Certainly to the layman, medium voltage (601V to 2,000V) and high voltage (greater than 2,001V) work seems extremely dangerous, and in some cases that’s true. However, implementation of safe work practices, and improvements in safety equipment have made this work relatively safe. Many utility contractors employ stringent work rules which already comply with (and exceed) OSHA regulations. The following are highlights of some of the more important OSHA regulations for line work found under the “Power Transmission and Distribution” subpart of the Code of Federal Regulations.

Before any work can begin, OSHA requires a thorough assessment of the area to determine what parts are energized, the condition of poles, hardware, and equipment. This survey shall include any affected peripherals such as fire alarm, phone, or cable TV lines.

Workers then approaching a work area must maintain minimum clear distances from energized parts with a phase-to phase potential of 2,100 volts or higher. This applies to any workers who are not completely isolated, and includes workers using “hot sticks” or other similar devices that are insulated. For instance, the minimum clear distance for energized parts from 2,100 volts to 15,000 volts is 2 ft. This distance increases slightly to 2 ft. 4 in. for voltages from 15,001 volts to 35,000 volts, and increases incrementally thereafter.

Workers will first usually put on their personal protective equipment. OSHA does require that all rubber equipment and live-line tools be visually inspected prior to use. In addition, rubber gloves in particular shall be “air-tested” prior to use.

Lines and equipment that are deenergized to be worked on can, in most cases, visually show that it’s disconnected from energized portions of the system. In cases where an item is not visibly open or visibly locked out, special care needs to be taken.

First, the line needs to be identified and declared deenergized by a designated worker. All switches that can supply power to the deenergized section shall be plainly tagged that men are working on the section. If switches can be locked out, or have their handles removed (or other similar action) this shall be done to assure the switches cannot be turned on. After all the above work is performed, the section shall be final tested to verify the section is deenergized. At that point protective grounds shall be installed, and then work may start. When attaching ground leads, start by attaching the lead to the ground point, then connect the other end with insulating tools or similar devices. Reversal of the above process is performed when reenergizing the section.

OSHA has a few general regulations for equipment use. For instance, a visual inspection and test of brakes and operating systems shall performed on all equipment at the start of the workshift. Hydraulic fluids used in Aerial lifts or similar equipment shall be of the insulating type- with fire-resistant characteristics of this fluid being exempted for this type of high voltage work. Arial lifts used near energized lines or equipment are required to be either grounded or barricaded. Equipment (such as cranes) without a voltage rating shall be kept clear of high voltage lines and equipment by 10 ft. (for 50,000 volts and less). Also OSHA prohibits line work under adverse weather conditions (especially high winds) except during emergencies.

There are many regulations OSHA has for line-stringing operations, however most of these regulations are covered by normal company work rules. OSHA does, however, require a briefing to be held before work starts which discusses the following topics:

• The type of equipment to be used.
• The grounding devices and procedures to be used.
• The crossover methods to be used.
• The clearance authorization(s) required.

When stringing operations are parallel to existing, energized lines, a competent determination needs to be made to ascertain if dangerous, induced voltage buildups can occur, especially during switching and ground fault conditions. If this is the case, the entire stringing operations require grounding until conductor installation is complete. The normal OSHA regulations also apply as to inspecting all equipment and line stringing accessories, etc. prior to use.

Working on live-line bare-hand work is a specialty in itself. OSHA requires any worker attempting this type of work to be thoroughly training prior to working on any energized circuits. Before working on live-line bare-hand work, the following items need to be determined:

• The voltage rating of the circuit on which work will be performed.
• The clearances to ground or other phases on which work will be performed.
• The voltage limitations of the aerial-lift equipment to be used.

All equipment used for this type of work shall be designed, tested and intended for live-line bare-hand work. One of the keys to this work is the insulating capacity of the aerial bucket arm. The ability of the aerial bucket to be completely isolated from any other voltage potential make this type of live-line bare-hand work possible. Before the start of the workday, when higher voltages are worked during the day, or any other factors develop that may change voltage conditions, the aerial bucket arm shall be physically tested. This test consists of placing the bucket arm in contact for three minutes with the voltage to be encountered during the work. Leakage tests shall be made during the three minutes. If more than 1 microampere/ kilovolt rating (between phases) is found, the bucket arm fails the test and shall not be used until repairs are made.

Once the aerial lift passes the test, work may then proceed only with personal supervision by a person trained and qualified in live-line bare-hand work. Again, this may be standard procedure to those familiar with live-line work, but OSHA does require the conductive aerial bucket liner to be bonded to the energized line being worked before the line is worked on. The worker is also similarly bonded to the liner with conductive shoes, or leg clips. This ensures the worker (isolated from ground or other phases) is at exactly the same voltage potential as the line, thereby making the live line safe to perform work on.

A careful assessment of the applicable regulations should be reviewed with your own safety procedures to assure compliance with OSHA regulations.

Training in the proper use and operation of the equipment used for material handling is an important part of an overall accident prevention program. The following are highlights of OSHA regulations for material handling equipment.

Forklifts and Industrial Trucks

Forklifts Multi-Employer Sites- Joint Liabilities

Most jobsites encountered have more than one contractor involved. If you’re the only contractor on a particular jobsite, and a CSHO [Compliance and Health Safety Officer] discovers violations, you would receive any citations and fines- simple.

However the way OSHA treats jobsites with more than one contractor may surprise you. For instance general contractors who disregard hazards created by other subcontractors onsite may find themselves with the same citation as well! In most cases, immediate [written if necessary] notification of any violations to the controlling contractor onsite to quickly eliminate the hazard will not only limit possible worker injury, but also prevent widespread citations passed out to all contractors onsite regardless of their perceived involvement.

Lets take a look at a hypothetical situation that could occur on a jobsite. Say a construction project has a construction manager and a general contractor. An excavation subcontractor opens up for an 8′ deep foundation, which is then poured. Before backfill is placed however, the plumbing contractor places a 2×10 board across the 8′ deep excavation for a walkway. Various subcontractors then walk across the board to gain access to the building interior to perform work. A CSHO observes the various trades crossing the makeshift ramp, contacts the construction manager, and conducts an inspection resulting in the citation of this single violation.

Question: Which contractors could be cited?
Answer: Every contractor onsite could be cited!

OSHA has defined who on a multiple-contractor jobsite can be cited for a single violation. This comes from the 29 CFR Part 1926.16 (a) through (d) titled “Rules of Construction”. The following applicable statements illustrate OSHA’s position with regard to each contractor’s responsibility concerning safety hazards.

(a) “…the prime contractor and his subcontractors may…make an agreement…thus relieving the subcontractors from the actual but not any legal, responsibility…”

(a) “…In no case shall the prime contractor be relieved of the overall responsibility for compliance with the requirements of the part [the OSHA Act] for all work to be performed under the contract.”

(b) “…the prime contractor assumes all obligations under the [OSHA Act] …, whether or not he subcontracts any part of the work.”

(c) “…[the subcontractor] also assumes responsibility for complying with the [the OSHA Act] with respect to [his portion of work]. Thus, the prime contractor assumes the entire responsibility under the contract and the subcontractor assumes responsibility with respect to his portion of the work. With respect to subcontracted work, the prime contractor and any subcontractor…shall be deemed to have joint responsibility.”

(d) “Where joint responsibility exists, both the prime contractor and his subcontractor[s] regardless of tier, shall be … subject to [the OSHA Act].”

OSHA has interpreted the above statements to define classes of contractors which can be cited for a violation. There are four types:

The “Exposing Employer”
This is defined as the contractor who by action or inaction allows his workers to be exposed to a hazard. In the hypothetical case described before, any workers crossing the makeshift ramp would allow OSHA to cite [and fine!] their employers- even if their employer had no knowledge of this happening!

The “Creating Employer”
This is defined as the contractor who actually created the hazard. In this case, the plumbing contractor or perhaps the excavation contractor would be determined as having created the hazard by not backfilling, or at least providing a walkway with handrails.

The “Controlling Employer”
This is defined as the contractor who has the authority to ensure that hazardous conditions are corrected. In this case the construction manager would have that role and could be cited for not having the hazard corrected.

The “Correcting Employer”
This is defined as the contractor who has the responsibility to actually correct the hazardous conditions. In this case the general contractor would likely have had that role and could be cited for not correcting the hazard..

As you can see in this example, many contractors can be cited and fined for each violation, depending on a contractor’s involvement- even if peripheral.

Now, what can you do to protect yourself from getting caught “in the net” with other contractors when violations are discovered? Again OSHA has developed a list of items as a defense to a citation- however, ALL ITEMS MUST APPLY:

The contractor did not create the hazard.

The contractor did not have the responsibility or authority to have the hazard corrected.

The contractor did not have the ability to correct or remove the hazard.

The contractor notified other contractors in control of the specific hazards to which it’s workers were being exposed to.
The contractor has instructed it’s workers to:
Recognize the hazard.
How to avoid it.
Where feasible- use protection from it.
Remove themselves from the jobsite.

From a review of the above items it would seem that each contractor onsite in effect has to make their own safety inspection of the jobsite prior to, and during the duration of work.
While this may seem impractical, safety is indeed everyone’s concern. Contractors who show written evidence of a practice of notifying other contractors of their potential safety hazards may go a long way in a favorable finding from a CSHO when handing out citations.

Another way to help your position whether you’re a general or subcontractor is to have safety as a regular topic of discussion. Almost every construction project has either weekly or monthly progress meetings. This is an excellent time for you to place jobsite safety on the agenda as an item to be discussed. This is where new hazards seen by any contractor can be brought out, and a plan to quickly eliminate it accomplished. Any new hazardous materials can be determined, the jobsite MSDS sheets updated, and all contractors brought up to speed as to what hazardous materials are onsite [another OSHA requirement].

All contractors onsite should work together to promote safety. At times any contractor can “slip up”, and a word from the general or construction manager can keep everyone onsite not only safe- but safe from possible collateral citations. Looking out for each other should be part of any construction project.

Are your workers storing materials correctly?

An OSHA safety course and safety training for your construction site can help keep you from having to deal with these issues. Contact us today for a materials safety manual for your jobsite.

A large part of the construction industry consists of simply moving, handling and storing various materials and equipment. From accepting shipments, loading and transporting tools and materials from the shop to the jobsite, moving materials around a jobsite, to loading and bringing tools and materials back to the shop. Thus, construction workers are usually involved in a constant state of material movement.

This is perhaps why material handling is a major factor in workplace injuries. Improper storage and handling methods can cause costly injuries. While it is discussed frequently, improper lifting is still a leading cause of workplace injury. Bending, and especially bending and lifting with a twisting motion can sometimes cause severe back injury. In fact, according to the National Safety Council, more than 20% of all occupational illnesses are the result of back injuries.

In addition to injury caused by lifting, workers can also be injured by falling or collapsing materials improperly stacked, or by the lifting or moving of equipment. The common actions that result in injury can be grouped into three categories:

Carrying or lifting loads that are too large and awkward, or too heavy can cause muscle or ligament tears, strains or sprains.

Being struck by, or caught between materials or lifting or moving equipment can cause fractures, bruising, or in extreme cases, even fatalities.

Falling materials, or improperly cutting ties, or straps can cause cuts, bruises and fractures to the worker or bystanders.

In most of the above cases, using personal protective equipment can prevent or limit injury from materials handling. Hardhats, gloves, safety shoes, eye, ear and face protection, and sometimes clothing can all contribute to protecting the worker.
Employers need to assess their storage areas and jobsites in an effort to minimize or eliminate causes of injury from material movement. The following are some of OSHA’s regulations regarding this subject.

Material Storage

General

When storing materials, it needs to be done in a manner that will not cause or contribute to fire propagation or explosion, overgrowth of weeds or vegetation, or to the harboring of rats and other pests. Naturally when storing flammable or combustible materials more stringent requirements apply. For instance, flammable liquids need to be separated from other materials by a fire wall. Also, combustible materials are required to be in an area where smoking and open flames or sparks are prohibited.

Another consideration is to provide sufficient aisle space around materials to allow for loading, unloading, and turning to prevent a worker from accidentally getting pinned between materials or equipment. Aisles should also be looked at for any trip hazards that may be present due to improper material storage. Overhead clearance shall also be assessed since materials striking an obstruction can fall onto workers.

When stacking materials, it’s important to be aware of the condition of the boxes or containers, accessibility, and the materials weight and size.

Bound Materials

Materials bound together need to be blocked, or stacked in a manner that will prevent sliding, falling, or collapsing of material piles. Aisles need to be kept clear, especially any aisles that serve as a fire exit. If storing on a building or structure’s floor, care needs to be taken to ensure the floor loading is not exceeded.

Lumber

When stacking lumber, OSHA will allow stack heights to 16 ft. when the materials are moved manually. If forklifts, or other similar equipment is used for material handling, lumber may be stored up to 20FT. If used lumber is stored, OSHA does require all nails to be removed before stacking.

Brick and Block

When stacking brick or block, OSHA has height and stacking requirements also. Stacks of loose brick shall not be more than 7 ft. high, however any brick layers above 4 ft. shall be placed on a 1:6 taper (see diagram). Masonry blocks are allowed to be stacked higher, but any block layers higher than 6 ft. shall be placed on a 1:2 taper (see diagram).

Bagged and Bundled Materials

When stacking bagged or bundled materials, they shall be stacked in interlocking rows for stability. Bagged materials shall be stacked by stepping back the layers and cross-keying the bags at least every ten layers.

Drums and Barrels

When stacking drums or barrels, they need to be stacked symmetrically. If stored on their sides, the bottom layer of drums need to be blocked at the sides to prevent movement. When stacked on end, each layer of drums or barrels shall have planks, plywood, pallets, or other similar articles placed on each layer to provide a flat stacking surface for the next layer. In addition, the bottom layer of drums would be required to be blocked on the sides to prevent movement.

Finally, some materials may be more suitable for storage by placing in other containers, or racks. Also pipe and bars should not be stored in racks that face main aisle as it could cause a hazard to others when loading or unloading

This is part one of a two part series on material storage and handling.

Does Your Site Meet the OSHA Workplace Safety Requirements?

An OSHA safety course and safety training for your construction site can help keep you from having to deal with these safety violations. Contact us today for a custom written safety manual for your jobsite.