Incident Prevention Magazine

Incident Prevention is on a mission to be a major player in the reduction of job related accidents within utilities and telecommunications. The publication, our iP Safety Conferences and this site are dedicated to providing utility safety and operations professionals the resources to build safety programs and implement processes that lead to...

Incident Prevention is on a mission to be a major player in the reduction of job related accidents within utilities and telecommunications. The publication, our iP Safety Conferences and this site are dedicated to providing utility safety and operations professionals the resources to build safety programs and implement processes that lead to reduced work-related incidents.

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Bill Martin, CUSP, NRP, RN, DIMM

Recognizing Our Human Risk Factors

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Determining the root cause of an incident or accident gives us the opportunity to share lessons learned to help prevent future duplication of the event. In this article, we’ll identify those inherent human traits that seemingly have little to do with the tasks lineworkers perform but often are the cause of incidents. It’s difficult to mitigate risk if we don’t recognize it, so let’s explore how simply being human can set traps for us.

Inattentional Blindness
Before we go any further, please be interactive here. Log onto your computer and plug in https://youtu.be/KB_lTKZm1Ts. The link will lead you to an awareness test during which you simply count the number of passes one team makes in a 15-second basketball game. Spoiler alert: If you haven’t watched the video yet, don’t read any further until you have.

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Mack Turner, CUSP

Feedback and Accountability in the Disciplinary Process

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Disciplining employees is always a tough task to handle, so it’s not surprising that many leaders and employees have a fear of the disciplinary process. However, discipline is a necessary part of business. That’s because sometimes, despite people’s best intentions, course correction must occur. As leaders who are tasked with doling out discipline, we should be careful to focus on the company’s needs in addition to the well-being of our employees throughout the process. We also need to keep in mind that our employees are our most valuable asset and should be treated with respect regardless of circumstances. In the end, although the disciplinary process can cause anxiety, fear and a host of other emotions, it can be a win-win for both sides.

When I started in this industry over 25 years ago, a nickname was bestowed upon me – I became known as “Grunt.” If I did anything that my foreman did not like, descriptive yet not-so-nice words escaped from his mouth, and I was threatened with unemployment. In another incident, I once watched a seasoned journeyman accidentally run a bucket into a phase, after which he was told by the foreman to grab his tool bag and lunch and get off the job. We know now that this kind of discipline and correction would never fly in today’s workplace – and it shouldn’t. Both leaders and employees deserve a disciplinary process that is fair and puts a focus on giving our employees – and the workplace – a chance for a positive forward direction.

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Stacey Simmons

The Hard Hat Celebrates 100 Years

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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.

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Jim Vaughn, CUSP

Train the Trainer 101: Telcom Workers Don’t Need FR – Or Do They?

The question that is the title of this installment of “Train the Trainer 101” originally came to me from a client during safety training for the company’s distribution employees. The client is a T&D contractor with a telecommunications (telcom) division. And yes, the question was regarding arc flash, which is not the same thing as FR. To utility workers, FR formerly meant “flash resistant.” The acronym FR was stolen from the utility industry by the road construction industry for traffic safety vests and now has come to stand for “flame resistant.” Flame resistance is the quality of a material designed for protection from exposure to fire or flame, not electrical arcs. OSHA, which does not use “FR” in the standards, requires that arc flash protective clothing also must be flame resistant to ensure clothing does not continue to burn after exposure to an electrical arc. In addition, flame resistance is required for the outer layer of clothing worn by an electrical worker who could be exposed to a heat source that could ignite that outer layer. There has been confusion, so it is important to recognize that use of the term “FR” on a traffic vest label does not mean the vest is arc protective; it is only flame resistant, meaning it has resistance to burning and will not continue to burn if the flame exposure is removed. It’s a habit to use the term FR when referring to arc flash protective gear, but we all need to understand the difference in labeling.

Now, back to the initial question. My first thought upon hearing it was that telcom workers are not required to use FR. After all, telcom is regulated by OSHA 29 CFR 1910.268, and 1910.268 does not require arc protective clothing like the 1910.269 standard does. But the answer doesn’t end there. So, if you are in the telcom business, don’t stop reading here. This is a lesson on interpretation of the standards as much as it is an answer to the question, who is required to wear arc flash protection?

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Danny Raines, CUSP

Voice of Experience: Planning for a Storm Restoration Effort

The electric utility industry is experiencing more major catastrophic storms than ever. Hurricanes, tornadoes, and snow and ice storms are taking their toll on both systems and employees. It was just several months ago that we were dealing with back-to-back hurricanes – Florence and Michael – and now we’re well into a winter that has dealt large swaths of the country plenty of snow and record-breaking low temperatures. 

At some point I stopped counting the number of storms I have worked during my 51 years in the industry. What I do know is that each storm has been a learning experience for me. One thing I’ve noticed over time – in addition to the increase in the number and severity of natural disasters – is that mutual assistance from other utilities and contractors has become a significant resource for host utilities that have suffered damage from these events. In light of that, I want to share some information that may help things go more smoothly for you and your crews during future restoration efforts.

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Jim Vaughn, CUSP

February-March 2019 Q&A

Q: We have crews working under a clearance on a de-energized circuit jointly controlled by two different utilities (employers). The concern is that the other employer’s personnel, wishing to bundle maintenance opportunities during the outage, are taking protective relays out of service on their end of the circuit. If a switch were inadvertently closed on their end, taking their relays out means no tripping protection since the other end of the circuit is open, too. Such an action could delay if not eliminate relay protection and raise current on the grounds protecting our workers. Is there an obligation between utilities to manage an outage under common rules?

A: There is an OSHA-based solution that comes in two parts. And even though your question is about grounding and tripping during inadvertent re-energizing, the solution to the issue actually lies ahead of grounding.

As you are aware, OSHA 29 CFR 1910.269(m) contains the rules for de-energizing lines and equipment for the protection of employees. That rule section is the pre-eminent means of ensuring no switch is ever closed without the permission of the employee in charge of the equipment or lines that have been de-energized and placed under their control. As you noted in your inquiry, we ground a circuit after the clearance process to ensure against any possibility of re-energizing. The grounding is based on an evaluation of relay trip settings to assure effective tripping to protect the crew under the clearance. Any change to the values or trip settings puts the crew at risk.

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David McPeak, CUSP, CET, CHST, CSP, CSSM

Frontline Fundamentals: Developing a Complete Definition of Leadership

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Our industry is under a lot of pressure. There is the ever-increasing pressure to keep the lights on and rates down by performing work efficiently and safely. To do more with less. Adding to the pressure is an aging workforce, high levels of turnover, and changes in workforce demographics – such as generational differences – that make it difficult to recruit and retain qualified employees.

What that means is leadership is more challenging and more important than ever. As the industry evolves and changes, so must its leaders. For that reason, leadership will be the focus of our 2019 Frontline Fundamentals columns and webinars. I highly encourage you to read the articles; send us your questions, concerns and experiences; and actively participate in the free webinars. Most importantly, take these opportunities to evaluate and improve yourself as a leader. Remember, leadership is a skill that can be improved.

In the remainder of this article, we are going to discuss two things that keep leaders in our industry from reaching their full potential: fear and an incomplete definition of leadership. We also will define leadership, how it is measured and outcomes produced by successful leaders. Lastly, we will address critical characteristics that effective leaders possess.

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Chip Darius, CUSP, OHST, CET, CSHO

Controlling Struck-By Hazards in Utility Work Zones

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Struck-by hazards are one of the greatest threats to workers employed in the utility and construction industries, and thus are hazards every utility and construction company should be focused on mitigating. Typical examples of struck-by hazards include traffic passing through a work zone; vehicle and equipment movement within a work zone or construction area; rotating or swinging equipment, such as an excavator; and falling loads and tools.

Worker fatalities in work zones dropped due to the last recession, hovering around 100 fatalities per year from 2007 to 2013, but numbers are rising again as the economy strengthens and roadway work projects increase. More than 140 worker fatalities in work zones were recorded in 2016.

OSHA is the Minimum
OSHA standards establish minimum legal standards for safety programs, and many employers rely on OSHA when creating company safety plans and policies. In this particular area, it is essential to emphasize the word “minimum” because OSHA standards lag far behind current consensus standards and recognized industry safety practices. Employers committed to protecting workers from struck-by hazards must set their sights higher than the OSHA minimums, looking to ANSI consensus standards and industry practices for guidance. This article explains the current federal OSHA and industry safety practices.

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Lee Marchessault, CUSP

Are Your Substations Safe?

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Electrical power is a critical service that profoundly affects our daily lives. Without it, we would lose cellphone service, safety on city streets would be compromised because lights would not work, and the quality of life as we know it would diminish significantly. We would have to close schools and hospitals, and most jobs would be eliminated. Much of our food supply also would be critically impacted.

To continue living the life we are accustomed to – and have come to expect – we must have a reliable source of electricity, which starts with generation. Outside the generation station, power typically is stepped up to a higher voltage and usually ends up at a transmission system voltage (i.e., 115 to 550 kV). Transmission substations provide a means to transmit and protect the high-voltage transmission systems throughout the U.S. To distribute the power to homes and businesses, the transmission voltage is stepped down to lower voltages in distribution substations. Both transmission and distribution substations have breakers and fuses to provide system protection, along with many other parts and pieces that provide protection for equipment, personnel and the public, as well as reliability.

To ensure that power is always available, utilities must be diligent – engaging in regular inspections and National Electrical Safety Code (NESC) audits – in identifying conditions that may impact reliability and safety. The NESC has been around for approximately 100 years. Initially created as a guide to help electrical professionals understand safe design and work practices for generation, transmission and distribution systems, it is a culmination of many other standards, some of which will be referenced in this writing. Substations – or “supply stations,” as they are referred to in the NESC – are an integral part of our transmission and distribution infrastructure and have inherent hazards that must be considered.

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Chris Court, CSP

Why Employees are Silent When Near Misses Occur

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What is a near miss? For those of you who are new to occupational safety, it’s typically defined as an event in which no workers were injured and no equipment or other property was damaged, but – had things gone just a little differently – injury or damage could have occurred.

Let me give you an example. A group of employees were digging a trench with an excavator so they could install some underground piping. At one point, the bucket came in contact with an old, abandoned 480-volt temporary power line that was not supposed to be in the area. Fortunately, the line was not energized, so no employees were injured, nor was the line damaged. Because the trench was already deep enough to set the pipe, the crew chose to re-cover the 480 line and continue working. This event should be considered a near miss, but it also is exactly the type of event that some workers may choose not to report to their company. The fact that the circuit was not energized in this case is not the most important issue. The crew did not know the circuit was there and did not identify it in the utility locates that should have preceded the excavation. Those issues indicate defects in the planning process, records and archives, and execution of the project. A near-miss report has the value of helping to ensure those defects are identified and corrected. Just because this line wasn’t energized doesn’t mean the next one won’t be.

The topic of near misses and the lack of employee reporting has been an interest of mine since I started working in the industrial sector. At first, I thought employees perhaps didn’t know what a near miss was and that reporting would increase if they were properly trained on the subject. I learned that wasn’t the case after I invested a good deal of time in training as well as talking to employees about what defines a near miss. After making those efforts, I only witnessed a slight increase in employee reporting that eventually slowed to a stop. I did find that lack of knowledge about near misses was true for newer employees, but that didn’t explain why older, seasoned employees were still keeping quiet. I also learned that the lack of near-miss reporting happens just about everywhere, whether it’s an established chemical plant with tenured employees, a new construction site with a diverse workforce, or even a remote oil and gas site.

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David Spooner

How Hawaii Electric Light Co. Protected Employees During a Lava Flow

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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.

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Jim Vaughn, CUSP

Train the Trainer 101: Solving PPG – Without Electrical Math

This installation of “Train the Trainer 101” may have an odd title, but it was inspired by some recent conversations I’ve had. I’ve learned a lot about personal protective grounding (PPG) in the past 20 years, and I continually learn even more as others share their research and experiences. Some time ago I learned that much of the fundamental electrical math upon which electrical circuit theory is based does not adequately explain the risk from high currents imposed on grounded systems. That does not mean there are not theoretical explanations for all of the results in high-current fault testing. But the simple circuit math of Ohm’s law cannot explain the complex electrical physics that occur in a high-current fault, and that is partly what confuses the issue concerning EPZ.

What is simple is this fundamental of worker protection: It takes 50 volts to break the electrical resistance of a worker’s skin. If you can break the electrical resistance of the skin, current can flow, and the worker can be injured. However, if voltage cannot penetrate the skin, current cannot flow. You cannot eliminate system current by grounding; you can only divide it (i.e., send most of it through a different path) and hope for the best. But you can eliminate voltage in the worker exposure. You eliminate voltage potential by bonding. Once you’ve eliminated the voltage potential hazard, current no longer matters and thereby the risk is altogether eliminated.

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Danny Raines, CUSP

Voice of Experience: How Was Your 2018?

I would like to ask those of you reading this article to reflect on your professional life in 2018. What was different from previous years? Was safety at your company better, worse or about the same? As I sit and write this article during the first week of October 2018, I know that so far this year, the electric utility industry has suffered more than 20 fatal accidents and over 30 serious flashes and contacts. I don’t know what’s going to happen between now and the end of the year, but I pray no one else gets hurt.

The fact is, our industry has suffered extremely high numbers of fatalities since around 2013. The last I heard, in 2017 we had 45 fatalities between investor-owned utilities, cooperatives, contractors and municipals. NIOSH and EPRI started doing research in the mid-1990s through approximately 2006, and they found that the electric utility industry recorded 24 to 28 fatalities each year. The causes of those fatalities included contacts, falls and vehicle accidents.

What continues to amaze me is that our industry has the investigation and root cause analysis measures to identify why accidents keep happening, but we fail to implement the measures available to us to prevent recurrences of these types of accidents. The majority of fatalities occur during energized line work, yet they keep happening. Why? On one hand, while it’s true that lineworkers are some of the best trained craft workers out there, even the most seasoned lineman is human and can make an error in a moment of stress, or if his mind wanders or for any number of other reasons. 

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Jim Vaughn, CUSP

December 2018-January 2019 Q&A

Q: With all the talk about grounding, cover-up, EPZ and minimum approach distances, we have been debating the best practice for setting steel poles in energized 138 kV. A big question is, what class gloves should ground personnel wear while handling the pole? How can Class 3 or 4 gloves protect against 138 kV?

A: The short answer is that a Class 4 glove won’t protect against 138 kV. However, if you do it right, there is a very good chance you won’t be exposed to 138 kV even if you do get the pole in the 138. Here is how and why. At transmission voltages, we rely on planning, equipment setup, and precise/predictable control of the equipment and airspace to prevent contacts. We then take additional equipotential bonding actions to protect against a worst-case scenario like loss of control and pole contact with a circuit.

Here are some recommendations for those additional actions. Grade the work area. Grading the area flat around the pole hole gives the crew space for equipotential mats or grids. In best-case planning, it is ideal to stand the pole up with little hands-on contact until you get to the grabbers. If you are using portable mats, the prime location is at the stand-up/grabber location. During handling, the crew members on the pole butt will be in an EPZ. The pole then gets swung to the hole without crew contact. At the hole, mats are used to line the hole for crew who will handle the pole setting. Many crews are now using cattle panels as grids to create equipotential mats in the pole-setting areas. The panels are available at feed stores, constructed of welded #4 steel wire and bonded to the ground rod to create a large walking area around the pole-handling area that will be at equal potential with the pole.

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David McPeak, CUSP, CET, CHST, CSP, CSSM

Frontline Fundamentals: Human Performance Implementation

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For all of 2018, this column and its associated webinars have focused on human performance (HP). I have thoroughly enjoyed and learned a lot from the guest speakers who participated in the webinars, as well as the readers and webinar participants (you) who have been engaged, shared their experiences, and asked intelligent and challenging questions.

In this article, I will wrap up the HP series by reviewing key points, outlining proven strategies about HP implementation and inviting you to our next webinar – scheduled for January 16 – that I am really excited about because we will have a panel of experts gathered to explain HP implementation, address your concerns and answer your questions.

HP Review: Principles and Key Points

Principle One: People are fallible, and even the best make mistakes.
People screw up. We make mistakes, and often we are not aware of them. That is a real problem, especially with regard to safety. Rarely are our errors and their undesired consequences intentional, and most errors have no immediate negative consequences. Because of this, your safety program must acknowledge that people will make mistakes. With that acknowledgement, we can use HP tools to reduce errors and manage controls.

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Bob McCall

How to Build a High-Performing Team

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I’m really excited to be writing this article for my utility family. I enjoyed all 33 of my years working in the industry. Now, as a leadership consultant, I have the privilege of using my knowledge, experience and passion to help the utility industry improve. My goal is to provide you with proven tools that will enable you to lead your team to their highest level of performance – where each of your team members will be able to consistently perform at their top potential every day, in every task. It is at that level where zero accidents and zero injuries occur on a consistent basis, and that’s what we want and need in our workplaces. It is no secret that our industry is still among the most hazardous. The penalty for making a mistake can be life-threatening. While I was still working in the industry, it was the love I had for my team that made me want to do all I could to protect them. And that love translated into success throughout my career, during which I created a number of high-performing teams. I want to tell you a little more about that in these pages.

“Treat a person the way that you want them to be and you will make them great” is wisdom that John Maxwell – a best-selling author on the topic of leadership – states in his book “Becoming a Person of Influence: How to Positively Impact the Lives of Others.” College football analyst and retired coach Lou Holtz has said, “If you get people to believe in themselves, they will set higher goals.” I’ve long respected both John and Lou as leaders, so during my working years at utilities, I absorbed what they said and tried putting it into action. As I mentioned earlier, all of my success in my previous industry career was the result of investing and believing in people. In total, I was able to build high-performing teams eight times throughout that career. The process is complex, but it starts with one brief question: Why build a high-performing team? The answer is, because a high-performing team will do everything at an exceptional level. They will meet or exceed all of their goals. They will perform excellent pre-job briefings. They will be highly attentive and participatory. They will have a strong ability to recognize and mitigate hazards. They will follow each job plan with the understanding that if anyone on the team sees something wrong or senses that something is wrong, they can stop the job and ask a question without upsetting other team members. A high-performing team uses the safest work methods, and its members reflect great leadership combined with a culture that supports an error-free workplace.

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Debbie Dickinson

Using Task-Based Work Assignments to Create Proficient Crews

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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.

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Rob D. Adams, CLCP, CUSP, and Pete Prast, P.E.

Enhancing Safety for Line Patrol Technicians

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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.

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Hugh Hoagland and Stacy Klausing, M.S.

Rubber Insulating Sleeves and Arc Flash Protection

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Rubber insulating sleeves are commonly worn with dielectric gloves in high-voltage applications to provide added insulation from electrical contact for those working on energized equipment. The rubber insulating gloves and rubber insulating sleeves are worn for shock protection; sleeves typically are worn with rubber insulating gloves when the arm can cross the minimum approach distance or the restricted approach boundary. A protector glove typically is used for arc flash protection and for mechanical protection of the rubber insulating glove, but this over-glove does not protect the entire glove and does not extend up a rubber insulating sleeve.

Many lineworkers wear short-sleeved, arc-rated (AR) T-shirts under rubber insulating sleeves, and a concern was raised in the industry that the insulating sleeves are not arc-rated. As a result, Iowa OSHA issued a letter of interpretation that since rubber sleeves are not arc-rated, long-sleeved AR shirts are required, in their opinion, to meet the letter of OSHA 29 CFR 1910.269. Federal OSHA has not issued an interpretation.

Since there is currently no standard that covers arc flash testing of rubber insulated products, ArcWear – an independent, third-party testing laboratory – studied several sleeves to assess arm protection and ignition withstand. That’s because although, per Iowa OSHA, workers are required to wear arc-rated, long-sleeved shirts under the rubber sleeve for arc flash protection, they may unnecessarily contribute to heat stress, and there was no evidence one way or another that this requirement would add to the end users’ protection levels. The configuration of wearing a short-sleeved T-shirt tucked into a rubber insulating glove may be more comfortable to a worker while providing complete coverage, but the question remained, would it provide enough protection in case of an arc flash?

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Jim Vaughn, CUSP

Train the Trainer 101: Are Those Tools and Equipment Approved?

We provide tools and equipment for our crews. Sometimes they are special tools, and sometimes they are generic tools necessary to support routine crew work. Sometimes they are accessories for trucks and equipment, and sometimes they are simply extra tools or equipment to make things easier on the people in the field. The question then is, are these tools approved?

The following is going to aggravate some readers, so let’s start with a reminder: I attempt to clarify and simplify compliance with this series. This is about making compliance easier and sometimes less expensive. So, here is an example.

About 20 years ago I was organizing a training school for a community college in Florida. I was recruiting utilities as clients. A visiting utility safety director saw that we had 40-foot-length retractables at the tops of the training poles. He said, “You are going to get into trouble with those yo-yos. They have to be mounted on approved davits.” My first question – and what should be your first question, too – was, approved by who? Without skipping a beat, the safety director responded, “OSHA.” We then went to his office where he had a similar device for which they had paid a little over $2,000. And just like he said, right there on the box was clearly printed “OSHA approved.” It only took me a few minutes on OSHA’s website to show him reference after reference and interpretation after interpretation in which OSHA stated to employers and manufacturers that it does not approve equipment. If an employer writes to OSHA and asks if they approve of having the employer’s employees in a specific type of exposure, and the employer intends to use a specific tool and equipment in a particular configuration, OSHA will respond that the agency does not approve equipment. The agency will then go on to state that in the situation described, using the equipment as described, OSHA believes the employer’s solution would – or would not – meet OSHA’s requirements.

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