, lightning or fault current. We’re not going to debate that in this article, but we are going to discuss – and bust – some common myths about working with 120-volt circuitry and equipment, as well as myths regarding lightning and fault current exposure.

Myth 1: Circuit breakers are better than fuses.
If you utter this statement and are merely talking about convenience, you may have a cogent argument, but convenience does not outweigh safety. If you are merely talking about cost, you may again have a cogent argument, but the cost argument doesn’t win when it comes to safety because how do you put a price on a human life?

So, why might a fuse be better than a circuit breaker? All fuse manufacturer representatives will assure you that fuses in general operate faster than breakers. They may operate in less than a quarter of a cycle compared to three to four cycles for many circuit breakers. If you are in series or parallel with fault current flow, you literally are being cooked from the inside out. Reducing the amount of time the circuit is allowed to operate is a better protection strategy than allowing current flow to go on longer. Additionally, fuses typically are better at interrupting an avalanche of fault current from an incoming service. Breakers and fuses have maximum amp interruption capacity ratings, meaning if a breaker or fuse is installed on a circuit with a higher fault current capability than the breaker, the breaker or fuse can simply melt or arc across and fail to operate. The least-protective fuse interrupts 10,000 amperes of incoming energy, while a typical branch circuit breaker interrupts 5,000 amperes.

Myth 2: If you turn on a light switch with wet hands, you will get electrocuted.
While there is a possibility you might get electrocuted, you probably will not. That’s not to say you won’t get shocked; you must understand the difference between shock and electrocution. A shock occurs anytime current flows through your body, via any path, for any duration and at any magnitude. Electrocution is a shock that kills you by interfering with bodily processes. It only takes as little as 50 milliamps to send an adult heart into ventricular fibrillation; death is imminent within four to six minutes of ventricular fibrillation.

Another definition also is useful here: Fault current is current flowing anywhere you don’t want it to flow, especially through you. Fault current can flow in parallel or in series with normal current flow, or with the load. You don’t want to be in the path of fault current. Fortunately, the likelihood of being in a fault current path while operating a modern plastic switch, even with wet hands, is very low. Even lower is the likelihood of electrocution from the event.

Ergonomic safety has had a profound impact on the utility industry over the last decade, without many workers even knowing it. Yet as professional tool ergonomists, we have seen many erroneous “ergonomic” product claims over the years, so in this article we want to highlight the importance of knowing how ergonomic products are measured and if the tools you’re using are truly advancing ergonomics at your company.

Before we dive into the technical aspects of ergonomic measurements, let’s review some background information. OSHA continues to define line work as a high-risk occupation in terms of the risks of electrocution, falls and human error, but also in terms of risks for musculoskeletal disorders and ergonomic injuries. The agency has gone so far as to say that one in three injuries is an ergonomic injury. Examples of these injuries include carpal tunnel syndrome, rotator cuff tendinitis, elbow epicondylitis (tennis elbow) and trigger finger tendinitis.

These injuries translate into an incredible number of dollars spent by employers. According to the 2017 Liberty Mutual Workplace Safety Index, U.S. businesses spend more than a billion dollars a week on serious, nonfatal workplace injuries. Of the billion dollars a week, over 20 percent of the injuries – which account for nearly $14 billion a year – are directly attributed to overexertion involving outside sources.

Objectively Measuring Ergonomics
Based on the information presented above, it’s clear that quality workplace ergonomics are good for both employee health and an employer’s bottom line. But while almost every tool manufacturer talks about ergonomics, are their claims about ergonomics true or just a marketing stunt? It’s important to understand how a company tests their products prior to purchasing them. The truth is that some tool manufacturers have not measured ergonomics at all, some outsource the measurement process and some do partial measurements but don’t perform the complete process. At Milwaukee Tool, not only do we conduct measurements in-house, but we also have teams of subject matter experts who implement ergonomic designs into the tools utilities use every day.

Objectively measuring ergonomics is a very precise task. Some ergonomic risk factors to look for in your tools are high levels of noise, vibration and required force. While some exposure to these risk factors isn’t necessarily hazardous, exposure to high thresholds of these categories puts workers at serious risk for eardrum damage, vibration-induced white fingers, trigger finger tendinitis and carpal tunnel syndrome, among others. 

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.

Q: We are a contractor and were recently working in a manhole with live primary cables running through it. We were cited in an audit by a client’s safety team for not having our people in the manhole tied off to rescue lines. We had a tripod up and a winch ready for the three workers inside. What did we miss?

A: This question has come up occasionally, and it’s usually a matter of misunderstanding the OSHA regulations. The latest revision of the rule has modified the language, but following is the relevant regulation. Look for the phrases “safe work practices,” “safe rescue” and “enclosed space.”

1910.269(e)(1)
Safe work practices. The employer shall ensure the use of safe work practices for entry into, and work in, enclosed spaces and for rescue of employees from such spaces.

1910.269(e)(2)
Training. Each employee who enters an enclosed space or who serves as an attendant shall be trained in the hazards of enclosed-space entry, in enclosed-space entry procedures, and in enclosed-space rescue procedures.

1910.269(e)(3)
Rescue equipment. Employers shall provide equipment to ensure the prompt and safe rescue of employees from the enclosed space.

This rule deals with enclosed spaces, not other spaces referenced in 29 CFR 1910.269(t), “Underground electrical installations.” Enclosed spaces are not, as many think, spaces with energized cables inside. In fact, the definition of an enclosed space has no mention of energized cables. What it does have is the single criterion for an enclosed space: Under normal conditions, it does not contain a hazardous atmosphere, but it may contain a hazardous atmosphere under abnormal conditions.

Electric utility workers face complex, high-risk electrical hazards nearly every day. Information about shock hazards – which may come from impressed voltage, residual energy, induction, objectionable current flow in a grounding system or stored energy – has been taught to many of us for quite some time, as have the methods of assessing them.

On the other hand, arc flash hazard assessments are still relatively new to us. In the past, most of us knew that an arc flash could potentially occur during the course of performing our tasks, but the level of the flash and the PPE requirements – other than wearing 100 percent cotton – were not seriously considered in our day-to-day activities until approximately 15 to 20 years ago. To provide more concrete guidelines, OSHA published new regulations in April 2014, with more recent enforcement dates. Instead of making a best guess about PPE, the industry now has a reasonable approach to providing adequate PPE for utility employees who are tasked with performing open-air work. Once a utility completes the required arc flash analysis, develops a policy based on the analysis results and adequately conducts training for affected field personnel, the job of assessing risk and determining PPE levels can easily be incorporated into the daily job briefing. The goal is to make the assessment data easy to access and understand in order to provide effective protection for all workers.

Causes and Severity Levels of Arc Flash Events
An arc flash is the result of either a short circuit during which two energized parts of different potentials (phases) make contact, or a ground fault where an energized part and a grounded conductive part of a different potential make contact. An arc flash event may be caused by a failure of electrical apparatus, potentially due to lack of maintenance, or by worker error, perhaps due to an employee moving conductive parts near energized parts or leaving conductive tools in an energized work area. It’s important to note that differences in potential must always be effectively isolated by distance (air) or insulated barriers.

The growth of the wind energy generation industry in the U.S. has been phenomenal. According to the American Wind Energy Association, at the end of 2016 there were over 52,000 utility-grade wind turbines operational in more than 40 states, with a total capacity of 83,000 megawatts. The Global Wind Energy Council’s latest report shows that the U.S. has the second-largest wind power capacity, after China, with 16.9 percent of the world total, and employs over 100,000 people directly or indirectly. As the number of wind turbine towers grows, so does the number of people involved in their maintenance and repair. In 2015, the U.S. Bureau of Labor Statistics projected that employment of wind turbine service technicians would grow 108 percent between 2014 and 2024. There were approximately 4,400 wind turbine service technician jobs as of 2014.

Wind turbine tower heights also are increasing, with the tallest tower currently in the U.S. measuring 379 feet hub height, and even taller towers have been installed elsewhere in the world. While some towers are outfitted with service lifts, in the majority of towers personnel must climb fixed ladders to perform both routine and unusual operations. The increasing numbers and heights of towers mean more workers climbing ever greater distances.

Research studies conducted at the University of Wisconsin-Milwaukee (UWM) that have specifically investigated the renewable energy sector, including wind power generation, along with data from OSHA and the Bureau of Labor Statistics, have identified multiple risks to workers as a result of climbing fixed ladders. Strains and sprains, falls, overexertion and even fatalities were reported to be possible direct consequences of climbing and working at heights during both the construction and maintenance of wind turbines. Indirect risks also were identified, including potentially being electrocuted from contact with high-voltage cables and being struck by an object or caught between objects. Although power generation injury statistics are not separated by fuel source, 2015 Bureau of Labor Statistics’ data indicates that there were three fatal falls in the power generation industry, and 550 falls with nonfatal injuries. Data from the United Kingdom shows 163 total accidents in the wind power industry in 2016, including five fatal accidents. This data generally is assumed to vastly underreport the actual numbers, which may be 10 times higher.