Vertical Hazards in Power Generation, Transmission and Distribution

OSHA CFR 1910.
269 Final Rule 2015:

Vertical Hazards in Power Generation,
Transmission and Distribution
29 CFR 1910.269, Electric Power Generation, Transmission, and Distribution intends to reduce
electrical hazard risk to workers, not only within the electric utility industry, but also within
other facilities that operate and maintain transmission and distribution systems. In 2014, OSHA
(Occupational Safety and Health Administration) published the 1910.269 final rule revision to
this 40-year-old standard to enhance clarity and reflect changing times. Dierences between
OSHAs rules for general industry and for construction have been streamlined to be much
more consistent.
In order to resolve outstanding matters, OSHA delayed compliance deadlines for certain
requirements until 2015 and are now in eect. New and revised requirements include:
Host employer and contract employer exchange of safety-related information
Minimum approach distances
Arc-flash protection
Fall protection
Establishing a relatively safe working environment from the outset is addressed in part via
mandated communication among host employers, contract employers and employees.
Engineering analyses are required to determine minimum approach distances in proximity to
high-voltage environments. Arc hazard heat energy estimates must be calculated in order to
provide arc flash-rated personal protective equipment to workers at risk. Fall protection is
addressed not only as it relates to free fall distance, but also to climbing on vertical structures
and vertical climbing systems.
This paper highlights certain portions of the final rule that are relevant to those working
within power generation, transmission and distribution systems. Italicized areas have been
quoted directly from the final rule.
Because every life has a purpose...

1910.269(A)(3) INFORMATION TRANSFER Work positioning equipment is defined as a body belt or
body harness system rigged to allow an employee to be
To improve overall workplace safety by requiring exchange supported on an elevated vertical surface, such as a utility
of safety-related information, host employers must inform pole or tower leg, and work with both hands free while
contract employers of certain information prior to start of leaning.
work, such as characteristics of the host employers installation All employees must use appropriate fall protection when
that are related to the safety of the work to be performed. they climb or change location on poles, towers or similar
Information is to be passed along to employees in a way structures. An exception is made in instances when use of
that enables compliance with the standard. fall protection is infeasible or creates a greater hazard than
climbing or changing location without it. The previous
1910.269(L)(3) MINIMUM APPROACH DISTANCES exemption allowing qualified employees to free-climb has
been removed.
To help safeguard unprotected workers from hazardous Addressed elsewhere in Subpart R are tethering, restraint
close proximity to energized lines and equipment, the final or travel restricting systems to hold workers in place. This
rule provides newly updated determination methods. fall protection system is meant to prevent user falls from
Concerning voltages higher than 72.5 kilovolts, employers any distance and consists of a body belt or body harness,
must determine the maximum anticipated per-unit transient anchorage, connectors, and other needed equipment.
overvoltage, phase to ground, through an engineering analysis
or assume a maximum anticipated per-unit transient
1910.269 (L) (8) PROTECTION FROM ELECTRIC ARCS
overvoltage, phase-to-ground, in accordance with Table R-9 or
Table V-8, [of the standard] respectively.
The standard now puts forth requirements for arc-rated fall
protection equipment. Fall arrest equipment must be able to
1910.269(G)(2) FALL PROTECTION
pass a drop test after arc exposure with heat energy of 405
cal/cm2 if workers using the equipment are exposed to
Two types of personal fall protection systems are addressed,
electric arc hazards. A common scenario for arc hazards
personal fall arrest systems and positioning device systems.
concerns bucket truck workers in close proximity to power
lines; fall protection personal protective equipment may be
A personal fall arrest system, consisting of an anchorage,
subject to arc flash exposure, potentially resulting in burns
connectors and body harness and may include a lanyard,
to the worker and compromised fall arrest capability, unless
deceleration device or lifeline, safely arrests a worker in a
it has been designed to withstand an arc flash.
fall from a working level on a horizontal or vertical surface.
The standard requires personal fall arrest systems to be
rigged such that an employee can neither free fall more than
6 feet (1.8 m), nor contact any lower level.
Employers must assess workplaces to determine those CONCLUSION
workers who are exposed to electric arc hazards.
OSHA had already recognized the need for work The final rule is likely to produce higher levels of worker safety
positioning equipment to pass a flammability test. by reducing the number of electrical shocks, burns, falls from
Under certain conditions, the outer layer of clothing worn heights, and other accidents, injuries and deaths associated
by employees must be flame-resistant. with power generation, transmission and distribution. OSHAs
revised standards are intended to provide consistent
In addition, employers must estimate incident heat energy
requirements for work performed within both construction
of arc hazards to which workers would be exposed, and
and general industry standards.
must provide those workers with protective clothing and
other protective equipment with an arc rating greater than or As part of implementation, OSHA suggests that employers
equal to the estimated heat energy. review the publication, Training Requirements in OSHA
Standards and Training Guidelines, Voluntary Training
CONDUCTIVITY Guidelines, Section III, to assess employee risk to electrical
hazards including electrical shock, arc flash or arc blast. OSHA
A subject that is prone to potential confusion for users of arc also references new 1910.269 Appendix E Protection from
flash fall protection equipment is conductivity, a separate Flames and Electric Arcs for guidance as to estimating
safety concern from that of arc flash protection. Arc flash available heat energy.
products are designed to resist high heat and energy.
Conductivity concerns a products ability to conduct For more information concerning OSHA CFR 1910.269, visit
electricity. Common methods used to reduce conductivity www.osha.gov/dsg/power_generation/.
of personal protective equipment include use of hardware
coated with PVC, thereby insulating metal hardware away For more information regarding MSA arc flash-rated fall
from workers. However, this practice may not eliminate protection products, visit www.MSAsafety.com.
all risk.
Neither OSHA nor ASTM F887 address electrical conductivity
of fall protection equipment as no formal test method exists.
Workers must also maintain minimum approach distances to
prevent workers from contact with energized sources. As a
result, exposed metal components such as D-rings and
buckles used on arc flash fall arrest equipment are still
common in the industry.
3
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OSHA CFR 1910.

269 Final Rule 2015:

Host employer and contract employer exchange of safety-related information

Minimum approach distances

Because every life has a purpose...

MSA: Because every life has a purpose.

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