Utility Worksite Safety Articles

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.

“I don’t know what I did to cause this injury, Doc. I’ve had lower back pain on and off for the past five years, but it’s never been like this before. All I did was reach under the boom for a roll of cable on the truck when I felt something give in my back and then felt shooting pain down both legs. What the heck happened?”

This is not an unusual story. When I used to practice as a chiropractic orthopedist, I heard similar accounts on a daily basis. Lower back pain affects utility workers in epidemic proportions. In 2004, my company surveyed 224 employees of a public electric utility, and the results revealed that more than one of every five lineworkers reported living with moderate to severe lower back pain on a weekly or daily basis. There are valid reasons why most lineworkers believe that lower back pain is just a consequence of the work they do, but the good news is that it doesn’t have to be that way.

The Mechanics of Back Pain
Most lower back pain is mechanical in nature, meaning it does not come from cancers, other diseases or infections. But it doesn’t necessarily come from performing physical work either. All physical work causes some daily microscopic wear and tear of your body, and the more a job requires you to do physically, the more wear and tear will occur. Before you start looking for another job, however, remember that your body is fully capable of repairing the vast majority of the wear and tear that occurs from demanding physical work. The painful conditions that most lineworkers experience in their careers occur because the balance between the amount of damage done each day and the repair that occurs each day gets thrown out of whack. How you position and move your body as you perform work dramatically affects how much wear and tear you sustain each day. Habitually working with stressful techniques can cause more microscopic damage on a daily basis than your body is capable of repairing. If it is not repaired, this microscopic damage accumulates over time and eventually causes painful conditions. “Cumulative trauma” is the name given to this slow accumulation of microscopic damage. As cumulative trauma increases over the years, the end results commonly are painful conditions, serious injuries and degenerative arthritis.

When designing your PPE program, how do you know which option will work best for your application? How can you get the most for your money? How can you get no-cheating compliance from your workers? With so many arc-rated (AR) and flame-resistant (FR) PPE products on the market, it can be difficult for a utility or utility contractor to make a sound decision. To start, complete an analysis to determine hazard levels, as well as the workers who will be exposed. Application, comfort and cost should be considered when deciding on the best product to purchase. In this article, we will help you see how to maximize your AR and FR gear. The process begins with making a choice that makes sense for your company and your application, and then you will need to know how to care for the PPE so you can get the most from your money and extend the equipment’s lifespan.

Application and Comfort
While there have long been arguments and marketing claims about the superiority of either treated or inherent fibers used for FR and AR clothing, the truth is that both can work well from a protection standpoint, and both have a place in the market. Determining which one to use depends on the application and properties the end user needs.

For instance, aramids are durable and can work well with exposure to certain acids and bases – as an example, para-aramid is sensitive to chlorine bleach, mineral acids and UV, but these do not affect its flame resistance – yet pure aramids do not work well with regard to molten metal hazards because molten metal sticks to the fabric. However, there are several aramid blends that work well with molten metal. Modacrylics are great for chemical resistance, but the fiber has a high amount of shrinkage in a thermal exposure and doesn’t pass some of the small-scale tests for flash fire unless blended. Cottons and a similar, regenerated cellulose FR fiber known as FR rayon are breathable, soft and relatively inexpensive, yet they do not perform well in acid exposures. They also have fair colorfastness, meaning that their colors can fade with exposure to light and laundering.

OSHA’s final rule on 29 CFR 1910 Subpart D, “Walking-Working Surfaces,” is finally here. It’s 26 pages of nine-point font equaling 21,675 words, and I read them all. It’s big, and if you include the preamble in your analysis, it is also complicated. It was just as hard to write about as it was to read. I guess that shouldn’t be unexpected for a final rule that has been in the works since 1983. The original 1910 Subpart D was published in 1971. The first update was proposed in 1983, but it was never ratified. Proposals were again considered in either the Construction standard or the General Industry standard in 1990, 1994 and 2003. This edition of the final rule for 1910 Subpart D covers it all. OSHA should be congratulated for bringing almost all of the fall-related standards into one location, making it easier for the employer to find rules related to working surfaces under one subpart instead of having to search for those rules that may affect the employer’s workplace. This may be news to some novice safety professionals in the utility industry, but not all regulations affecting us are restricted to 1910.269 or 1926 Subpart V. Subpart D applies, so it is important to be familiar with it.

What’s New?
Preventing falls is almost the entire purpose of rules for walking-working surfaces. The surfaces are not always those spaces of aisles between walls. Most walking or working spaces in the workplace are not defined aisles; they are more likely to be incidental spaces about the work area. It is quite easy for those incidental spaces to be encumbered by tools, materials and process waste that create stumbling or tripping hazards. In addition, many of those working spaces are raised surfaces, from the tops of foundations to the tops of skyscrapers. That being the case, OSHA has brought into Subpart D the body of fall protection standards. You will now find a greatly expanded section on ladders; step bolts (towers) and manhole steps; scaffolds and rope descent systems (building maintenance); the duty to have fall protection; new and expanded requirements on fall protection equipment design; and some expanded language on the training of employees to recognize and prevent falls in the workplace.

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

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

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

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

Q: We are a small, distribution-only municipal utility that has been looking into human performance. We are having some trouble understanding it all and how it could benefit us. Most of the training resources are pretty expensive. Can you help us sort it out?

A: We can. Human performance management (HPM) has been around in various forms and focuses since before the 1950s. Throughout the ’50s and ’60s, it seems the focus was on companies performing functional analysis and correcting issues that created losses, thereby promoting more efficient and error-resistant operations. In the ’60s and ’70s, much of the literature on HPM seemed to surround the nuclear power industry, and indeed the introduction of HPM into the transmission/distribution side of the utility industry appears to have come through the generation side. In the ’70s, researchers began to experiment and write about more closely analyzing the knowledge and skills of the performer. It took a while to sink in, but the safety industry began to research HPM as a culture analysis and risk prevention tool. It makes sense. Human performance – in particular knowledge, skills modes, decision-making modes and performance – affects all of every enterprise whether you have an HPM program or not. Organizations are made of people. HPM has identified and categorized commonalities in types of personalities that predict how people make decisions and perform tasks. Studying human performance also can help identify safety culture issues and risk behaviors. It’s not a big or expensive step to train your workforce on problem-solving and decision-making characteristics of the human mind. Soon they will understand their own processes and the limitations of the way they naturally think, allowing them to make adjustments toward better performance. So if we can take advantage of HPM to prevent incidents, why not do it? Most organizations start small. Pick a few key people to begin training on the basics of HPM, and then look at your organization to see where the initial undertakings can do the most good. There are several experts associated with Incident Prevention who will be glad to help should you need it. Additionally, on the iP website (www.incident-prevention.com) you can find numerous HPM articles in the iP archives as well as information and training sessions from past iP Utility Safety Conferences. HPM works. We hope you will pursue it.

The National Electrical Safety Code is a referenced standard to OSHA 29 CFR 1910.269. A referenced standard means it is a voluntary consensus standard that OSHA recognizes as a means to help the employer meet the requirements of the OSHA rules. OSHA will not cite an employer on the basis of an NESC provision, but the agency may use the NESC as evidence the employer knew a hazard existed and may have been prevented using the provisions of the NESC.

The 2017 edition of the NESC was released earlier this year. It has been reorganized for easier use and includes a number of changes and exceptions to rules, as well as the introduction of some new, useful tools to help users more easily access and utilize NESC content. The latest edition follows a tradition to ensure the continued practical safeguarding of persons and utility facilities during the installation, operation and maintenance of electric supply and communication facilities. NESC Part 4 is the pertinent section for lineworker safety, and it has been revised fairly extensively. The following summary of the changes can be a useful guide for those directly impacted in their daily work.

Arc Hazards
NESC Part 4 rules include a section on arc hazards that was updated in the 2012 edition. At that time, a new low-voltage arc flash table was added that coincides with the rules in the code related to arc hazard analysis. This table has been further modified in the 2017 edition of the NESC. The table, numbered 410-1, is based on recent industry testing performed with the Electric Power Research Institute and Pacific Gas and Electric Co., and now includes more detailed information, primarily on 480-volt arcs.

Revisions have also been made to Rule 410A3 to help ensure that employers perform an assessment to determine the potential exposure to electric arcs for their employees when they go to work on energized lines or equipment. This rule is used to help determine the flame-resistant and other types of personal protective equipment that is necessary. Exception 4 has been added to the rule to help employers and employees understand when protection is needed for the head and face.

When utility employees travel to remote backcountry job sites, things can turn bad quickly if they are not prepared to deal with hazards. And a bad situation can become exponentially worse during the winter months, when over-the-snow travel may be involved and additional factors – such as limited or failed communications, difficult terrain, winter storms, avalanche hazards and the potential for cold weather injuries – can potentially wreak havoc.

If employees are to understand how to safely handle these types of emergency situations, employers must diligently train and equip employees well before they travel to a backcountry site. For starters, all workers must be taught how to identify a survival situation. If a problem arises on a job site, lone employees or small crews with limited resources on hand should be trained to notify their operations centers to advise them of the problem, regardless of whether or not the employees believe they can overcome the issue on their own. This is a critical step that is often overlooked. Many times workers believe that walking back to the highway vehicle is the best option if they become stranded in the backcountry due to an equipment failure or operator error. This is almost always the worst thing to do, and many deaths have been attributed to such incidents. Traveling on foot in deep snow – which is incredibly difficult, if not impossible – should be the last choice, as crew trucks should have food, water and heat to last crew members several days of the worst-case conditions.

Beyond the basics of how to identify and address a survival situation, employers should also train employees about communication protocols, survival priorities, the appropriate survival tools to bring to the backcountry, and how to recognize and avoid cold weather injuries.

As a third-generation lineman in the high-voltage utility industry, I can say based on experience that the industry has changed slowly at certain times and radically at others. And yet one thing that has not changed much over the years is the process of performing live-line work on extra-high-voltage (EHV) transmission lines. It still requires the use of live-line tools; it still requires linemen to maintain minimum approach distances; it still requires that linemen possess the knowledge and ability to use tools properly depending on the application, whether it be steel or wood construction; and it still requires access to the energized end of the insulator string or conductor. For many years the method of accessing the “hot end,” as we call it, required the use of live-line-rated aerial lifts, horizontal or vertical live-line insulated ladders or, in some instances, helicopters. Each access method has its own set of intricacies that can be time consuming, labor intensive and costly, but all of the methods have the same end result when the procedure involves the bare-hand method for conducting the maintenance work. Live-line maintenance using the hot-stick method is another topic entirely, so for the purposes of this article, I am only going to address live-line bare-hand work.

Creating a New Tool
Well before OSHA’s final rule regarding 29 CFR 1910.269 and 1926 Subpart V was published in 2014, ushering in new fall protection standards, the live-line bare-hand committee within the company I work for – Tri-State Generation and Transmission, headquartered in Westminster, Colo. – began to think a great deal about providing our linemen with a new tool for performing traditional live-line work. Ongoing environmental and related job site concerns also impacted our thought process at the time. Those concerns included a lack of rights-of-way; earth disturbances caused by the need to access structures and set up aerial lift equipment; the possible need to re-vegetate earth that we disturbed during a job; lack of ability to de-energize transmission lines requiring live-line work; and the costs associated with the use of helicopters for routine live-line EHV maintenance.

The time the committee spent thinking about creating this new tool for live-line work was the beginning of developing Tri-State’s rope access and rescue program for live-line bare-hand work. Basic work methods did exist at the time, but we wanted a rope access program that provided greater training and direction and could include rescue at a level that hadn’t existed before but that we as linemen had always wanted. As time went on, we began to develop a comprehensive process for performing live-line transmission maintenance just as we had always done with ladders, trucks and helicopters, and it was – and continues to be – every bit as efficient, cost effective, rescue enabled and, most importantly, safe.

In the last installment of “Train the Trainer 101” (see http://incident-prevention.com/ip-articles/train-the-trainer-101-understanding-canine-behavior-for-the-protection-of-utility-workers), I provided information to help utility personnel understand, in part, why dogs do what they do. In particular, I addressed the pack mentality, dominant and submissive behaviors, and when and why a dog may feel threatened and try to attack. In the conclusion to this two-part article, I will explain how best to respond to unfamiliar dogs and what to do if you are attacked, as well as discuss breeds that are more commonly involved in biting incidents.

How to Respond to Unfamiliar Dogs
A dog’s response to a stranger will vary depending on whether he is with a handler or alone. When the dog is with a handler, remember what you know about the dog and human family relationship. The dog will respond to his handler’s actions as well as his own interpretation of an encounter with an unknown human. If you are the unknown human, speaking in casual tones to the handler, as well as the handler responding in a casual tone, will immediately set the dog at ease.

Workers in residential areas often are attacked by dogs who never posed a threat to people in the neighborhood. One reason behind this may be that workers focused on their task don’t exhibit the same mannerisms as visitors to the home or the people who frequent the property. This “unusual behavior” raises a dog’s suspicion and consequently his alertness level.

If you are walking toward a dog and his handler, stop a few feet away. If you are jogging or moving briskly, that may signal aggression to the dog. Stopping and allowing the handler and dog to approach you tends to reduce the dog’s alertness level.

I was recently asked to provide information about the challenges and opportunities found when working on direct-buried underground distribution (UD) systems. In light of that request, I’ll address those topics in this installment of “Voice of Experience.”

My first opportunity to work on UD systems was as a truck driver operating a trencher in the late 1960s. UD systems were fairly new at the time; lineworkers were learning new techniques, using different types of tools to terminate cables and installing switchable elbows. In that day, some elbows were non-load-break. Back then the work was all about proper use of tools, identifying equipment and following the minimum rules. There were no OSHA regulations. We learned many techniques and work practices the old-fashioned way: through the school of hard knocks.

The challenges that workers faced back then are much the same as they are today, with two exceptions: The industry has more experience installing and operating UD systems, and equipment is now much more technically sophisticated and reliable. For many years, maintenance of UD systems was nonexistent. The common approach was to dig a ditch and put cable in the ground, and industry workers believed everything would last forever. That belief was short-lived; within a few years, external concentric neutrals began oxidizing, and radial and loop-fed systems suddenly became single-conductor, earthen-ground return systems. Driven ground rods at transformers split coil for secondary voltages. There was no neutral conductor for return currents or fault current flow.

Q: We hear lots of opinions on whether a lineworker can lift a hot-line clamp that has a load on it. There is a rule that says disconnects must be rated for the load they are to break. We’ve been doing it forever. Are we breaking an OSHA rule or not?

A: Incident Prevention has answered this question before, but it won’t hurt to revisit it and use the opportunity to explain how OSHA analyzes a scenario to see if it’s a violation. Most objections to operating a hot-line clamp (HLC) under load are based on OSHA 29 CFR 1910.269(l)(12)(i), which states that the “employer shall ensure that devices used by employees to open circuits under load conditions are designed to interrupt the current involved.” There are some utilities that prohibit operating HLCs energized, and there’s nothing wrong with that. Our purpose at iP is not to judge an employer’s operational rules but to enlighten and educate the industry.

On its face, the rule seems to prohibit use of an HLC to break load. Anybody could also argue, then, that any operation of an HLC must be dead-break since HLC manufacturers offer no load-break value at all. However, there are several facets to analyze in this scenario. First, if a non-rated HLC cannot be lifted under load, how about a drop-out switch? We operate those thousands of times a day without injury to the employee, although sometimes an ill-advised operation does smoke a pole top. There is nothing in the rules that prohibits an employer from making an engineering-based decision establishing criteria or protocols for operating HLCs or drop-outs under certain load conditions. Primarily, the employer’s determination would be based on risk to the employee and risk to the equipment. For OSHA, the primary consideration would be risk to the employee. Just as in the working alone rule, if the device is operated by a hot stick from a position that prevented injury to the employee, there would be no violation. Second, what would be the solution in the scenario? If the solution required installing a mechanical jumper and installing a load-break switch, would such an operation add risk exposure to the crew, and would adding the switch really enhance the safety of the operation? At the very worst case, the scenario – operating the HLC under load – could be ruled a de minimis violation. De minimis is the level of violation where OSHA recognizes that a direct rule was violated, but there was no other way, or no safer way, of executing the required task, and there was no risk to the employee.