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Subpart V revisions and line construction
The Occupational Safety and Health Administration (OSHA) estimates that 444 serious injuries and 74 fatalities occur annually among employees involved in electric power generation, transmission and distribution work. The existing construction standards in the 29 Code of Federal Regulation (CFR) Subpart V, Electric Power Transmission and Distribution, were promulgated in 1972. After more than 30 years, OSHA has proposed changes.
For many, this update is long overdue. While these standards remain the governing reference for line contractors, related consensus standards have kept pace with industry advances in work practices and equipment. In 1994, OSHA promulgated a new standard, 29 CFR 1910.269, for general industry operations. It included requirements not found in the construction standards.
A major focus of the Subpart V revision is that construction standards must mirror the corresponding general industry standard. This is critical, since many tasks performed by electricians in general industry and construction are identical. Often, the only difference is whether the work is considered maintenance of existing systems or a new installation. Consider the following example offered in the preamble of the proposal: “Employers changing a cutout (disconnect switch) on a transmission and distribution system would be performing construction work if they were upgrading the cutout but maintenance or general industry work if they were simply replacing the cutout with the same model.”
The proposed standard will also replace out-of-date consensus standards that were incorporated by reference with performance-oriented requirements. The language proposed is consistent with the latest revisions of the consensus standards but allows greater flexibility for compliance. This philosophy appears for the first time in the creation of 29 CFR 1926.97, Electrical Protective Equipment, Special Requirements. The American National Standards Institute (ANSI) standards, previously incorporated by reference in Subpart V 1926.951(a)1, have been removed and placed in the new proposal. Staying with the main focus of consistency between construction and general industry, corresponding regulations in general industry, 1910.136 and 1910.137, will be revised. The references to the consensus standards in both simply offer help with compliance. The actual reference given has also been updated to identify the original source of the standards, the American Society for Testing and Materials (ASTM), instead of ANSI. A similar approach to consensus standards occurs throughout Subpart V. A list of helpful consensus standards is available in Appendix E to Subpart V—Reference Documents.
The proposed elements of Subpart V actually follow the elements of 1910.269, beginning with Section 1926.950, General Industry. This section addresses the scope of the rule, training and the determination of existing conditions. Contractors will be required to ensure employees are trained based on regular supervision and/or annual inspection of their work performance. Another significant and controversial part of 950 is the proposed relationship between host and contractor. Both host and contractor would have a role in the hazard assessment. Additionally, the host would be required to inform the contractor of any contractor safety violations.
Part 1926.951 emphasizes the general requirements in the medical and first aid provisions in other construction standards. It offers two options for compliance, which are to train all employees in CPR within three months or ensure at least two trained individuals are on-site at any given time.
Part 952 adds a new requirement to Subpart V, Job Briefings. Job Briefings requires the employer to plan the job and review the plan with employees prior to beginning work. The extent of the briefing and whether more than one briefing is required in a day depends on the complexity of the work and variety of tasks to be performed.
Part 953 deals with enclosed spaces. This section is designed to deal with the confined spaces commonly found in electric transmission work. OSHA recognizes the hazards found in these spaces are much more limited than hazards in permit spaces. The precautions the section requires are set in accordance with this belief.
The basic requirements for personal protective equipment in construction can be found in Subpart E. Part 954 refers line contractors to that section. It also relies on Subpart M of the construction standards for basic fall protection. In doing so, it establishes the need for workers in bucket trucks to use a body harness. As required by Subpart M, body belts are limited to use in positioning system.
In Part 955, the proposal prohibits the use of conductive portable ladders near exposed energized lines or equipment. However, there is an exception for specialized high-voltage work. The standard actually allows the use of a conductive ladder where an employer can demonstrate that the use of a nonconductive ladder is a greater hazard.
Parts 956 and 957 deal with tools. Part 956 addresses precautions for hand and power tools. Part 957 proposes rules for live-line tools. Tools plugged into building wiring would continue to be governed by the rules in Subpart K of the construction standards. Portable and vehicle-mounted generators need to have a grounding capability. Precautions would need to be taken to protect against the capacity for injury of hydraulic tools. Part 957 sets design criteria for live-line tools and requires a daily cleaning and inspection of these tools
Parts 958 and 959 of the proposed rule cover material handling and mechanical equipment. For the most part, both sections defer unqualified workers to other applicable subparts already found in the construction standards. The requirements for qualified workers for both storage and use of mechanical equipment revolve around a worker respecting the Minimum Approach Distances (MAD). If the proposed rule goes forward, workers will need to familiarize themselves with the MADs and applicable rules for storage and mechanical equipment use.
Part 1926.960, Working on or Near Exposed Energized Parts, contains a number of new controversial requirements. For the first time, contractors are provided with a perspective from OSHA as to the “appropriate means” for determining when a line can be considered de-energized. This is accomplished by referring to the rules found in the proposed section 1926.961, De-energizing Lines and Equipment for Employee Protection.
Part 960 also establishes a two-person rule for installation, removal or repair of lines that are energized at more than 600V. Exceptions are made for task performed for public safety. OSHA is also trying to bring back the concept of introducing an ergonomic factor into the MAD. As stated in the proposal, “The employee would have to work from a position where the employee would not be able to reach into the minimum approach distance.”
Another concept brought into the proposal is flame-resistant clothing. In the existing general industry rule, OSHA merely required that an employee’s clothing do no greater harm. OSHA plans to introduce the idea that employers determine the potential energy from a hazardous arc flash and provide flame-resistant clothing with an appropriate protective level. This is an interesting concept, since OSHA admittedly recognizes “none of the methods can predict precisely how much heat energy an employee will face.” OSHA’s approach is that a good indication of energy can be determined, and it has provided references and an appendix to assist employers.
The rules found in Part 1926.961 that apply to de-energizing lines and equipment for employee protection are dependent on the circumstances. OSHA recognizes the differences in whether or not the system is visibly open, being worked on by one or multiple crews and under the direction of a central operator. Regardless of the method, it will be important to determine the conditions under which the lines or equipment are de-
enegerized, determine the control access and track the status of the system. Part 1926 introduces the concept of an “employee in charge” of a crew.
Part 1926.962, Grounding for the Protection of Employees, would require protective grounds to be placed so that employees would not be exposed to hazardous differences in potential. It allows employers and employees to determine the grounding method. However, it does establish criteria for grounding equipment and procedures to install or remove a ground.
Part 1926.963 is Testing and Test Facilities. It contains work practices for hazards associated with special testing of lines and equipment. These procedures can be found in the National Electrical Safety Code (ANSI C2).
The rules for overhead lines are covered in 1926.964. The precautions begin with an employers responsibility to ensure the structures, poles, towers, etc., are safe. It also targets hazards associated with induced voltage. Although it does not provide specific guidance for determining if the hazard exists, it provides additional provisions on grounding. For example, it specifies that, “Grounds must be installed in increments of no more than 2 miles.”
Due to the many electric distribution systems beneath the earth in manholes, vaults and other enclosures, OSHA has proposed new language in Part 1926.965, Underground Electrical Installations. The precautions here supplement those from the proposed 19256.953, Enclosed Spaces. This part offers precautions such as prohibiting climbing on equipment, employees to be in the clear when tools or materials are lowered, installing duct rods in the direction that presents the least hazard to employees, etc. Employees performing work in underground installations will need to become familiar with both sections when the rule is promulgated.
Like many sections, parts 1926.966, Substations, and 1926.967, Special Conditions, are meant to supplement the general precautions in the other parts of the proposal. Little is offered in either that would contradict the previous standard or 1910.269. The supplemental precautions offered here should be consulted when the rule passes. In addition, the definitions found in 1926.968 and the appendices found at the end of the standard will help with any clarification needed on the new languages in the proposed rule.
OSHA believes these changes will prevent an additional 116 injuries and save 19 lives and have an overall financial benefit to the industry of $101 million. Of course, this is based on its figures, estimating the cost of compliance at $33.9 million, the prevention of injury and death as noted and a cost of $50,000/injury and $6.8 million/fatality. One can certainly question its estimates. Many have questioned elements of the proposed standard. A hearing was held on March 6, 2006, where comments were presented. The post comment hearing was scheduled to end on July 14, 2006. OSHA will take all comments into consideration. Contractors should keep abreast of the activity on this standard. As noted, significant changes in work practices and the cost of doing business may occur. EC
O’CONNOR is with Intec, a safety consulting, training and publishing firm that offers on-site assistance and produces manuals, training videos and software for contractors. Based in Waverly, Pa., he can be reached at 607.624.7159 or by e-mail at [email protected].