A few years ago I came upon a crew using 6-inch chocks to hold back a 38-ton crane truck. I told the crew I was happy that they were making an effort at compliance, but I had to ask them, “Why do we place chocks under a truck’s wheels? Is it to comply with our safety rules or to keep the crane from running away?” It was obvious to me that the short chocks would not hold the crane. The driver proved my assumption true a few minutes later. From the cab, with the transmission in neutral, he released the parking brake. The crane easily bounced over the chocks and, unfortunately, hit my pickup truck.
Sometimes I ask similar questions about grounds installed during stringing. That’s because it seems we do not pay as much attention to the value of grounding as we do to the perceived value of an act of compliance. Grounding during stringing plays a very important role in protecting workers; however, that’s only the case if we know why we are grounding and then install grounding so that it does what we want it to do.
A Change to the Rules
There was a change in the 2014 revision to OSHA 29 CFR 1910.269 that went largely unnoticed. The change to 1910.269(q)(2) removed language that dictated locations for temporary grounds used during stringing of conductors in an energized environment. Not only did OSHA remove the specific language that required grounds at break-overs, at energized crossings and no more than 2 miles apart, but the agency also removed all of the descriptive terms regarding placement of the grounded traveler, such as “either side of an energized crossing and both sides of a crossing that was de-energized and grounded.” Removing the specific language doesn’t mean you don’t have to ground. The industry recognizes that the use of temporary protective grounds prevents injury and loss of life during unanticipated incidents. The standard still has specific performance language that can only be met by the installation of temporary protective grounds. Rule 1910.269(q)(2)(ii) refers the employer to 1910.269(p)(4)(iii) for accepted methods used to protect employees. Rule (p)(4)(iii) is the grounding/barricading/insulating requirement for protection of personnel from equipment contacts.
It is most likely that part of the reason why the language was deleted was to stay within OSHA’s mission of using performance-based language to tell employers what they must accomplish, not how to accomplish it. In addition, OSHA probably realized that in the variety of conditions that exist in the utility world, there is no one simple formula sufficient to establish effective grounding for every scenario, although the agency’s old language was close.
OSHA’s former instructions for grounding were largely based on the consensus standard IEEE 524, “IEEE Guide for the Installation of Overhead Transmission Line Conductors.” IEEE 524 is listed as a reference document in Appendix G to 1910.269. Unlike adopted consensus standards, which have the weight of an enforceable OSHA standard, reference documents are tools an employer can use to develop compliance procedures. The introduction to Appendix G explains it this way: “The references contained in this appendix provide information that can be helpful in understanding and complying with the requirements contained in § 1910.269. The national consensus standards referenced in this appendix contain detailed specifications that employers may follow in complying with the more performance-based requirements of § 1910.269. Except as specifically noted in § 1910.269, however, the Occupational Safety and Health Administration will not necessarily deem compliance with the national consensus standards to be compliance with the provisions of § 1910.269.”
There is nothing complicated about reference standards. IEEE 524 is full of “may” and “should” recommendations. It is a useful tool, especially for individuals developing training and employers developing written work procedures to standardize operations. IEEE 524 is not a training program for employers new to the work. From the employer/compliance perspective, whether or not you use the IEEE standard, you should know what it says. And if you don’t follow the recommendations, you should have a reason why. That is because when OSHA is required to examine an employer’s operation – say, as part of an investigation – they will compare the consensus standard to your work practices and training. Any reference standard like IEEE 524, as a recognized standard published by the industry, is a basis for OSHA to cite an employer that lacks defensible training and procedures. If the agency decided the employer was negligent based on information they reviewed in IEEE 524, they would issue a General Duty Clause citation. In most cases when OSHA has done so, the agency has used language similar to the related standard, if not exactly.
Continue reading at Incident Prevention
For more on safety in the utility industry, check out Five Core Capacities for Sustainable Safety Excellence, Are You Making These 5 Heat Related Illness Mistakes?, and Using FR and AR Clothing to Mitigate Cold Stress.
