Utility Worksite Safety Articles

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.

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?

The revised OSHA 29 CFR 1910.269 standard has now been in place for three years. In making the revisions, OSHA replaced older, passive language that left much to be understood with more objective language that clarifies the meaning and intent of the regulation. The standard is now easier to understand and sets the expectations for employers and employees.

There were some major changes made to the standard, as we all know. Several more subtle changes also were included and have been discussed much less, but they still have had a significant impact on the regulation. In this installment of “Voice of Experience,” I want to focus on one of these more subtle changes that I believe has a tremendous effect on the training requirements found in 1910.269(a)(2). The 1910.269 standard published in 1994 was straightforward, describing what was required in order for an employer to determine that an employee was a qualified worker. By and large, the industry believed that if an employee had the required training, he or she could be determined to be qualified. Now, per paragraph 1910.269(a)(2) of the revised 2014 standard, all employees performing work covered by the section shall be trained as follows:
• Each employee shall be trained in, and familiar with, the safety-related work practices, safety procedures, and other safety requirements in this section that pertain to his or her job assignments. (1910.269(a)(2)(i)(A))
• Each employee shall also be trained in and familiar with any other safety practices, including applicable emergency procedures (such as pole-top and manhole rescue), that are not specifically addressed by this section but that are related to his or her work and are necessary for his or her safety. (1910.269(a)(2)(i)(B))
• The degree of training shall be determined by the risk to the employee for the hazard involved. (1910.269(a)(2)(i)(C))

Q: We have a group reviewing our personal protective grounding procedures, and they are asking if we should be grinding the galvanized coating off towers when we install the phase grounding connections. What are your thoughts?

A: In addition to your question, we also recently received another question about connecting to steel for bonding, so we’ll address both questions in this installment of the Q&A. Your question is about the effectiveness of grounding to towers, and the other question is about the effectiveness of EPZs created on steel towers. We’ll discuss the grounding question first and then move on to the EPZ question.

As to grounding effectiveness, we have two thoughts here – one simple and one that likely will raise more questions than we can resolve in these pages.

The simple thought is this: Consider grounding to the circuit static. It’s difficult to reach but doing so makes it easier to create an electrical connection. Using the system static shares current with adjacent structures and reduces current on the structure being worked. Dividing current among adjacent structures also reduces ground potential’s risks to workers at the foot of the tower. See the following Q&A regarding EPZ if you are grounding to the static.

As to connecting to the tower, grinding off the galvanized coating opens the underlying steel to corrosion and would need to be replaced after the operation. We have asked how utilities make connections and found that most use a flat clamp to a brushed plate or insulator bracket, or a C-clamp to a brushed bolt or step. Either method is a good one. Others follow one of the recommendations in IEEE 1048, “IEEE Guide for Protective Grounding of Power Lines,” 9.2.1.1 for lattice using a ground cluster. The cluster serves two purposes: providing a clamping connection and keeping the clamps close together.

Fortunately, the structure connection can be installed by hand, making the cleaning and mechanical security of the connection pretty reliable. There are several considerations to discuss that should be part of the training provided to lineworkers who make these connections.

Entering and working in confined spaces is serious business. In the years I’ve been a safety professional, I’ve been involved with several hundred confined space entries, including overseeing entries into most of the confined space examples listed in the scope of OSHA’s “Confined Spaces in Construction” standard. A number of times I’ve been called to the scene of a confined space entry where the entrants had been evacuated because of alarms from direct-reading portable gas monitors. Some of these alarms were caused by degradation of atmospheric conditions, while others were due to operator error. Thankfully, I’ve never been called to a scene involving a worker who was down and overcome in a confined space, but I must admit that where confined space entries are involved, such a situation is my worst nightmare.

Over the last few decades, part of my work also has included training hundreds of workers in confined space entry. Typically training covers two major components: teaching trainees the regulatory requirements of the standard for confined space entry, and training them about their employer’s specific processes and procedures for conducting confined space entries in compliance with the standard. However, as Jarred O’Dell, CSP, CUSP, noted in his February 2016 Incident Prevention article, “Trenching by the Numbers” (see http://incident-prevention.com/ip-articles/trenching-by-the-numbers), “This is a great approach but perhaps an incomplete one. Truly impactful safety training typically includes a third component: sharing of personal experience.” In this article, I want to share some of my personal experiences and goals as they relate to training workers on the topic of confined space entry, with the hope that I can offer some useful takeaways to other trainers and utility safety professionals.

A Major Motivator
I’ve always been passionate about teaching confined space entry, and my major motivator is this: If workers aren’t properly trained to enter confined spaces, they might not be able to go home at some point. I end every training session I conduct, regardless of the topic or skill level of those I’m training, by explaining to the trainees that the most important thing they will do each and every day is to safely go home to their families, their friends, their plans, their dreams – their lives.

I want my trainees to know that the reason we have confined space procedures, training, permits, direct-reading portable gas monitors and non-entry rescue equipment is because people can die in confined spaces. I also want them to know that many people who have died in confined spaces weren’t even the entrants. Nearly half of those who have died in a confined space situation were would-be rescuers. I want my trainees to care enough about safely going home at the end of the day that they will perform the necessary confined-space tasks correctly the first time, based on the training they have received, because I’ve found a way to make this training important to them on a personal level.

It takes a wide variety of activities – some obvious and others not so obvious – to keep electric utility operations humming along. With maintenance facilities and power plants in particular, there are sometimes unidentified exposures that grow as the facilities grow. In other scenarios, our understanding of exposures or emerging regulations requires the need for a professional hygienist to assess and remediate exposures. Ventilation surveys, which can detect ventilation system failures, are a critical but often overlooked tool that should be used to maintain safe, healthy operations, whether those are power generation operations, transmission and distribution operations, or peaker operations during which power is produced during periods of peak usage. All of these operations require appropriate ventilation to control atmospheric hazards. Failure to recognize the importance of maintaining and periodically checking ventilation systems may impart substantial hidden risk to personnel, facilities and operations.

However, it is not uncommon to see operations that lack the needed systems; are serviced by jury-rigged systems that do not meet operational needs; or are serviced by well-engineered systems that over time have fallen into disrepair due to a lack of ventilation surveys and preventive maintenance.

How is it that these matters fall between the cracks?

It is easy for occupational health to take a back seat to occupational safety or other priorities. Poor change management can be blamed if a new system is installed and there is either no follow-up or incomplete follow-up for hazard control concerns. A simple lack of subject matter expertise within an organization could be the problem; perhaps there is no knowledgeable industrial hygienist on staff and an overwhelmed safety professional wearing multiple hats gravitates away from his area of lesser expertise. In some cases, chemical exposures take years to become evident and manifest symptoms. As such, they are a lower priority than more high-visibility issues, like falls from height or arc flash. Or, it may be that ancillary activities are out of sight and out of mind, and not recognized as a priority for hazard control.

Regardless of the reason, occupational health and safety cannot be maintained without appropriate attention to ventilation matters. The purpose of this article is to shine a light on these matters and encourage organizations lacking the needed expertise to learn to handle them appropriately.

Clear minds, focused on the task at hand. Strict attention to details and checklists critical to the job. Precise and continual communication among the field, management and control teams. Ongoing training and safety manual review. Looking out for one another. Trust in the workforce’s skills with no micromanagement and with the boss’ door always open.

Such are the written – and unwritten – rules governing the field forces of Silicon Valley Power, the City of Santa Clara, Calif.’s municipal electric utility that recently marked a company milestone: 1,000 days without a lost day of work due to injury or work-related illness.

SVP serves 54,000 customers, including technology industry giants such as Intel, Owens Corning, NVIDIA, Texas Instruments and Applied Materials, and high-profile customers such as the San Francisco 49ers and Levi’s Stadium. Local generation resources include a 147-megawatt combined cycle natural gas plant, landfill methane gas and 20 megawatts of solar installations. Over 692 megawatts of renewable energy are imported from hydro, wind and geothermal partnerships and power purchase agreements; total renewables represent over 40 percent of the company’s power mix.

Health and Safety Success
SVP’s managers firmly believe that the company’s health and safety success begins with a multitude of safety briefings. These include weekly management conferences, mandatory shift start meetings and tailboarding before every job, regardless of scope.

And once the job begins, urgency is effectively tempered by caution. If safety may be jeopardized, there is never any pressure from the city or SVP management to hurry a job or push to restore power during an outage. Safety is first whether it’s in a project planning stage or when responding to an outage. Customer communications during an outage, including social media postings, stress that SVP will restore power as fast as its field force can safely do so.

For more than 100 years, Commonwealth Edison – commonly known as ComEd – has been powering the lives of customers across Northern Illinois, including those in Chicago, a city that has thousands of circuit miles of medium-voltage distribution cables installed in conduit and manhole systems.

Over the decades, ComEd’s underground cable splicers have experienced failures of distribution cable system components, including cables, joints and terminations, while employees were working in manholes and vaults. A large number of cable system failures occurred at cable joints in underground manholes. Some of these failures were due to degradation of the electrical connection inside these joints.

One of the hazards associated with a cable system failure is the risk of employee exposure to an electrical arc flash. This type of event can result in temperatures in excess of 35,000 degrees Fahrenheit, producing a blinding flash and causing aluminum and copper cabling components to instantly expand. If an employee is working adjacent to equipment affected by the blast, the heat generated can cause third-degree burns, and the pressure wave can damage hearing and throw the worker into the surrounding structure.

A Culture of Safety
Past experience at ComEd has demonstrated that thermal issues with joints are centered on mechanical connections, typically those that are crimped. Such mechanical connections are used in pre-manufactured joints.

According to OSHA 29 CFR 1910.269(t)(7)(i), “hot localized surface temperatures of cables or joints” are an abnormality that may be indicative of an impending fault. Unless the employer can demonstrate that the conditions could not lead to a fault, “the employer shall deenergize the cable with the abnormality before any employee may work in the manhole or vault, except when service-load conditions and a lack of feasible alternatives require that the cable remain energized.” However, “employees may enter the manhole or vault provided the employer protects them from the possible effects of a failure using shields or other devices that are capable of containing the adverse effects of a fault.”

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.

Q: Our plant safety committee has a longtime rule requiring electrical hazard safety shoes for our electricians. We were recently told by an auditor that we have to pay for those shoes if we require employees to wear them. We found the OSHA rule requiring payment, but now we wonder if we are really required to use the shoes. Can you help us figure it out?

A: Sure, we can help. But first, please note that Incident Prevention and the consultants who have reviewed this Q&A are not criticizing a rule or recommending a rule change for any employer. What we do in these pages is explain background, intent and compliance issues for workers and employers in the workplace.

You mentioned a longtime rule that probably dates back to the early OSHA rules that required electrical hazard boots for electricians. We can’t remember exactly when, but there was a letter to administrators in the early 1990s and subsequent rule-making that changed the language on the use of electrical hazard shoes. Your auditor is right; if you require employees to wear them, you are required to pay for them because unlike regular safety shoes, the electrical hazard criterion makes the safety shoe a specialty shoe. Specialty shoes must be provided at no cost to the employee (see www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=29825).

Now let’s address the question, are the shoes required? Employers are required to perform a workplace hazard assessment and then use engineering or procedural controls to eliminate hazards. If a hazard cannot be eliminated by procedures or engineering, PPE is required. OSHA agrees throughout current literature that electrical hazard shoes are to be employed as part of a system of protection based on the hierarchy of controls. If you read the rule closely, you will see that the language is very particular. OSHA 29 CFR 1910.136(a) – edited here for clarity and space – states that the “employer shall ensure that each affected employee uses protective footwear … when the use of protective footwear will protect the affected employee from an electrical hazard, such as … electric-shock hazard, that remains after the employer takes other necessary protective measures.” Those other measures are the hierarchy first, PPE last.

A fundamental premise of working safely is that hazards must be identified and then controlled. Too many incidents occur because hazards are not identified, or worse, they are identified but ignored or tolerated.

One of my favorite ways to introduce the concept of risk tolerance is to ask a Frontline class this simple question: “What are some things you might hear someone say before something really bad happens?” It always amazes me – and scares me – how open participants are when I ask this question. Typical responses I have heard include:
• “We’ve done this a thousand times and no one has ever gotten hurt.”
• “We’ve always done it this way.”
• “This is going to hurt.”
• “If this works, we’ll be heroes.”
• “I think it will hold.”
• “I can survive anything for two minutes.”
• “What’s the worst that could happen?”
• “Here goes nothing.”

That list could go on for a long time, and it gives us a lot of insight into how we think about hazards and risk. In fact, I want to be sure to mention one incredibly memorable response not listed above that led to some great discussion about risk tolerance: “Hold my beer and watch this.”

Take a moment to remember if you have ever made that statement or heard someone else make it. What followed? I have heard stories involving “testing” an underground dog fence, in which someone held the shock collar in his hand and ran through the fence; jumping off a roof into a swimming pool; attempting to bench-press 400 pounds; boxing a kangaroo; and a myriad of other superhuman feats fueled by alcohol. Oddly enough, sober people do not think it is cool or that it will impress someone if they, for instance, eat a spoonful of cinnamon.

When the earliest linemen first began to ground lines for worker protection, they attached a small chain – known as a ground chain – to the conductors, with the end dropped to the ground. When I began to work on a line crew, I’m sad to say that my grounding practices weren’t much better than those used in the early days. I wish someone had better explained to me then the situations that could arise, the ways grounding could protect me and the best methods to accomplish it. So, in an effort to help out other lineworkers in the electric utility industry, I want to share in the following pages some of the important aspects of grounding that I’ve learned throughout my career.

Worker Protection
Ever since enforcement of 29 CFR 1910.269 began in 1994, OSHA has required grounding practices that will protect employees in the event that the line or equipment on which they are working becomes re-energized. The equipotential zone, or EPZ, is made to do just that.

If you read paragraph 1910.269(n)(3), the preamble discussion and Appendix C to 1910.269, titled “Protection From Hazardous Differences in Electric Potential,” OSHA’s intent seems clear. To summarize, install temporary grounds and bonds at the worksite in such a manner that keeps the worksite at the same potential and prevents harm to workers even if the line is accidentally re-energized or exposed to induced voltages. You can follow Appendix C as a one-size-fits-all approach or perform your own engineering analysis to create procedures. But keep in mind that if you create your own procedures, you must be able to demonstrate they will protect your workers.