Author’s Note: Before we get to the article, I want to thank the members of Incident Prevention’s editorial advisory board for their help in assembling this installment of “Train the Trainer 101.” They help me keep my head on straight, especially when I have ideas that are way outside the box. Even though I am also on the board, they still hold me to high standards of accountability and accuracy. These folks are a great asset to iP and make better writers of everyone who contributes to the publication.
Over the past year, iP subject matter experts have fielded many questions about how to meet the minimum approach distance (MAD) and arc flash (AF) rules published by OSHA in the 2014 final rule regarding 29 CFR 1910.269 and 1926 Subpart V. The questions about MAD came from a variety of perspectives, but they were primarily submitted by contractors trying to facilitate the information transfer now required by 1910.269(a)(3) and 1926.950(c). Without information about a system’s fault characteristics, the contractor cannot determine MAD, either by calculation or via the tables in 1910.269 Appendix B and Appendix B to 1926 Subpart V. That means the contractors must fall back on the sometimes absurd provisions of alternative tables R-7 through R-9. In my work for a contractor, we have found that those alternative tables can make some work – particularly transmission work – very difficult, if not impossible, especially when faced with compact lattice structures or old construction standards on wood poles. For AF programs, that lack of information may be overcome effectively by experienced guesswork, but compliance by guesswork cannot be defended when the compliance safety and health officer asks how you determined the AF compliance requirements.