Section /Subpart Title Goes V Amendments Here

Transcription

1 Section /Subpart Title Goes V Amendments Here SPRING OCCUPATIONAL SAFETY AND HEALTH COMMITTEE MEETING APRIL 27, 2015 PRESENTED BY Charles Kelly EEI (202) ckelly@eei.org Melissa Bailey Ogletree Deakins (202) Melissa.bailey@ogletreedeakins.com

2 Section /Subpart V April 11, 2014: New standards issued with July 10, 2014 effective date June 2014: EEI filed suit in federal court to challenge the validity of the standards; compliance delayed during settlement negotiations February 13, 2015: EEI & OSHA reached settlement agreement February 17, 2015: Compliance with some new provisions Other compliance dates pushed out

3 Negotiated Compliance Guidance Host-Employer Information Transfer Fall Protection Minimum Approach Distances Protective Clothing Underground Installation Training

4 INFORMATION TRANSFER

5 How to Transfer Information? Any communication method that effectively communicates the required information Oral communication: telephone, orientation, or meeting Written communication: , text, bid package or contract, accessible website Tagging or barricading system Maps

6 Transferring Information During an Emergency? Less formal communication methods may be appropriate Known information may be limited and may not be relevant given that the system is down Host employer must make reasonable effort to transmit required information as quickly as practicable after it becomes available

7 Coordination of Work Procedures Host and contractor must coordinate work rules and procedures so as to protect employees Includes discussions/coordination regarding how information will be exchanged

8 From Host Employer to Contractor

9 Information Categories Existing Characteristics: Static information known by host Known Conditions: Information host has regarding specific conditions relevant to contractor s work Assessment Information: Data contractors need to determine MADs and protective clothing and equipment Requested Information: Information relevant to job in host s possession

10 System Characteristics Nominal voltage Transient voltage Induced voltage Presence of grounds Locations of circuits and equipment How to communicate? Can be communicated once Notify contractor of changes ( Management of Change process)

11 Known Conditions Only if known: Condition of grounds Condition of poles Environmental conditions relating to safety

12 Communication methods Option to provide through instructions on how to access the information Maps Tags Barricades Accessing database

13 Safety-Related Environmental Conditions? Safety-related environmental conditions of electric lines and equipment Must be environmental conditions that affect worker safety and related to electric lines and equipment Examples Ground conditions that impact stability of poles Presence of coal dust or fly ash in generating plant

14 Assessment Information MADs Provide data contractor needs to calculate OR Provide MADs + Prerequisites for MADs to remain valid Heat energies Provide data contractor needs to estimate OR Provide estimated incident heat energies to which employees may be exposed

15 Requested Information Any other information about the design and operation of the host employer s installation that is known to the host employer, requested by the contractor, and related to safety of contractor employees Compliance Guidance: Only applies to work within the scope of the standard

16 Subcontractors Host employers may require contractors to provide information to subcontractors Host employer ultimately responsible for ensuring information communicated effectively to subcontractors

17 From Contractor to Host Employer

18 Information Categories Any unique hazardous conditions presented by its work Any unanticipated hazardous conditions found during work must report within 48 hours Compliance Guidance: Only applies to conditions related to electric lines and equipment

19 Line-clearance tree trimming Information transfer provisions apply Assessment information Section (l) does not apply to LCTTing FR clothing/arc-rated equipment provisions do not apply LCTT employers required to comply with MADs set out in tables no requirement to calculate MADs

20 Compliance Dates May 1, 2015: Host employers must provide contractors with information regarding the existing, safety-related characteristics of electric lines and equipment. Prior to July 1, 2015, not required to provide information on maximum switching-transient voltages. July 1, 2015: Host employers and contractors must comply with all of the information transfer requirements.

21 How will this play out? *** Melissa s personal opinion Host employers: Somewhat different types of information to contractors Generation: Capital projects or turnarounds more time for planning; environment easier to control Transmission: Capital projects; fairly sophisticated contractors; less involvement in how the work will be performed

22 How will this play out? Host employers: Somewhat different types of information to contractors Distribution: More troubleshooting work to go to contractor; can provide information through training, but some information inevitably provided on the fly Storm/Emergency Work: Some ability to provide system characteristics and similar information in advance, but job briefing process will be critical LCTTing: FR clothing/arc-rated equipment and MADs not at issue

23 How will this play out? Contract Employers Key issues Communicating/ translating information to EIC for job briefing purposes Identifying unanticipated hazards for host Formalizing communications to host employer on unique/unanticipated hazards Road map communication on how information transferred Don t drive yourself crazy not every communication can be documented

24 JOB BRIEFING

25 Job Briefing Employee in charge must receive transferred information before each job Can prior communications during a project meet the before each job requirement? Maybe Time between prior communication and present job Manner previous information communicated Similarity between jobs Whether additional or different information required

26 Job Briefing How must the information be provided to the EIC? Any method that effectively communicates information before work begins Communicating existing characteristics through training, safety manual, or written procedures effective until characteristics change Known conditions may be communicated by maps, tags, etc.

27 Job Briefing EIC must conduct at least one job briefing at the beginning of each day or shift EIC must organize, preside over, and lead the job briefing Other employees may present information during the job briefing May 1, 2015: Employers must comply with new job briefing requirements Staggered compliance dates not all information from host to contractor communicated until June 30, 2015

28 FALL PROTECTION

29 Fall Protection Systems Personal fall arrest system arrest fall from a working level Work-positioning equipment allows employees to be supported on elevated vertical surface Fall restraint system prevents user from falling any distance

30 Fall Arrest System Fall arrest equipment used by employees exposed to flames or electric arcs must be able to pass a drop test after exposure to a 40±5 cal/cm 3 arc Harnesses and shock-absorbing lanyards meeting ASTM F87-04 or later versions up to ASTM F comply with the drop test requirement

31 Fall Arrest System Fall arrest system must be rigged such that employees cannot fall to the lower level Lower level does not include Tree branches Utility line conductors or cables Tower legs, cross bracings, or lattice works found on towers, substation structures, or similar structures

32 Work-Positioning Equipment Includes work-positioning equipment used to climb towers or similar structures; when positioned in final position, secure positioning strap to work hands free on vertical surface Free climbing is prohibited unless infeasible or greater hazard Congestion or obstruction on pole Must consider devices that provide for continuous attachment and other conditions that cause employees to lose grip Does not apply once employee reaches work location June 1, 2015: OSHA will begin enforcing no free climbing requirements

33 Anchorage Points Prescribed anchorage strength for workpositioning device At least 2x load of employee s fall or 3000 lbs of force (whichever is greater) Prescribed anchorage used for attachment of fall arrest system 5000 lbs per employee attached, or designed system Independent of anchorage used for platforms

34 Anchorage Points Calculating strength of each potential anchorage point on a tower or steel/concrete pole not required May use recognized and generally accepted good engineering practices Visual inspection must be performed for anything that suggest strength criteria not met (e.g., corrosion or cracks) Substantially vertical structural support members on towers meet the strength without engineering analysis but visual inspection must be performed as necessary

35 Anchorage Points Fixed or detachable ladders on steel structures: Engineering analysis and visual inspection Cable-supported devices: Engineering analysis and visual inspection

36 Anchorage Points Wood-pole fall-restriction devices meeting ASTM F meet strength requirement Not required to calculate strength of each bolted attachment provided engineering analysis and visual inspection conducted Not required to contact third party that installed the anchorage unless the third party is a host employer or contractor for the particular project At work position, if not possible to use wood-pole fall-restriction device at anchorage and to assess the strength of the bolt attachment, the employer may rely on the bolted attachment as an anchorage without assessment

37 Anchorage Points What is an engineering analysis? Consider design specifications and maintenance procedures No anticipation that strength of individual anchorage points will be assessed from an engineering standpoint

38 Aerial Lifts Employees Only Permitted to Use: Personal Fall Arrest System with body harness (no body belt) or Fall Restraint System Enforcement delayed for line-clearance tree trimmers only until the beginning of next year LCTT employer must be actively working with manufacturer to pilot use of fall restraint systems

39 MINIMUM APPROACH DISTANCE

40 General Voltages at or below 72.5kv: MAD based on tables Voltages above 72.5kv: Engineering study to determine the maximum per-unit transient over voltage required Additional tests required if portable gaps used to limit voltages

41 Minimum Approach Distance What methods may be used to determine the maximum per-unit transient overvoltage? IEEE Std Other recognized and generally accepted good engineering practices Assume maximum per-unit transient overvoltage using Table R-9 or Table V-8. Engineering analysis may be conducted on a system or a per-line basis

42 Minimum Approach Distance Restrikes: Employers that takes measures to reduce the probability to negligible level do not have to consider restrikes in calculating maximum transient overvoltage Prestrikes: Currently no evidence indicating whether prestrikes do or do not have effect on maximum transient overvoltages. Employers will likely conclude prestrikes have no meaningful effect OSHA may revisit once new industry standards issued

43 Compliance Dates April 1, 2015: For voltages of 5.1 kilovolts and more, employers must comply with the minimum approach distances set forth in Table R-3. February 1, 2016: For voltages of kilovolts and more, employers must determine the maximum anticipated per-unit transient voltage. Until the enforcement date, may use Tables 6, 10, 11, 12, or 13 in Appendix B of standard. February 1, 2016: For voltages of 72.6 to 169 kilovolts, employers must determine the maximum anticipated perunit transient overvoltage. Until the enforcement, OSHA will not issue citations if the employer assumes a maximum anticipated per-unit transient overvoltage, phase-to-ground, of 3.0 per unit. If no peer reviewed guidance (IEE516) by May 1, OSHA will extend dates further

44 PROTECTIVE CLOTHING

45 Incident Energy Estimates Employers must perform workplace assessment to identify employees exposed to flame and arc hazards. Employers must estimate incident heat energies to which employees may be exposed

46 FR Clothing Whole-body FR clothing required under the following conditions: Exposure to contact with energized circuit parts operating at more than 600 volts Possible for electric arc to ignite flammable material in the work area Possible for molten metal or electrical arcs from faulted conductors in work to ignite employee s clothing Estimated heat energy exceeds 2.0 cal/cm 2

47 Arc-Rated Equipment If exposure to estimated incident heat energy greater than 2.0 cal/cm 2, employee must wear arc-rated clothing on entire body except: Hands: Rubber Insulating Gloves or Leather Gloves & estimated incident energy equal to or less than 14 cal/cm 2 Feet: Heavy-duty footwear

48 Arc-Rated Equipment If exposure to estimated incident heat energy greater than 2.0 cal/cm 2, employee must wear arcrated clothing on entire body except: Head: Hard hat worn and est. incident energy is Less than 9 cal/cm 2 for single-phase arcs in open air Less than 5 cal/cm 2 for other exposures Includes employees placing and removing meters behind a meter shield that reduces the incident energy exposure to less than 5 cal/cm 2

49 Arc-Rated Equipment Head & Face Hard hat + face protection with minimum arc rating of 8 cal/cm 2 for single-phase arcs in open air or 9 cal/cm 2 for other exposures Single-phase arcs in open air can deduct 4 cal/cm from the estimated heat energy for purposes of determining required protection

50 Undergarments Employees exposed to the hazards from flames or electric arcs cannot wear clothing that could melt on their skin or that could ignite and continue to burn when exposed to flames or the estimated heat energy. Compliance Guidance Elastic in underwear and socks cannot be exposed to heat energy that would cause the elastic to melt Underwear and socks cannot contain, alone or in blend, acetate, nylon, polyester, rayon, and polypropylene

51 Compliance Dates April 1, 2015: Calculate reasonable estimate of incident heat energy from electric arc April 1, 2015: Provide most protective clothing and equipment and FR pants 11 oz. or more September 1, 2015: Protective clothing or equipment rated higher than 8 cal/cm 2

52 Compliance Dates September 1, 2015 No citations for failing to wear FR pants if: 1) 11 oz or heavier weight cotton pants and pants on order No citations for protective clothing/equipment if equipment on order

53 Compliance Dates Contractor can demonstrate that it has not received the assessment information from host employer no citations until September 1, 2015 for: Failing to perform estimates Failing to wear FR pants (as long as 11-oz or heavier cotton pants) Failing to wear equipment with appropriate rating

54 Compliance Dates Will the host be cited for failing to provide information for heat energy estimates? YES Host has until June 30, 2015 to provide this information What happens on July 5, 2015? Host cited for not providing the information; contractor is not cited What happens on September 6, 2015? Host and contractor cited (what is contractor s remedy here?)

55 UNDERGROUND INSTALLATIONS

56 Moving Cables Employees must inspect energized cables for abnormalities before moving Where a cable in a manhole or vault has abnormalities that could lead to a fault, cable must be deenergized before any employee may work in the manhole or vault Exception: Service-load conditions and a lack of feasible alternatives require that the cable remain energized

57 Protection Against Fault Indications of impending faults (not new) Oil or compound leaking from cable or joints, Broken cable sheaths or joint sleeves, Hot localized surface temperatures of cables or joints, or Joints swollen beyond normal tolerance

58 Energized Cables What type of inspection must be conducted? External inspection to detect conditions listed in standard. Not required to remove arc-proofing tape, duct work, concrete, asphalt or similar material from a cable. If one of the conditions found, the abnormalities must be treated as an indication of an impending fault.

59 Energized Cables Must the employer calculate the estimated heat energy exposures for employees who conduct cable inspections? OSHA does not anticipate that the inspections will expose employees to electric arc hazards Employers must conduct the initial assessment to determine whether employees are exposed to hazards from flames or electric arcs, but OSHA believes there will not be exposure

60 Energized Cables Employers required to deenergize cables when there is a reasonable possibility that performing the work could cause a fault Reasonable possibility of a fault if work practices used could: Penetrate cable Could place other damaging stresses on the cable jacket or insulation (e.g., bending cable at an extreme angle)

61 Energized Cables Not a reasonable possibility of a fault for the following work: Qualified employee removing arc-proof covering or similar materials from energized cable for cable identification and other purposes as long as the cable exhibits no visible abnormalities and the removal imposes no damaging stress on the cable or insulation jacket Qualified employee slicing through or chipping duct work, concrete, asphalt or similar material with hand tools or power tools using technique that prevents penetration of cable as described in compliance guidance New provisions went into effect on February 28, 2015

62 TRAINING

63 General Training for all employees must cover Safety-related work practices Safety procedures Other safety practices including emergency procedures Degree of training = employee s risk for hazard involved What must employers do to ensure employees receive the proper degree of training? Refer to OSHA s Training Requirements in OSHA Standards and Training Guidelines Not a significant change

64 Qualified Employee Training Qualified Person Training Must Cover: Distinguishing exposed live parts from other electric equipment Nominal voltage of exposed live parts Minimum Approach Distances Proper use of safety techniques and equipment Recognition of electrical hazards and protective techniques

65 Training Compliance Guidance Employers are not required to provide employees with training regarding hazards that do not pertain to their job duties Training requirements not applicable to employees that do not perform work covered under the standard No specific methods required to evaluate employee proficiency in the practices before the employee completes training.

66 Computer-Based Training CBT may be used in any format as effective as traditional classroom training (i.e., interactive, opportunity to ask questions and receive responses during training) Distribution of training materials as an intro or part of classroom or on-the-job training. Employees must have opportunity to ask questions about the materials during training.

67 Previously Trained Employees Proficiency of previously trained employees may be established as follows: Confirm prior training; Test or interview to determine that the employee understands safety-related practices and; Supervise employee closely until the employee has demonstrated the required proficiency Compliance Guidance: 3-step process is not mandatory

68 First Aid Training Employees must receive retraining on safety-related work practices that are performed less than once per year Employees not required to formally recertify first aid training every year Employee must have the opportunity to refresh and demonstrate proficiency in first aid skills each year Written test Verbal exchange between employee and supervisor Any other method that reminds employees of first aid fundamentals

69 Melissa A. Bailey Ogletree, Deakins, Nash, Smoak & Stewart, P.C K Street, NW, Suite 1000 Washington, DC melissa.bailey@ogletreedeakins.com