LOCAL 1245 SAFETY REPORT:
PEER-TO-PEER PRESENTATIONS WELL RECEIVED
By Ralph Armstrong
The Hold the Pull committee has completed 12 of the scheduled 22 presentations around the PG&E system. Due to storm work we have had to cancel and reschedule presentations several times.Presentations have been generally well received. We hope to have all presentations completed sometime in May.
Safety Steward appointments and training are next on the agenda. Business Manager Tom Dalzell has had initial discussions to start developing a similar program in PG&E’s Gas Department. We expect to bring in a group of members to start developing this in the near future.
Cranes and Derricks
Since the Jan. 20 CalOSHA public hearing in San Diego pertaining to CalOSHA’s proposed new crane standard there is no new information to report. The new standard is mandated by Fed OSHA who on November of 2010 implemented it own crane standard for the construction industry. Typically state plans have 180 days to write or modify rules that comply with new Federal requirements, which would put CalOSHA in the May timeframe to address them. Any new requirement on certification will not be required until 2014 per the federal requirement unless CalOSHA dictates it be sooner
The other issues that will also need to be addressed is the qualified rigger and signal person requirement which became effective in November as well with an immediate implementation date. Again look for this requirement to be mandated by CalOSHA around the May timeframe which is the same 180 day requirement.
OSHA, the federal agency in charge of investigating the Biedinger fatality because it was on Indian land, has issued three serious citations in connection with the fatality totaling $21,000.
Gerald Biedinger, a T&D Equipment Operator, was fatally electrocuted in Tuolumne, Ca. on Aug. 20, 2010 when the Highway Digger he was operating came in contact with an energized 17 kV line. Each citation carried a penalty of $7,000. They included one for violation of the MAD, one for not having the vehicle wheels chocked and one for not performing a proper hazard assessment on the site.
OSHA also, instead of invoking the General Duty Clause which states that the employer shall furnish its employees a safe place to work free of hazards, issued two letters under this clause with recommendations for abating future citations based on things they discovered during their investigation.
The first letter involved the umbrella that was used to block the sun. This umbrella also blocked the view of the operator while he was raising and lowering his boom. The recommendation is to have the umbrella removed.
The second letter pertained to having the employee exposed to electric shock by not having the equipment grounded to earth when working in the vicinity of electric power lines. The recommendation is to have the vehicle grounded to earth when the safe working distance to electric power lines can be encroached upon.
New PGE Rain Gear
There are 1,100 sets of the new Omega 3 rain gear being used in wear trials this year. If this new rain gear receives good feedback this will take care of the rain gear issues we have seen over the last couple of years. If not the company has stated they will move to the old rain gear which did not leak, however was not breathable and caused the workers to sweat.
There has also been some misinformation being passed along pertaining to the new Omega 3 gear and the ability to use it as a second layer for FR protection. This information is false. In order for any piece of FR Clothing to be considered for layering purposes the company must perform tests with each clothing combination to verify the actually level of protection that is being offered.
It is important for everyone to know that the only combination of clothing allowed for layering is what has been approved by PG&E. If there are any questions pertaining to these requirements you should verify with the company what combinations are allowable.
PG&E Commercial Driver Fatigue Management Policy
Since the state of California followed the Federal Motor Carrier Safety Policy and eliminated the Hours of Service requirement there has been some confusion on what the requirements are now. Although the requirements are no longer there each carrier or utility is still required to manage their own drivers so they do not become a hazard to themselves or the public. PG&E has done so by implementing their own Commercial Driver Fatigue Management Procedure titled: Utility Procedure: TRAN 2001P-01 Effective: 04/01/2010
It is important for not only the employee to know what these requirements are but their supervisor as well so they do not assign any work that could violate these policies. There still are exemptions for emergency work.
The General Instructions state:
An employee holding a commercial driver license (CDL) must not operate a motor vehicle, nor must a supervisor require or permit a CDL driver to operate a commercial regulated vehicle, while the driver’s ability or alertness is so impaired, or so likely to become impaired through fatigue, illness, or any other cause, as to make it unsafe to begin or continue to operate a motor vehicle.
If there are any questions about this policy please refer to the above document.
Setting Poles around energized voltages in excess of 21,000 volts
Some questions were raised recently about setting poles around lines and equipment that are operating at transmission voltages. An example given would be to set a new pole that had the potential to violate the Minimum Approach Distance of an 115kV line. CalOSHA states in
§2941. Work on or in Proximity to Overhead High Voltage Lines:
(f) Working on Conductors or Equipment Energized at 600 Volts or More.
(1) Employees shall not be permitted to touch or work on exposed energized conductors or equipment except when wearing suitable insulating gloves with protectors, or when using other suitable devices. Only rubber gloves labeled as being manufactured and tested to meet ASTM D120-95, Standard Specification for Rubber Insulating Gloves, for the potential voltage exposure shall be used. Rubber gloves shall not be considered suitable devices when working on conductors or equipment energized in excess of 21,000 volts.
While it is important to know what the maximum allowable voltage insulating equipment is allowed to be used on, it should never be the primary source of protection especially when it comes to transmission voltages. The Safe Minimum Approach Distance specified by OSHA or company policy should be the primary focus. Specific work practices that can keep the employee from touching poles or equipment such as ropes or rated insulated tools. If there is a possibility of the pole violating these minimum approach distances on transmission voltages, or if you feel the work is unsafe to perform under energized conditions, a clearance is always an option. As always when in doubt or there is some uncertainty about the requirements, stop work and discuss the particular job and safety precautions with the company’s safety office or work methods group.
CalOSHA Proposed change to the purchase requirement of specific types of PPE
CalOSHA has a proposed change to the requirement of employers to purchase specific items of PPE which is modeled after the current federal OSHA standard which was released around three years ago. This is somewhat of a takeaway from the current CalOSHA requirement, which has been in place for several years based on a California Supreme Court decision that requires the employer to purchase all PPE. If this is passed, I am not sure how much of an impact it will have on our employers and members yet. I have been following this closely and have provided some comments, particularly on the FR Clothing issue and have received comment back from the Standards Board, as follows:
Mr. Ralph M. Armstrong, Business and Safety Representative, IBEW Local 1245 by e-mail transmission to the Standards Board received on March 1, 2011.
Mr. Armstrong expressed concern over whether exception No. 5 (he apparently means exception No. 4) would exclude employers from having to pay for fire resistant clothing worn by electrical workers exposed to the hazard of arc flash while performing their daily duties.
Exception No. 4 is intended to address items which do not fall under the classification of personal safety devices and safeguards necessary to protect the worker mentioned in General Industry Safety Orders (GISO), Article 10. The items described in Exception No. 4 refer to articles of clothing/apparel and personal belongings such as skin creams, ordinary sunglasses, and suntan lotion which have no special employee protection function and would not be considered a safety device or safeguard required under Article 10. Consequently, non synthetic apparel as required by the Electrical Safety Orders for employees who are exposed to arc flash or flames per Sections 2320.2 (a)(8) and 2940.6(j) are considered personal devices/safeguards which employers will continue to have the duty to pay.
The Board thanks Mr. Armstrong for his comment and participation in the Board’s rulemaking process.
The proposed language is:
Amend Article 10 to add new Section 3380.1 to read:
§ 3380.1. Employer Duty to Pay for Personal Safety Devices and Safeguards.
Whenever any safety order in Division 1 of Title 8 requires the provision, furnishing, use or wearing of any safety device and/or safeguard, it shall mean that the safety device and/or safeguard shall be provided at no cost to the employee.
- Non-specialty safety toe-protective footwear (including steel-toe shoes or steel toe boots) and non-specialty prescription safety eyewear when the employer permits such items to be worn off the job-site.
- Metatarsal guards when shoes or boots with built-in metatarsal protection is provided by the employee and used with the employer’s permission.
- Logging Boots (calked boots or lug-soled boots) when required by Section 6254 of the Logging and Sawmill Safety Orders.
- Everyday clothing such as long-sleeve shirts, long pants, street shoes, normal work boots, ordinary clothing, skin creams, or other items used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen.
- Personal protective equipment and safeguards that are intentionally damaged or lost by the employee.
- Where an employee provides adequate protective equipment he or she owns and which meets the requirements of Section 3380(d) of these Orders. the employer may allow the employee to use it and is not required to reimburse the employee for that equipment. The employer shall not require an employee to provide or pay for his/her own PPE, unless the PPE is excluded by exceptions 1-5.
Troubleman Work Jurisdiction and Safety
A concern was raised over the installation and testing practices on some equipment in the field such as regulators. It appears there is some inconsistency in different areas as to who performs the testing and placing this equipment in service. There were 2 different issues one of which is a work jurisdiction issue and one is a safety issue. The company has committed to addressing these safety concerns. This appears to have been addressed in some areas but possibly not in all areas.
LOCAL 1245 SAFETY AND HEALTH COMMITTEE
The Local 1245 Safety and Health Committee met on March 17, 2011 at Weakley Hall in Vacaville. Committee members present were: Michael Gomes, Joe Joaquim, Sergio Munez, Art Torres, Al White and Ralph Armstrong. Committee member absent: Dan Boschee and Dane Moore.
During this meeting all the above items were discussed at length.
There are two new Local 1245 Safety Committee members. Dane Moore replaces Robert Burkle, who retired in December, and Joe Joaquim to replace Darryl Rice, who stepped down.
100% Fall Protection on Wood Poles
This was a general topic at this meeting and has been something controversial for several years now. The reason for the discussion was that some companies, both utility and contractors, are moving in that direction and we are sure to face several questions and resistance to this.
This movement has been going on for several years now starting in Canada and the Northeast and has been working its way west through the states. Just a couple of years ago there were only 2-3 manufactures that made safety straps such as the Bucksqueeze that cinched themselves to the pole when a climber cut out. Now there are several manufactures with these types of devices.
Low Voltage (600V or less) Lock Out Tag Out vs. Clearance Procedures
There was a question/concern pertaining to obtaining a clearance when working on the low side of a transformer in a substation, 600 volts or less.
With any work on electrical systems it is important to know that under CalOSHA law you either have to de-energize low voltage systems and lock them and tag them out or work them energized. What a lot of people don’t realize is it is against CalOSHA law to work on systems energized at any voltage with their barehand or leather gloves which can be found below under 2320.2 Energized Equipment or systems. Included below are the requirements under CalOSHA for both energized and de-energized work requirements under the Low Voltage Electrical Safety Orders:
All electrical equipment and systems shall be treated as energized as required by Section 2320.2 until tested or otherwise proven to be de- energized.
§2320.4. De-Energized Equipment or Systems.
(a) An authorized person shall be responsible for the following before working on de-energized electrical equipment or systems unless the equipment is physically removed from the wiring system:
(1) Notifying all involved personnel.
(2) Locking the disconnecting means in the “open” position with the use of lockable devices, such as padlocks, combination locks or disconnecting of the conductor(s) or other positive methods or procedures which will effectively prevent unexpected or inadvertent energizing of a designated circuit, equipment or appliance. Note:See also Section 3314 of the General Industry Safety Orders (GISO) for lock-out requirements pertaining to the cleaning, repairing, servicing and adjusting of prime movers, machinery and equipment.
Exception: Locking is not required under the following conditions: (A) Where tagging procedures are used as specified in subsection (a)(3), and (B) Where the disconnecting means is accessible only to personnel instructed in these tagging procedures.
(3) Tagging the disconnecting means with suitable accident prevention tags conforming to the provisions of Section 2320.6 and GISO Section 3314(e).
(4) Effectively blocking the operation or dissipating the energy of all stored energy devices which present a hazard, such as capacitors or pneumatic, spring-loaded and like mechanisms
§2320.2. Energized Equipment or Systems.
(a) Work shall not be performed on exposed energized parts of equipment or systems until the following conditions are met:
(1) Responsible supervision has determined that the work is to be performed while the equipment or systems are energized.
(2) Involved personnel have received instructions on the work techniques and hazards involved in working on energized equipment.
(3) Suitable personal protective equipment and safeguards (i.e., approved insulated gloves or insulated tools) are provided and used. (EITHER OR BUT ONE OR THE OTHER MUST BE USED)
Exception: The use of approved insulating gloves or insulated tools or other protective measures are not required when working on exposed parts of equipment or systems energized at less than 50 volts provided a conclusive determination has been made prior to the start of work by a qualified person that there will be no employee exposure to electrical shock, electrical burns, explosion or hazards due to electric arcs.
(A) Rubber insulating gloves shall meet the provisions of the American Society for Testing Materials (ASTM) D 120-02a, Standard Specification for Rubber Insulating Gloves, and be maintained in accordance with ASTM F 496-02a, Standard Specification for In-Service Care of Insulating Gloves and Sleeves, which are hereby incorporated by reference. Note: The ASTM F 496-02a standard contains provisions regarding the care, inspection, testing and use of insulating gloves and sleeves. Among other requirements, this standard provides that electrical retests shall not exceed 6 months for insulating gloves and 12 months for insulating sleeves and that insulating gloves and sleeves that have been electrically tested but not issued for service shall not be placed into service unless they have been electrically tested within the previous twelve months.
(B) Insulated tools shall meet the provisions of the American Society for Testing Materials (ASTM) F 1505-01, Standard Specification for Insulated and Insulating Hand Tools, which is hereby incorporated by reference.
(4) Approved insulated gloves shall be worn for voltages in excess of 250 volts to ground.
(GLOVES ARE MANDATORY OVER 250VOLTS)
Any questions pertaining to these requirements should be addressed to the Local 1245 Safety Committee.
Forms and guidelines are on the website. Units should start using them as part of their unit meeting and submit them to this committee whether or not there are accidents or concerns. This should be a standard reporting practice at every unit meeting every month. All accidents reported this month on the green form as well as accidents reported at the safety committee meeting are listed below:
We have had several verbal reports on accidents and Near Misses, but very little in the way of official reports. We know these accidents took place but the particulars behind them remain unofficial so I will provide the basics:
- 1st Step construction apprentice rolled a vehicle down a steep embankment during storm restoration work earlier this month. No injuries were reported. It appears he may have fallen asleep at the wheel, but it is still under investigation
- We had a report of an incident in Placerville where a phase came down on a truck while closing the normal open switch on a single phase loop. We have not received anything from the company but have discussed with members. There were no reported injuries, but there appears to be some equipment damage. Again, no official report but it appears that the phasing was off when the line switch was closed, causing the wire to come down on a vehicle and setting it on fire. How the phases got swapped at the feeder pole was under investigation.
- Tree accidents. We had a report of two tree accidents over the last couple of months from two different tree contractors. One involved a vehicle going over with non-life threatening injuries to the employee in the basket. The other was an employee getting struck in the head with his saw and being knocked unconscious.
- We had also had a 5th step construction apprentice recently fall from a pole while transitioning around the telephone. He received a broken limb in lower leg area and was kept overnight for observation.
- Report of two separate instances where crews made contact with their equipment to energized lines causing line outages.
Ralph Armstrong is Senior Business Representative, IBEW Local 1245