Revised OSHA Utility Safety Rules Quad-State Instructors Meeting La Crosse, WI June 11, 2014

General Published in Federal Register – Friday, April 11 Generally becomes effective July 10, 2014 Few rules have extended deadlines Most existing rules did not change scope or intent Rewording Broken out into individual statements

General Most changes occurred in the utility construction industry rules – 1926 Subpart V Now almost the same as General Industry utility rules Subpart V does not have any rules on: Line Clearance Tree Trimming Generation

General One common change across entire set of rules The phrase “The Employer Shall” was added to almost every rule that didn’t already contain it. The Employer shall determine… The Employer shall prove… The Employer shall ensure… If there was any question as to who is responsible, there shouldn’t be now

1910.269 a – General Employers covered under this section are not exempt from complying with other applicable provisions of 1910. Appendix A

1910.269 a2 – Training a2iC – The degree of training shall be determined by the risk to the employee for the hazard involved. a2iiC – MAD training also include “…skills and techniques necessary to maintain those distances”

1910.269 a2iiE – The recognition of electrical hazards to which the employee may be exposed and the skills and techniques necessary to control or avoid those hazards. a2iii – Line Clearance Tree Trimmers Skills and techniques to distinguish exposed live parts Determine nominal voltage of exposed live parts MADs and skills and techniques to maintain

1910.269 a2viii - …each employee has demonstrated proficiency in the work practices… Requirement for annual certification by employers has been removed

1910.269 a3 – Information transfer – New Host employer shall inform contract employer Nominal voltages of lines and equipment Maximum switching-transient voltages Presence of hazardous induced voltages Presence of protective grounds and equipment grounding conductors Locations of circuits and equipment Must obtain this info

1910.269 Also must provide the following info if in existing records: Condition of protective grounds and equipment grounding conductors Condition of poles Environmental conditions relating to safety Not required to make inspections This info also to be made available to own workers

1910.269 Also information about the design and operation of system that contractor needs to make assessments Any other info contractor requests about design and operation known by host employer related to protection of contractor’s employees Again, only info from existing records, no inspection of work site required

1910.269 Contractor must in turn: Ensure their employees instructed in hazards relevant to their work Advise host employer of any unique hazards presented by contractor’s work Advise host employer of any unanticipated hazardous conditions found Must provide this info to host employer within 2 working days

1910.269 Host and Contractor shall coordinate their work rules and procedures so all employees are protected as required

1910.269 b Medical services and first aid CPR is now included as part of the definition of first aid training (see part x) Annual training required Does not have to be “certificate” training 3 month training rule only applies to line-clearance tree trimming operations Employer to inspect first aid kits at least annually

1910.269 c Job Briefings Employer shall provide the employee in charge of a job with all available information that relates to the determination of existing characteristics and conditions. Remaining part of rule unchanged Same subjects Number Extent

1910.269 g Personal Protective Equipment New note added – all PPE required by various sections of these rules to be paid for by employer per 1910.132(h) Fall protection equipment Electrical protective equipment Flame-resistant and arc-rated clothing

1910.269 g2ii Personal fall arrest equipment– If exposed to hazards of flames or arcs, must be capable of passing specified drop test after exposure to arc heat of 40±5 cal/cm2 Does not necessarily mean an FR arc-rated harness

1910.269 g2iii Body belts and positioning straps Long list of construction and strength requirements Most from old 1926.959 Locking snaphooks required For employees not weighing more than 310 lbm, belts and straps in conformance with ASTM F887-12 are deemed to be in compliance

1910.269 givC Fall protection systems used as follows: Employees working from aerial lift shall use a fall restraint system 1910.67 no longer applies Employees elevated more than 4 ft above ground on poles, towers or similar structures Personal fall arrest Work positioning equipment Fall restraint

1910.269 Until March 31, 2015 – qualified climber may continue to climb or change location without fall protection under same conditions as current rule Starting April 1, 2015 all employees must use fall protection equipment when climbing or changing position

1910.269 g2ivD Work positioning systems shall be rigged so that an employee can free fall no more than 2 feet. g2ivE Work positioning equipment shall be capable of supporting at least 2 times potential impact load or 3000 pounds-force ASTM F887-12

1910.269 g2ivF Unless of the locking type and designed specifically for the connection, snaphooks may not be connected: Directly to webbing, rope or wire rope To each other To a D ring in which another snaphook or connector is attached To a horizontal lifeline Any other incompatibly shaped object

1910.269 l Working on or near exposed energized parts l2 Two employees required – same list of tasks where two employees are required but revised to emphasize that second employee is required when any employee performs these types of work All other parts of this rule remain the same

1910.269 l3 Minimum approach distances This rule was extensively revised OSHA choose to not follow existing NESC MADs By April 1, 2015 employers must be using new values of MAD Either calculate per new Table R-3 Or use Table R-6 (≤72.5kV) or R-7 (>72.5kV)

1910.269 1-1 2-1 2-2 2-6 2-9 3-4 2-3 2-11 3-3 3-11

1910.269 These values only valid up to 3000 ft elevation If working higher than that then correction factors in Table R-5 must also be used For transmission work, companies will want to do the calculations as values in Table R-7 are for max T and are greatest distances

1910.269 l3iii No employee may approach or take any conductive object closer to exposed energized parts than the established MAD unless: Insulated from energized part Energized part is insulated from employee Or performing live-line barehand work If gloving, must have control of the part being worked on in a manner to prevent exposure to uninsulated parts of the body

1910.269 l4 Type of insulation When rubber insulating gloves are used as insulation, rubber insulating sleeves must also be worn, unless: All exposed energized parts not being worked on are insulated; and Insulation installed and removed from a position that does not expose upper arms to contact with other energized parts

1910.269 l4ii OSHA did not set any mandatory distance an employee must be from energized parts before putting on or removing rubber gloves and sleeves Only that this must be done from a position such that the employee cannot reach into the MAD established by their employer while putting on or removing gloves and/or sleeves

1910.269 l8 Protection from flames and electric arcs Employer shall assess workplace to identify employees exposed to hazards from flames or electric arcs Make a reasonable estimate of incident heat energy to which each employee would be exposed. Appendix E

1910.269 May use one of several methods to calculate heat energies, within limits (App. E Table 3)

1910.269 Do not have to do heat estimates for every job Can do broad estimates provided they represent the maximum employee exposure Very similar to requirements under NESC-2007

1910.269 l8iii Employees cannot wear clothing that could melt onto skin or ignite and continue to burn when exposed to flames or heat energy estimated. Acetate, nylon, polyester, rayon and polypropylene banned unless treated or worn in a manner as to eliminate the hazard

1910.269 l8iv Outer layer must be flame resistant when: Exposed to contact with energized parts at more than 600 volts Electric arc could ignite flammable material in work area that could ignite clothing Molten metal or arcs from faulted conductor in work area could ignite clothing Incident heat energy estimate exceeds 2.0 cal/cm2

1910.269 l8v Employees exposed to hazards from electric arcs must wear protective clothing and other protective equipment with an arc rating greater than or equal to heat energy estimated Protective equipment shall cover the employee’s entire body, except as follows:

1910.269 Hands – While wearing rubber insulating gloves with protectors or, If heat energy no greater than 14 cal/cm2, heavy-duty work gloves (12 oz/yd2)

1910.269 Feet – Feet when wearing heavy-duty work shoes or boots

1910.269 Head – Only head protection per 1910.135 when Less than 9 cal/cm2, single phase open air exposure Less than 5 cal/cm2 all other exposures Head Protection plus arc rated faceshield above those levels Minimum 8 cal/cm2 faceshield when 9 – 13 cal/cm2 single phase open air exposure Minimum 9 cal/cm2 faceshield all other exposures

1910.269 For exposures involving single phase open air arcs the arc rating of the head and face protection may be 4 cal/cm2 less than estimated heat energy

1910.269 Arms – There is no provision in new rules for short-sleeved arc rated FR shirts OSHA did not recognize rubber sleeves as providing protection from arc heat energy TVA

1910.269 n Grounding for the protection of employees n3 Equpotential zone Temporary protective grounds shall be placed at such locations and arranged in such a manner that the employer can demonstrate will prevent each employee from being exposed to hazardous differences in electric potential.

1910.269 Appendix C The Occupational Safety and Health Administration will deem grounding practices meeting these guidelines as complying with paragraph (n)(3) of this section. Either follow guidelines in Appendix C or do an engineering analysis to be able to demonstrate you are meeting minimum level of protection

1910.269 Starts on page 20681 of Federal Register edition containing the new rules

1910.269 Other changes in this paragraph n4i Grounding equipment has to be capable of conducting maximum fault current that could flow at point of grounding for the time necessary to clear the fault.

1910.269 n6 Connecting and Removing Grounds At 600 volts or less employee may use insulating equipment other than live-line tool to install or remove grounds Must ensure line or equipment is not energized at time Or demonstrate employee is protected from hazards that may develop if line or equipment is energized

1910.269 p4 Operations near energized lines or equipment p4i mechanical equipment must be kept outside MAD as established by employer under paragraph (l)(3)(i). Insulated portion of an aerial lift operated by qualified employee is exempt from this requirement if applicable MAD maintained between uninsulated portion of the aerial lift and exposed objects having a different electrical potential

1910.269 q Overhead lines and live-line barehand work q2 Installing and removing overhead lines q2i When lines that employees are installing or removing can contact energized parts, the employer shall use the tension-stinging method, barriers, or other equivalent measures to minimized the possibility that conductors and cables the employees are installing or removing will contact energized power lines or equipment.

1910.269 q2iv when stringing parallel with other energized conductors, OHSA removed the requirement for grounds to be installed a specific locations. Instead replacing it with the statement …”,temporary protective grounds shall be placed at such locations and arranged in such a manner that the employer can demonstrate will prevent exposure of each employee to hazardous differences in electrical potential.”

1910.269 r Line-clearance tree trimming operations MAD tables referenced in several rules in this part renumbered to match up with revised MAD tables in paragraph l. r5iv A power saw shall be started on the ground or where it is firmly supported. Drop starting of saws over 15 pounds, other than chain saws, is permitted outside the bucket of an aerial lift,… NOTE added

1910.269 u Substations u1 Access and working spaces OHSA revised note to this rule to say than ANSI/IEEE C2-2012 (NESC-2012) contains the guidelines on dimensions for access and working spaces to comply with u1. OSHA will determine whether an installation not in compliance with u1 based on …

1910.269 Does installation conform to edition of ANSI C2 that was in effect when installation was made. Does configuration of installation enable employees to maintain MAD as determined in (l)(3)(i) when working on exposed energized parts. Do precautions taken when employees perform work in the installation provide protection equivalent to protection provided by access and working space meeting ANSI C2-2012.

1910.269 u4 Guarding of rooms and other spaces containing electric supply equipment u4iii Unqualified persons may not enter the rooms or other spaces while the electric supply lines or equipment are energized. u4v entrances to rooms or spaces locked or under the observation of a person attending the room or other space for the purpose of preventing unqualified employees from entering.

1910.269 x Definitions Contract employer – An employer, other than a host employer, that performs work covered by this section under contract.

1910.269 Entry – (as used in paragraph (e)). The action by which a person passes through an opening into an enclosed space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space.

1910.269 Exposed, Exposed to contact – Not isolated or guarded Fall restraint system – A fall protection system that prevents the user from falling any distance.

1910.269 First aid training – Training in the initial care, including cardiopulmonary resuscitation (which includes chest compressions, rescue breathing, and, as appropriate, other heart and lung resuscitation techniques), performed by a person who is not a medical practitioner, of a sick or injured person until definitive medical treatment can be administered.

1910.269 Host employee – An employer that operates, or that controls the operating procedures for, an electric power generation, transmission, or distribution installation on which a contract employer is performing work covered by this section. Note – electric utility or owner of the installation is the host employer if it controls operating procedures

1910.269 Isolated – Not readily accessible to persons unless special means for access are used. Personal fall arrest system – A system used to arrest an employee in a fall from a working level. Work positioning equipment – A body belt or body harness system rigged to allow an employee to be supported on an elevated vertical surface, such as a utility pole or tower leg, and work with both hands free while leaning.

1910.269 Appendix A Flow Charts Illustrate the scope and application of 1910.269. Addresses the interface between 1910.269 and Subpart S, electrical 1910.146, permit-required confined spaces 1910.147, control of hazardous energy

1910.269 Appendix B – Working on Exposed Energized Parts Appendix C – Protection From Hazardous Differences in Electric Potential Appendix D – Methods of Inspecting and Testing Wood Poles Appendix E – Protection From Flames and Electric Arcs

1910.269 Appendix F – Work Positioning Equipment Inspection Guidelines Appendix G – Reference Documents