In case you missed it, OSHA just published a new electric power generation, transmission, and distribution rule.
To be exact, the announcement was made April 14, 2014, and the rule goes into effect on July 10, 2014 (that “go live” date is now coming up soon). But, OSHA DID delay compliance and enforcement guidelines for some of the requirements. See below for more on that.
According to OSHA, the changes:
- Update the Electric Power Transmission and Distribution for Construction standard, issued in 1972
- Update the Electric Power Generation, Transmission, and Distribution for General Industry (Operation and Maintenance) standard, issued in 1994
- Harmonize the two standards (general industry and construction) so the same rules apply generally to the same kinds of work
- Update the standards so they’re based on the latest consensus standards and improvements in electrical safety technology
OSHA’s provided lots of information here. In addition, we’ve gathered that information up and presented it below (relying heavily on their handy Fact Sheet and FAQ, parts of which we’ve directly copied and pasted below so you get the words from the horse’s mouth).
What are the significant changes in OSHA’s new electric power generation, transmission, and distribution rule?
Significant changes include:
General Training
- The degree of training must be determined by risk to the worker for the hazard involved.
- Qualified workers must have training to recognize and control or avoid electrical hazards present at the worksite.
- Line-clearance tree trimmers must have training to distinguish exposed live parts and to determine the voltage on those parts, and they must have training in minimum approach distances and how to maintain them.
- It is no longer necessary for employers to certify that workers are proficient in safe work practices
Host Employers and Contractors
- Host and contract employers must share information with each other on safety-related matters and must coordinate their work rules and procedures.
Fall Protection
- On and after April 1, 2015, qualified workers must use fall protection when climbing or changing location on poles, towers, or similar structures unless climbing or changing location with fall protection is infeasible or creates a greater hazard than climbing or changing location without it.
- Fall arrest equipment must be capable of passing a drop test after exposure to an electric arc with a heat energy of 40.5 +-cal/cm2 if the workers using the fall protection are exposed to flames or electric arc hazards.
- On and after April 1, 2015, work-positioning equipment must be rigged so that workers can free fall no more than 0.6 meters (2 feet).
- Information on the inspection of work-positioning equipment appears in appendices to the standards.
Minimum Approach Distances and Insulation
- Revised minimum approach distances become effective on April 1, 2015.
- Information to help employers establish minimum approach distances appears in appendices to the standards.
Protection from Flames and Electric Arc Hazards
- The employer must assess the workplace to identify workers exposed to flame or electric-arc hazards.
- No later than January 1, 2015, employers must estimate the incident heat energy of any electric-arc hazard to which a worker would be exposed.
- No later than April 1, 2015, employers generally must provide workers exposed to hazards from electric arcs with protective clothing and other protective equipment with an arc rating greater than or equal to the estimated heat energy.
- Information on protecting workers from flames and electric arcs appears in appendices to the standards.
De-energizing Transmission and Distribution Lines and Equipment
- Multiple crews working together on the same lines or equipment must either: (a) coordinate their activities under a single worker in charge and work as if all of the employees formed a single crew; or (b) independently comply with the standard and, if there is no system operator in charge of the lines or equipment, have separate tags and coordinate de-energizing and re-energizing the lines and equipment with the other crews.
Protective Grounding
- Employers may use insulating equipment other than a live-line tool for placing grounds on or removing grounds from circuits of 600 volts or less under certain conditions.
- Information on protective grounding for de-energized lines appears in appendices to the standards.
Underground Electrical Installations
- Special precautions apply when employees perform work that could cause a cable to fail.
Electrical Protective Equipment
- The Electrical Protective Equipment for Construction standard applies to all construction work, not just electrical power generation, transmission, and distribution work. That standard also replaces the existing construction standard’s incorporation of out-of-date consensus standards with a set of performance-oriented requirements that is consistent with the latest revisions of the relevant consensus standards.
- The final rule recognizes a new class of electrical protective equipment, Class 00 rubber insulating gloves.
- The standards adopt new requirements for electrical protective equipment made of materials other than rubber.
Foot Protection
- In addition to revising the Electric Power Generation, Transmission, and Distribution, and the Electrical Protective Equipment standards, OSHA also revised the General Industry Foot Protection standard to clarify that an employer must ensure that workers use protective footwear as a supplementary form of protection when the use of protective footwear will protect the workers from electrical hazards, such as static-discharge or electric-shock hazards, that remain after the employer takes other necessary protective measures.
Source for above section: OSHA Fact Sheet
Now, let’s look in more detail at some FAQs about the new OSHA electric power generation, transmission, and distribution rule.
When does it take effect and when will it be enforced?
The revised 1910.269 and Subpart V will be effective July 10, 2014, but the compliance deadline for some provision on fall protection, minimum approach distances, and arc-flash protection is being extended to April 1, 2015. Also, OSHA has announced an interim enforcement policy stating that enforcement for MOST of the new requirements won’t begin until October 31, 2014 as long as an employer is complying with the General Industry regulations.
Where is the rule published?
Here is OSHA’s new Electric Power Generation, Transmission, and Distribution rule..
Has OSHA created compliance aids for the new rule?
There’s a helpful webpage, a fact sheet, an FAQ, and a minimum approach distance calculator. Stay tuned for more, too.
Who has to comply with 1910.269?
Employers that operate or maintain electric power generation, transmission, or distribution lines or equipment.
Who has to comply with Subpart V?
Employers with employees who perform construction work on electric power transmission or distribution lines or equipment.
In terms of compliance with Subpart V, what does “construction work” mean?
OSHA notes that “construction work” includes the erection of new electric transmission and distribution lines and equipment and the alteration, conversion, and improvement of existing transmission and distribution lines and equipment.
What more can you tell me about the required Transfer of Information from Host to Contractors?
Well, let’s define some terms first, shall we?
A host employer is an employer that operates, or that controls the operating procedures for, an electric power generation, transmission, or distribution installation at which a contract employer is performing work covered by the standard. The host employer DOES NOT HAVE TO BE the entity that hired the contract employer.
A contract employer is an employer, other than a host employer (above), that performs work covered by the standard under contract.
What must a host employer tell the contract employer before work begins?
According to the new electric power generation, transmission, and distribution rule, before work begins the host employer must inform the contract employer of:
- The following characteristics of the host employer’s installation when they are related to the safety of the work to be performed–nominal voltages of lines and equipment; the maximum switching-transient voltages; the presence of hazardous induced voltages; the presence of protective groups and equipment grounding conductors; and the locations of circuits and equipment, including electric supply and communication lines and fire-protective signaling circuits
- The following conditions when they are related to the safety of the work to be performed and known to the host employer–the condition of protective groups and equipment grounding conductors, the condition of poles, and environmental conditions relating to safety
- Information about the design and operation of the host employer’s installation that the contract employer needs to make the assessments required by the standard
- Other information about the design or operation of the host employer’s installation that is (1) known by the host employer, (2) requested by the contract employer, and (3) related to the protection of the contract employer’s employees.
What information must a contract employer provide to the host employer before work begins?
Before work begins, the contract employer must advise the host employer of any unique hazardous conditions posed by the contract employer’s work. Also, the contract employer must advise the host employer of any unanticipated hazardous conditions found, while the contractor’s employees are working, that the host employer did not mention; the contract employer must provide this information to the host employer within 2 working days after discovering the hazardous condition.
Is the host employer now required to supervise contract employers’ employees or report observed violations of the standard?
No, but see the discussion of the information-transfer provisions in Section V of the Federal Register notice for a more complete explanation of host-employer responsibilities.
Do the contract employer’s employees have to follow the host employer’s work rules?
No, but the host employer and contract employer must coordinate their work rules and procedures so that each employee of the contract employer and the host employer is protected as required by the standard.
What about the fall protection provisions?
Some of the more common questions are answered below.
What different types of fall protection equipment does the standard require?
Depending on the circumstances, the standard requires one of three types of fall protection:
- Personal fall arrest system. A system used to arrest an employee in a fall from a working level.
- Fall restraint system. A fall protection system that prevents the user from falling any distance.
- 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.
What forms of fall protection must employers use to protect employees working from aerial lifts?
The standard requires employers to protect an employee working from an aerial lift using one of the following:
- A personal fall arrest system, or
- A fall restraint system.
What forms of fall protection must employers use to protect employees working from a pole, tower, or similar structure?
The standard requires employers to protect an employee working at heights of more than 1.2 meters (4 feet) on a pole, tower, or similar structure using one of the following, as appropriate:
- A personal fall arrest system,
- Work-positioning equipment,
- A fall restraint system, or
- Other fall protection meeting Subpart D of OSHA’s general industry standards or Subpart M of OSHA’s construction standards, as applicable. A guardrail system meeting one of those standards is an example.
Must qualified employees climbing or changing location on poles, towers, or similar structures use fall protection?
Generally yes. Starting April 1, 2015, the standards require qualified employees climbing or changing location on poles, towers, or similar structures to use fall protection, unless the employer can demonstrate that climbing or changing location with fall protection is infeasible or would create a greater hazard than climbing or changing location without it. (Note that “climbing” includes going up or down the pole, tower, or other structure.)
What about the minimum approach-distances?
Common questions about the minimum approach distances are listed (and answered) below:
How does the standard set minimum approach-distance requirements?
The standards require the employer to establish minimum approach distances that employees must maintain from exposed energized parts. The employer must base those distances on formulas set by the standard or follow default minimum approach-distance tables contained in the standard.
How does the standard treat maximum transient overvoltages?
No later than April 1, 2015, for voltages over 72.5 kilovolts, the employer must determine the maximum anticipated per-unit transient overvoltage, phase-to-ground, through an engineering analysis. Alternatively, the employer may assume a maximum anticipated per-unit transient overvoltage, phase-to-ground, in accordance with the following table:
| Voltage Range (kV) | Type of Current (ac or dc) | Assumed Maximum Per-Unit Transient Overvoltage |
|---|---|---|
| 72.6 to 420 | ac | 3.5 |
| 420.1 to 550.0 | ac | 3.0 |
| 550.1 to 800.0 | ac | 2.5 |
| 250 to 750 | dc | 1.8 |
Does OSHA provide guidance on establishing minimum approach distances?
Yes. Appendix B to the standard provides tables listing minimum approach distances for conditions common in electric power transmission and distribution work. Employers may use these tables to establish minimum approach distances under the exposure conditions covered by the tables. (Note that the final rule permits employers to continue to use the minimum approach distances in the old standards until March 31, 2015.) In addition, Appendix B provides guidance on:
- How to comply with the minimum approach-distance requirements in the standard,
- How to use portable protective gaps to limit maximum transient overvoltages at the worksite and thereby reduce minimum approach distances, and
- How to calculate minimum approach distance when employers use portable protective gaps.
And, in addition to that, OSHA has provided an online minimum approach distance calculator.
What requirements does the standard adopt for employees who are unprotected from energized parts?
The standards contain two requirements related to employees working near energized parts without electrical protective equipment or live-line tools:
When an employee uses rubber insulating gloves or rubber insulating gloves and sleeves as insulation from energized parts, the employee:
- Must put on the gloves and sleeves in a position where he or she cannot reach into the established minimum approach distance, and
- May not remove the rubber insulating gloves and sleeves until he or she is in a position where he or she cannot reach into the established minimum approach distance.
When an employee performs work near exposed parts energized at more than 600 volts, but not more than 72.5 kilovolts, and is not wearing rubber insulating gloves, being protected by insulating equipment covering the energized parts, performing work using live-line tools, or performing live-line barehand work, the employee must work from a position where he or she cannot reach into the established minimum approach distance.
What about the arc-flash protection provisions?
Common questions and their answers are immediately below.
What must an employer do to protect employees from hazards posed by flames and electric arcs?
In general, the employer must:
- Assess the workplace to identify employees exposed to hazards from flames or from electric arcs;
- Make reasonable estimates of the incident heat energy of any electric-arc hazard to which an employee would be exposed;
- Ensure that employees exposed to hazards from flames or electric arcs do not wear clothing that could melt onto their skin or that could ignite and continue to burn when exposed to flames or the estimated heat energy;
- Ensure that the outer layer of clothing worn by an employee is flame resistant under certain conditions; and
- With certain exceptions, ensure that employees exposed to hazards from electric arcs wear protective clothing and other protective equipment with an arc rating greater than or equal to the estimated heat energy.
What are the deadlines for compliance with the arc-flash protection requirements?
The employer must assess the workplace for arc-flash hazards by the effective date of the final rule. In addition, the employer must ensure that employees do not wear clothing that could melt onto their skin or that could ignite and continue to burn by the effective date of the final rule. By January 1, 2015, the employer must make reasonable estimates of incident energy. Finally, the employer must provide protective clothing and other protective equipment meeting the arc-flash protection requirements of the final rule by April 1, 2015.
Must employers pay for the flame-resistant and arc-rated clothing and other arc-flash protective equipment required by the standard?
Yes. As required by OSHA’s general rules on employer payment for personal protective equipment (29 CFR 1910.132(h) and 29 CFR 1926.95(d)), employers must pay for the flame-resistant and arc-rated clothing and other arc-flash protective equipment that the electric power generation, transmission and distribution standards require.
Has OSHA provided any guidance on how to how to perform the required assessment and how to estimate incident heat energy?
Yes. Appendix E to the standard provides tables listing incident heat energies for common exposures found in electric power transmission and distribution work. Employers may use these tables to estimate incident heat energy under the exposure conditions covered by the tables. In addition, Appendix E provides guidance on:
- How to assess the workplace for flame and electric-arc hazards;
- Selecting a reasonable incident-energy calculation method under various conditions;
- Selecting reasonable parameters for use in calculating incident heat energy, including:
- Selecting a reasonable distance from the employee to the arc, and
- Selecting a reasonable arc gap.
Has OSHA provided any guidance on how to select the protective clothing and equipment required by the standard?
Yes. Appendix E to the standard provides guidance on:
- How to select clothing that does not ignite,
- How to select protective clothing with an acceptable arc rating, and
- When the standard requires arc-rated head and face protection.
Source for above section: OSHA FAQ
Hope that helps. Let us know if you have questions or comments, or if you foresee any particular challenges you’ll face as you try to comply with these new regulations.
