Author: Jim Vaughn, CUSP

The Skinny on Confined Spaces

Author’s Note: Yes, this is a fleet-oriented magazine, so you might ask why this issue includes this article on confined spaces. Well, I’m glad you asked. All utility employees, including fleet employees, are required to have the skills to recognize a confined space and the hazards in the confined space, and they must also know how to protect themselves from confined space hazards. As you read through this article, you will note the descriptions and characteristics of a confined space, and you may find that some fleet-related spaces do qualify as confined and have the same hazards as a plain old manhole. It doesn’t matter who you work for or what you do, a confined space represents risks that will kill if you don’t recognize them.

There are rules in our industry. We, as utility or utility contractor employers, must follow the rules for two reasons. The first reason is that, if we don’t follow the rules, we get into trouble with the regulatory authorities. The second and more important reason is that the rules are in place to protect employees from injury or death. So it is with confined spaces. Confined spaces can and have killed workers.

Confined space is a confusing issue among many of our colleagues and one I get questions about all the time. In fact, a recent inquiry about confined spaces in wind spurred this article. We will first look at the classification of the spaces we work in so that you start from the right perspective as you try to comply with the rules and effectively protect your workers without going way beyond what’s required. Then we will look at how to practically apply the rules in our workplaces.

The Statistics
According to the U.S. Bureau of Labor Statistics’ Census of Fatal Occupational Injuries, manholes and vaults are the third most frequent locations for confined space deaths. The most common sources of fatal exposure are naturally occurring hydrogen sulfide, carbon monoxide and naturally occurring methane. Trench collapses killed 168 workers in 2020, the year of the most recent census report. Yes, trenches can be confined spaces.

Looking at the exposure statistics should get our attention. Those spaces are where we work. And we have another emerging confined space issue related to wind generation. There are no census reports yet because wind turbine maintenance is just getting into swing as turbines age and maintenance intervals increase, but we know injuries and fatalities are increasing, too.

OSHA requires every employer to examine their workplace for confined space hazards and develop a plan for worker protection.

The utility industry has a special classification known as an “enclosed space.” For all practical purposes, we have two classifications: permit-required confined space and enclosed space. Let’s start with some definitions. Permit-required confined space regulations are found at 29 CFR 1910.146 (Subpart J) and 1926 Subpart AA. Enclosed space standards are found at 1910.269(e) and 1910.269(t). You must be familiar with 1926 Subpart AA and 1910.146 so that you clearly know what a permit-required space is and when a location is considered one (more on that in a bit). Your utility’s enclosed space program and training must be based on 1910.269(e) and 1910.269(t). So, now let’s look at how all this fits together for practical application and keeping your workers safe.

Understanding Definitions
First, we need to understand the definitions of the spaces we work in. For those, we go right to the definitions in the OSHA standard for permit-required confined spaces in 1910.146. We must also go to the end of 1910.269, where we will find the definitions for keywords used in the 1910.269 standard. Each definition from the standard is followed by an explanation.

“Confined space” means a space that:

  1. Is large enough and so configured that an employee can bodily enter and perform assigned work; and
  2. Has limited or restricted means for entry or exit (e.g., tanks, vessels, silos, storage bins, hoppers, vaults and pits are spaces that may have limited means of entry); and
  3. Is not designed for continuous employee occupancy.

Explanation: This definition does not cover electrical manholes, vaults or wind towers. First, all three defining characteristics must be present. While condition 1 might be construed as a manhole, walk-in vault or subterranean electrical vault, that assumption is clarified by conditions 2 and 3. Condition 2 uses examples to help readers understand the term “restricted means for entry.” These restricted means are typically flanges or plates fastened in place with several bolts, meaning it takes a very purposeful act to try to enter the space. You can also surmise from this description the types of facilities these spaces are in. Condition 3 further clarifies the space as “not designed for continuous employee occupancy.” The word “designed” means that the entryways are engineered for access with space and hardware to facilitate frequent and relatively convenient access. Inside the space is appropriate room for maneuvering, walkways, walking grates, handholds, covers for hazardous equipment, lighting and/or ventilation. “Continuous employee occupancy” means that it is expected and common for employees to routinely enter the space for operation, maintenance or inspection.

“Non-permit confined space” means a confined space that meets the definition of a confined space but does not meet the four conditions (see below) of a permit-required confined space.

Explanation: The purpose of this definition and the way it is written have to do with mitigating any of the four hazards that make a space a permit space. This practice is known as reclassifying a permit space. If you have a permit space, but you mitigate or control the four hazards called out in the definition for a permit-required confined space, that space is now a confined space, recognizing that if any of the mitigated hazards reoccur, that space is instantly now a permit space. Following are the four conditions that make a confined space a permit space.

A “permit-required confined space” means a confined space that has one or more of the following characteristics:
Contains or has the potential to contain a hazardous atmosphere.
Contains a material that has the potential for engulfing an entrant.
Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section.
Contains any other recognized serious safety or health hazard.

Explanation: Characteristic 1 is frequently cited as justification for making a manhole a confined or permit space. The reasoning is that, should a fire occur, a hazardous atmosphere would exist. The assumption is true – a hazardous atmosphere would exist – but it does not apply to manholes or vaults. This definition is about confined spaces that are classified as permit spaces. A manhole or an electrical vault does not meet the configuration for a confined space established in the definitions, so this characteristic is not associated with electrical manholes or vaults. This definition also exempts wind towers for the same reason. Characteristic 2 refers to flowing materials, such as water, or flowable solids, such as seed. Characteristic 3 refers to bottom-dispensing hoppers or storage bins. Sloping walls do not relate to manholes, electrical vaults or wind towers. Characteristic 4 is also used to include manholes because electricity is hazardous, and vaults or manholes can contain hydrogen sulfide or carbon monoxide. While this is true, as is the case in characteristic 1, these electrical spaces don’t meet the configuration requirements of a confined space.

So, a confined space has to do with shape and access, while a permit-required confined space has to do with the hazards within the confined space.

An “enclosed space” is defined as a working space – such as a manhole, vault, tunnel or shaft – that has a limited (different from “restricted” in confined space) means of egress or entry; that is designed for periodic employee entry under normal operating conditions; and that, under normal conditions, does not contain a hazardous atmosphere, but may contain a hazardous atmosphere under abnormal conditions.

Note to the definition of “enclosed space”: OSHA does not consider spaces that are enclosed but not designed for employee entry under normal operating conditions to be enclosed spaces for the purposes of this section. Similarly, OSHA does not consider spaces that are enclosed and that are expected to contain a hazardous atmosphere to be enclosed spaces for the purposes of this section. Such spaces meet the definition of permit spaces in 1910.146, and entry into them must conform to that standard.

Explanation: Now we get to the space particularly defined for the electric utility industry, the enclosed space. Rule 1910.269(e), “Enclosed spaces,” explains that the enclosed space classification is in lieu of the permit-space entry requirements contained in 1910.146. This rule further requires that if, after the employer takes the precautions required by paragraphs (e) and (t) of 1910.269, the hazards in the enclosed space endanger the life of an entrant or could interfere with an entrant’s escape from the space, then entry into the enclosed space shall meet the permit-space entry requirements of 1910.146. This is a very important rule because it clarifies that 1910.269(e) does not stand alone as work rules for manholes and vaults. Section (t), “Underground electrical installations,” is part of the requirements for the protection of workers in enclosed spaces. You must be familiar with and follow both to get it right.

Another Look
Let’s look again at the definition for “enclosed space,” particularly the note to the definition. In simple terms, the note shares two important perspectives from which we interpret the rules of 1910.269(t). First, if it is designed for employee entry, it is not a permit space. Second, if the space is expected to contain a hazardous atmosphere, it is not an enclosed space. Again, this is important in defining an enclosed space, particularly when dealing with basements of wind towers or the nacelle. In a normally operating system, the presence of oil, hydraulics, or electrical equipment and cables is not considered a hazardous atmosphere or other hazard. This is a key issue for manholes and electrical vaults, especially regarding rescue, and here is why.

Remember, a manhole is covered by both 1910.269(e) and (t). Part (t) requires a first-aid-trained attendant on the surface if the manhole has energized cables or equipment. Part (t) also allows the attendant to enter the manhole for short periods to provide non-emergency assistance. Part (e) requires an attendant as well. The part (e) enclosed space attendant must be first-aid trained and is not permitted to enter the space to assist workers inside. In fact, the rule uses the phrase “immediately available outside the enclosed space,” and those duties performed by the attendant must not distract the attendant from monitoring employees within the space or ensuring that it is safe for employees to enter and exit the space. So, why the difference? It is explained in the preamble. Part (t) specifies that the hazard is “electrical contact” to the exclusion of all other hazards. Part (e) includes other hazards such as gases, water and fires/explosions. Where the only hazard has been determined to be contact with an exposed electrical hazard, an attendant can briefly enter the space.

The Bottom Line
The bottom line on rescue from a manhole, vault or wind enclosed space is this: OSHA makes it clear in the preamble to 1910.269 that the intention is to have a space for the electric utility industry that recognizes both the nature of enclosed spaces and the types of tasks we perform in those spaces. Wind is somewhat different in configuration, but it is still electric utility generation, transmission and distribution, so we still benefit from that.

Here is a summary of what you should know about enclosed spaces:

  • OSHA’s intent is that all confined spaces are hazardous until they are classified by a competent person and remediated to make the space safe to enter. Otherwise, they shall be treated as permit spaces.
  • OSHA also intends that a competent person must classify electrical manholes, vaults, tunnels or shafts as enclosed spaces in accordance with the standard before workers enter those spaces.
  • Classification of an enclosed space requires detection of flammable gases, toxic fumes and oxygen levels.
  • Where unacceptable atmospheres require ventilation, gas checks must assure the ventilation is effective prior to any entry.
  • Where electrical systems exist, a competent person must inspect and assure the integrity of the insulating systems.
  • A manhole or vault that’s only hazard is electrical shock requires an attendant who can occasionally enter the space to assist workers (see 1910.269(t)(3)(ii)).
  • An enclosed space has more potential hazards, not just electrical hazards, so an enclosed space attendant cannot enter the space (see 1910.269(e)(7)).
  • Enclosed space rescue where a hazardous atmosphere exists (e.g., smoke, fire, gas, toxic fumes) must be non-entry rescue. This requirement means enclosed space entrants must be equipped with rescue lines.
  • A manhole or vault that has come to contain any hazardous condition, such as smoke, gas or flood, is a permit space and non-entry rescue must be performed, meaning the entrants must be in a harness and lifeline where those potential hazards exist.
  • Entry rescue must be made by a qualified person in protective gear, and an attendant must be on the surface during the rescue entry.
  • Any space that has a hazardous atmosphere must be effectively ventilated or treated as a permit space.
  • Workers around any confined space of any classification must be trained to the requirements of the 1910.269 standard before they enter or serve as an attendant.

Some Final Notes on Wind
When it comes to wind, rescue for a basement or the bottom of a tower is not too difficult to figure out and plan for. The nacelle has proved to be more difficult, and we have had several bad outcomes in those spaces in the past decade. The nacelle gets surveyed for hazards by a competent person just like a manhole does. If hazardous conditions are discovered, remediation must occur. Leaking fluids is a big one, especially if they are flammable.

Egress from a nacelle is either down the ladder or out the top hatch. If the exit is the top hatch, timely rescue must be in the plan. The roof rescue is often a rappel, so that equipment must be in place while the work is going on. Rappelling should also be considered down the ladder. In a fire, it is much faster to rope down the ladder than to climb down it.

About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn, CUSP, has devoted the last 24 years to safety and training. A noted author, trainer and lecturer, he is a senior consultant for the Institute for Safety in Powerline Construction. He can be reached at

This entry is part 2 of 9 in the series June 2022

Safety Signs and Sign Policy

You might be surprised how a little thing like a safety sign can turn out to be one of your company’s biggest financial losses of the year. Over the last decade, I’m aware of three clients who lost big because a sign they put up was the wrong color, the print was imprecise, or the employer didn’t have a sign policy or effective safety sign training.

Let’s start with having a sign policy. When helping to develop any policy, I always tell clients that the policy you write is only as good as the training you provide when you roll it out. For instance, if I were to research signs in preparation for a sign policy, I would likely start with the ANSI Z535 safety sign standard. That is where you find the results of the research and testing performed by industry on how to compose and employ effective safety signs. Having done all the research, you establish a procedure and policy that ensure signs are effective. Your new policy enhances worker safety and the safety of the public, and it protects the employer. There is only one very big problem: Your sign program will not be effective if the workforce that uses the signs, the facilitator who provides the signs, and the employees who install or maintain the signs don’t understand sign color, size, print and placement. This is especially true over time when the signs become worn, illegible or damaged, or if they need to be replaced or moved.

If you aren’t already convinced, you are probably now asking, why do employees need to know about safety signs? There are a number of reasons and all of them are lab tested. Agencies like OSHA and MSHA know through experience that safety signs prevent incidents when they are part of a system of safety. Placing signs is only part of the job. A good safety program consists of several elements that link together to establish a safety culture. Employees who are trained on the purpose and function of safety signs are more likely to see and adhere to them. Training employees on the value and construction of signs gives them some ownership and awareness that signs are important and are not only to be followed but are to be maintained in a functional condition. Training on safety signs is not an all-day enterprise. But that short training makes the safety signs a tool in facilities safety when employees understand why they work and what they mean. Signs that an employer places in the environment are there to protect the public from hazards associated with the employer’s facilities. These are the signs warning of lakes, ditches, driveways, alligators, hidden drives, speed limits, trucks entering/exiting, energized equipment, radio-frequency energy and slow-moving vehicles.

The ANSI sign standards are tested to determine the effects on observers of viewing the signage and warning symbols. Those effective sign constructs are then categorized and standardized to keep signs consistent. When workers and the public see a safety sign, they are conditioned to react to the color and graphics. By “conditioned,” I mean that consistency in color, graphics and shape is immediately recognized as a warning because signs are consistent. The Manual on Uniform Traffic Control Devices provides the same consistency, so much so that no one really reads a stop sign. The size, shape and color automatically result in the driver slowing to a stop. This cognitive act was made clear a few years ago when an artist thought stop signs were boring, so he replaced numerous standard stop signs with artistic versions using different colors and graphics. The result was a flood of traffic accidents and jail for the artist who foolishly signed his artwork.

The ANSI safety sign standard specifies that a sign must have three panels bordered within the sign. The three components of effective signage are the signal word panel, the message panel and the symbol panel. The signal word is one word, such as “DANGER,” “WARNING” or “CAUTION.” The message is short, concise and describes the hazard, such as “High Voltage” or “Poison” or “Wild Animals.” The symbol panel is a second method to repeat the message for those who may not fully comprehend it. The symbols are researched using numerous groups of people of varying ages, levels of education, nationalities and culture groups to learn their responses to viewing the symbols. These three panels and the colored backgrounds make up the effectiveness of the sign. The colors for “DANGER” are white letters on a red background. For “WARNING,” they’re black letters on an orange background. “CAUTION” uses black letters on a yellow background, while “NOTICE” uses italicized white letters on a blue background. “SAFETY INSTRUCTIONS” are white letters on a green background.

The placement of signs is elective based on avenues of approach to the hazard and angles of view. Signs should be placed within view of an approaching person so that they can see the sign and react in time to avoid the hazard. Inside a facility where employees are trained to recognize signs, placement is simplified. Out in the public environment, unlike with the MUTCD, the size, number and location of signs are not specified. The owner must make an evaluation and consider the nature of the passing public and the level of hazard to decide where and how many signs are appropriate, keeping in mind that approaching persons must be able to see and react to the sign’s message in time to avoid the hazard.

Real-Life Examples
In the introduction to this article, I mentioned the cost of poor environmental signage. Here are a couple of real instances where the true value of safety signs was overlooked.

Case 1
A utility built a substation. The fence around the substation was 7 feet high with three strands of barbed wire at the top. The fence was also a minimum of 18 feet from the nearest structure in the substation. Outside the substation, a hedge ran parallel along the substation’s rear fence. The hedge was about 10 feet high and 12 feet from the fence. When the fence was erected, the crew installed “HIGH VOLTAGE” red-and-white warning signs every 30 feet along the 240-foot-long fence. About four months later, a local man with a history of burglary and theft convictions laid a wooden ladder against the barbed wire and easily scaled the fence. A short time later, while cutting the 4/0 ground from the substation power transformer, he got in series with a ground current and was electrocuted. A substation maintenance crew member found his body. According to the coroner, he had been in the substation three days.

Within 72 hours, the utility received a notice of claim and a negligence injury lawsuit based on the standards of care established in Section 11 of the National Electrical Safety Code and the codes referenced therein (the American National Standard for Environmental and Facility Safety Signs, ANSI Z535.1, .2, .3, .4 and .5). The suit was successful and hinged on one brief paragraph found in ANSI safety sign standard 8.2.2, “Determination of Safe Viewing Distance,” which reads, “Determination of safe viewing distance for the message panel text shall take into consideration a reasonable hazard avoidance reaction time.” It was argued by the utility that the ANSI standard only applied to workers. The jury disagreed – and they were right. The plaintiff’s case clearly showed that the ladder the victim used was placed almost equidistant between the two closest signs. The plaintiff also demonstrated that when emerging from the hedge used to conceal his unlawful entry for a criminal purpose, the local man could not see the face of the signs. That single argument was enough to result in a multimillion-dollar award to the family of the deceased.

This raises the question for the utility: Would training on sign placement and purpose have triggered a change in company policy? If the sign installers had recognized the placement issue, would the signs have been placed at 8-foot intervals and would that have prevented the incident? No one can argue intent or assumptions on the part of the deceased in this event. What is clearly true is that sign placement did not meet the intent of the standard of care.

Case 2
A highway engineering and construction firm leased an empty 3-acre lot as a base of operations. Highway equipment and materials were stored there. Residential housing was across the street from the lot. A neighborhood market down the street next to the construction lot was across the street from a residential street entrance.

One morning, an improperly loaded material truck caught the system neutral of a single-phase line that crossed the construction lot entrance. The impact broke the #4 copper primary, which fell clear of the neutral, landing on the crushed granite cover in the construction lot. The road crews said the wire was smoking some at first but then stopped. They decided to put up a sign. They used a 4×8 sheet of 5/8 plywood against a sawhorse. In orange fluorescent marking paint, they sprayed this warning on the plywood: “Don’t Touch the Wire.” They proceeded to return to their work area some 100 yards away and then called the power company to report the downed wire.

Fewer than 15 minutes later, a pedestrian from the residential area crossed the street into the construction lot, walking toward the market. She stepped on the downed wire and was electrocuted just as the utility troubleman was pulling up to the location. One of the two-man crew cut the wire with hot cutters and rubber gloves while the second began CPR on the pedestrian. The first man drove to the fuse and pulled it. Despite their efforts, the victim did not survive.

The family of the deceased sued the engineering firm and won. The ANSI sign standard was the basis of their negligence claim. The plaintiff agreed that the workers sought to minimize risk to the public. The plaintiff’s claim also showed that the sign was noncompliant with the ANSI standard in size, shape, color and message and thus could not be recognized by the victim. It was purely an accident that the wire was brought down, but the crew recognized there was a remaining hazard. That is why they put up the sign. Their efforts were honorable but fell short of the standard of care established by the ANSI standard. The crew should have stood by to warn approaching members of the public of the hazard, but instead they chose to erect a warning. That made sense to them because they knew the nature of the hazard. The message made sense to them because they clearly knew of the presence of the wire. The color made sense to them because that is the color that they use to write warnings on the ground where underground obstructions are known to exist. But the pedestrian had no foreknowledge or experience that would have caused her to recognize the hazard expressed by the crew member’s sign.

The ANSI sign standard shows that colors, hazard symbols and warning messages have a repeatable and predictive effect, informing observers that a hazard is present. Of course, such a sign was not available in this case, and a compliant sign could not have been constructed by the highway workers. However, basic knowledge of the function and purpose of signs should have compelled the workers to know their plywood composition was not effective or compliant when such a life-threatening hazard was present. A trained worker would have immediately rejected the crew-made sign idea and posted observers to keep the area clear.

By the way, remember the old white “DANGER” sign in a red oval on a black background? When research showed the value of the three-panel design in 1991, the new design was presented. The ANSI standard explained the rejection of the old red oval but allowed its use to provide time for the conversion. In 1998, the oval sign was removed from the standard and no longer considered compliant. You can still buy them even though they were removed from the ANSI standard. However, again, installing red-oval “DANGER” signs is no longer considered compliant. The bottom line here is that if you are a safety person and/or a policy writer, you need to know these consensus standards and employ their guidance in your own safety programs – both to better protect your workers and to protect your employer.

About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn, CUSP, has devoted the last 24 years to safety and training. A noted author, trainer and lecturer, he is a senior consultant for the Institute for Safety in Powerline Construction. He can be reached at

This entry is part 1 of 9 in the series March 2022

Containing Contagions in Close Quarters

Pandemic preparation is nothing new. In fact, I have been telling employers since the 1980s that a pandemic plan is one of the business/safety mechanisms they should have in place. It’s just good practice to address and interrupt a contagion that could potentially immobilize the employer’s workforce.

The United States has been researching pandemic responses since a swine flu outbreak in 1976, but few if any publications back then addressed workforce contagions. The earliest literature on organized pandemic responses appeared around 1976 when the U.S. government established formal research panels to develop a nationwide response to a pandemic threat. The panels performed research and modeling activities and revised and expanded both research and national immunization programs in response to new threats, such as the avian flu in 1997, anthrax in 2001 and SARS in 2003. Even though U.S. government literature mentioned bioterror as a concern following the avian flu outbreak, the anthrax event was a homegrown bioterror event that raised the stakes.

OSHA was still in its infancy in the mid-1970s and operated around the fringes of the government’s pandemic plans. Those plans in the 1970s and 1980s still did not even mention using employers and workplaces as part of the systematic controls to limit contagions – even though the swine flu originated at Fort Dix, New Jersey, infecting 230 soldiers. In 1994 and 1998, the Centers for Disease Control and Prevention published recommendations for a coordinated response to nationwide and international pandemic events. OSHA’s COVID guidance for employers in 2020 was still only ordered for health-care and health-care-related exposures. In fact, the only OSHA rules for communicable disease reporting originated in the rules for temporary camps in 1974, where they still reside today (see 29 CFR 1910.142(l)).

Segue to storm season and crews in close quarters. Occasionally, in very hard-hit areas, crews end up in temporary camps. Typically, these are portable sleeping quarters with room to sleep six to eight people. Few of these portable sleeping quarters meet the space and configuration requirements of the OSHA standard for temporary camps. I believe OSHA would view the portable trailers used by lineworkers in storm restoration as different than what the 1910.142 standard was created for: labor camps for transient agricultural workers. Even if crews end up in hotels, they frequently share a dining area, especially in the first weeks after a bad storm. The dining areas often are contracted and pick up local workers supervised by employees of the contract service. I have seen this dozens of times in my nearly 50 years in the industry, and often the dining areas are the source of contagions that typically spread flus and colds. Of course, now we have to add COVID to the list, which by many accounts is worse than the flu. For our purposes, it doesn’t matter which is worse – they can both cripple a storm response and they can both be prevented with the same cleaning and hygiene techniques.

During flu seasons in particular, temporary camps must take extra steps to minimize the spread of the influenza virus. These steps are also effective for preventing the spread of the common cold as well as other potential contagions, such as Zika virus and Legionnaires’ disease, that are not uncommon in closed, high-occupancy living facilities. The most effective strategy for preventing the spread of contagions among encamped workers is to focus on identifying and eliminating points of multiple touch in public access areas, particularly mess halls. I have surveyed several temporary camps and mess halls over the years, so here are some recommendations for protecting your visiting workforce.

Contract Kitchen Services
I wish I could tell you that a contract kitchen’s staff will be properly trained and equipped to provide sanitation services, but that is not always the case. In fact, they seldom arrive with a trained crew, and many services necessary to run a camp kitchen are handled by locals often hired after the kitchen arrives. Food and housekeeping handlers need to be clearly advised on how vinyl gloves work as well as how they must be donned, doffed and disposed of. They must also be trained on when to change gloves and understand that using the same pair for all activities transmits contagions. This is the same for cleaning supplies, especially rags. Many crews opt for the convenience of spray bottles and paper towels that do a pretty poor job of sanitizing.

Table Surfaces
Tables should be cleaned with detergent and then wetted with a disinfectant. Detergents remove viral contaminants but do not destroy them. Those viral contaminants are simply transferred to the towel and can later be spread to other surfaces with the towel. Disinfectants such as Lysol kill viral contaminants but are not an effective cleanser.

The CDC does not recommend bleach solutions as anti-viral agents for decontaminating surfaces. Bleach can be effective in decontamination, but it is not as reliable as a surface disinfectant as commercial disinfecting products like Lysol. And while a spray bottle for cleaning is convenient, it is not as effective as towels and buckets with a cleansing solution. A tabletop cleansing solution of water and dish soap, with a half-cup of household bleach per gallon added to the mix, will permit using cloth towels for cleansing and ensure the cloth towels in the solution will not harbor and transfer viral contaminants.

After cleanser is used, the tabletop should be disinfected with Lysol. Allow the disinfectant to remain wet for at least 30 seconds before being wiped. Wiping dry the disinfectant can be done with cloth towels since disinfectants will kill viral contamination on cloth towels. 

Condiment Dispensers
Commercial bottles of popular condiments are shaped, grooved and otherwise decorated as an advertising and sales tool, which makes them hard to clean and disinfect. Individual packets of condiments are considered a best practice. However, sourcing, managing and using individual packets becomes tedious, not to mention that how you distribute individual packets can lead to contagion just through handling. An alternative is to pour condiments into plastic squeeze dispenser bottles, which lack bottle contours, knurled or textured tops, and moisture-harboring labels that cannot be readily disinfected. Plastic bottles are designed to be readily wiped and disinfected. People filling the bottles should be trained just like those cleaning the tables. Bottle filling should be performed by masked workers wearing gloves.

Common Area Refrigerators and Coolers
In auditing mess halls in the past, I have frequently found refrigerator and cooler doors to be overlooked as a contamination source. They are handled by everybody and, gloves or not, each time they are handled, the user picks up and leaves behind contaminants. It is recommended that refrigerator and cooler doors and handles be decontaminated after each meal and periodically during the meals. Touch surfaces on refrigerators and coolers should be cleaned and decontaminated in the same manner as tabletops.

Drink Dispensers
Five- and 8-gallon dispensers as well as pitchers are often used to serve drinks. These are very hard to wipe or clean during use. The best prevention of viral contaminant transfer when serving drinks is to provide all liquids in single-serving, individually sealed units. If drink dispensers are to be used, the dispensing mechanism should be the cup-press-activated type as opposed to a lever pressed by hand. Signage requesting use of a clean cup for each drink dispensed is appropriate.

Portable Coolers and Ice Kegs
Coolers and kegs should be dumped out daily. Before dumping, a half-cup of bleach per gallon of water in the container should be added. The contents should remain or be lightly swirled for 30 seconds to disinfect the interior surfaces of the cooler or keg walls. Portable coolers should be restricted to cooling single-serving containers; the contents should not be used as drinking water.

Hand-Washing Facilities
Cleaning of hand-washing facilities should be the same as surface decontamination of tabletops. A thorough cleaning with the water/dish soap/bleach solution should be carried out, followed by a 30-second wetting of the surfaces with Lysol.

Portable Lavatories
The vendor should be disinfecting the interior of the facilities during pump-outs. Ensure that the facilities are pumped and disinfected on a regular schedule. During flu season, a pump-out is recommended daily.

Don’t Ignore Bedbugs
Even if you want to ignore them, they will not let you. Bedbugs are not associated with any country or social stratum, affecting rich and poor alike. And there are numerous states with poorly controlled bedbug infestations, making it a realistic likelihood that bedbugs may be introduced to common sleeping quarters. Lineworkers travel from across the U.S. during storm restoration events, and many may stop overnight at inexpensive motels (though even the priciest hotels are not immune), so bedbugs can be expected in temporary camps. I’m even aware of a case in Puerto Rico where a sleeper trailer came with bedbugs already infested. Those trailers originated in Ohio – they didn’t get contaminated in Puerto Rico.

There are insecticides that kill bedbugs, but pre-treating is not an effective measure for prevention. Early detection and control are effective measures. Once bedbugs are established, it will take several treatments and isolation periods of all room contents to get rid of them.

CDC recommendations include detection kits that will attract and trap bedbugs before they have a chance to multiply and establish colonies. Two documents that provide good information on prevention and control can be found at and

Another CDC recommendation is to install at least one detector system in each bunk trailer that is checked daily by housekeeping staff. If bedbugs are detected, the contents should be removed immediately and sealed, and pest control should be applied. Pest control will kill active bedbugs, but a reapplication every two weeks for one to two months is required to kill hatching eggs. Prevention is the best way to stop colonization, so quick action is the best practice. Eggs laid will hatch in two weeks. A hatchling takes about five weeks to reach reproductive maturity. Females can lay one to five eggs a day. Infestation can get out of control in a matter of days if not treated.

Finally, I also recommend mattress seals be installed on mattresses to protect against bedbugs inhabiting the mattress’ packing and padding, making pesticides ineffective.

About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn, CUSP, has devoted the last 22 years to safety and training. A noted author, trainer and lecturer, he is a senior consultant for the Institute for Safety in Powerline Construction. He can be reached at

This entry is part 1 of 9 in the series December 2021

Who is Your Customer?

But first, this public service announcement.

If your organization doesn’t already have a policy on energy drinks, you should do the research and develop one. I had long been skeptical of energy drinks because I know that anything that artificially enhances body function always comes with consequences, especially if it’s overused. It’s no different than any prescription drug that supplants the body’s failed functions. There are always side effects. With heat stress or any other kind of stress, the body gets tired, which is how it tells you that it’s exhausted and needs rest to repair itself. If we artificially stimulate the body to ignore those signals, the outcome is not just bad – it can and has become deadly.

In the years of the energy drink boom, I was a contractor. On two occasions, I had healthy 20-somethings helicoptered to hospitals from remote areas after they collapsed and displayed symptoms of a heart attack or stroke. Both instances occurred in over 100-degree work environments. On each occasion, at the paramedics’ request, we looked for and found a cooler full of energy drinks. The victims couldn’t answer questions, but the paramedics had already seen the symptoms and needed to know if that was what they were dealing with.

I decided to launch into research and found some concerning issues with several energy drinks that led the contractor I worked for to do what the U.S. Department of Transportation has done – prohibit energy drinks on our work sites. The problem is what I mentioned above. A cycle begins in which users rely on energy drinks to pep them up for the workday. The energy drinks mask body function limits. Over time, if energy drinks are consumed daily, the consumer may not even realize they are damaging their body – sometimes permanently – because they have essentially become addicted to the cycle.

During my research, I found a 2015 university-based research report on the consumption of energy drinks. In conjunction with the Mayo Clinic, researchers published their clinical findings (see, which confirmed what emergency rooms and hospitals had been reporting for several years. The use of energy drinks, consumed throughout the day as a means of coping with high physical stress in the workplace, has detrimental health effects, including heart stress that has led to the death of otherwise healthy young adults. There are now numerous studies that cite similar concerns. Safety and health professionals should be reading them.

Also in my research, I found that users of energy drinks in these controlled clinical studies – who drink two or more energy drinks a day – experienced a variety of symptoms, including insomnia; anxiety; nervousness; onset of Type 2 diabetes; a stress hormone increase of up to 74%; cardiac arrest; abnormal heart rhythms; niacin overdose; rapid heartbeat; caffeine poisoning; and addiction. The stress hormone issue may be one of the worst side effects. Enhanced stress hormones indicate that the ingredients in the drink are simulating the effects of adrenaline. In stress events, adrenaline is produced principally by the adrenal glands on top of the kidneys. Adrenaline plays an important role in our fight-or-flight response by increasing blood flow to muscles and output of the heart. The additives in most popular energy drinks stimulate users in the same way adrenaline does. But unlike the body that lowers adrenaline production when the stress passes, the chemicals in the drinks do not. Look at the labels. Energy drinks are usually advertised to increase productivity, metabolic stimulation, stamina, physical endurance and mental acuity. The ingredients in these beverages include but are not limited to caffeine; sugar; niacinamide; carnitine; amino acids; herbal extracts; natural extracts; taurine; guarana; ginseng; vitamins B3, B6, B9 and B12; sucrose; glucose; inositol; and a variety of preservatives. One energy drink a day may be tolerable, but if you ask your doctor, you will find that a daily diet of many of these additives will easily result in organ damage.

‘Consume Responsibly’
The energy drink industry has labeled their products with warnings such as “consume responsibly.” They have FAQs on their websites that address caffeine, but they don’t address the other ingredients with the potential to do damage if they are not consumed responsibly. So, what does “consume responsibly” mean? Does it mean reading the label and looking up the ingredients to see what overuse can do to you, or does it mean talking to your doctor about using them? Maybe it means looking up the energy drink on the bottler’s website. Every bottler website I reviewed mentioned that their ingredients are regulated by the U.S. Food and Drug Administration. That is true of the ingredients. However, they don’t mention that because of a loophole, the FDA does not regulate, examine or approve the mixture of ingredients the energy drink industry sells. Most of the bottlers mention that they follow or exceed the requirements of the American Beverage Association, an association of member companies that represent 95% of the energy drinks sold in the U.S. The ABA recommends labeling, and bottlers do go above and beyond the ABA mandatory requirements by complying with the ABA guidance for responsible labeling, the most important of which is “consume responsibly.”

So, if you are a consumer of energy drinks or a policymaker for the safety of your workers and colleagues, I encourage you to do your research. Be proactive and inform your colleagues and the workforce about these issues. Add this to your excessive heat policies. If you have the authority, I encourage you to develop policies that limit if not prohibit energy drinks on work sites. Instead, do what is pretty common among aware employers and encourage the limited use of electrolyte-replacing sports drinks. Sports drinks have a long and fairly uneventful history. We mostly see a sports-drink-to-water consumption rate of 1 volume of sports drink to 3 or 4 volumes of water. You should also consult with your local emergency rooms, as I have done. I have found strong opinions among doctors who have treated energy drink overdoses and will be glad to come to your site and address the issue from their perspective. Yes, you will get pushback from the field, but that is why we educate when we administer. Don’t wait until the first incident to do something about this risk to your employees.

Who is Your Customer?
This is a perfect opportunity for a segue into the primary topic of this article: Who is your customer? When you inform and protect your co-workers and colleagues regarding energy drink use and risks, you are also protecting your employer. That’s especially so if you are providing energy drinks to employees. If an employee has a health reaction to energy drinks provided by the employer, that employer is responsible under OSHA. If the employer does not provide energy drinks but knows of the adverse health effects of energy drink overuse, the employer can be held responsible by OSHA if an on-the-job energy drink abuser is hospitalized during work. The responsibility opens the door to other bad scenarios. 

When consulting with client utilities and contractors, and when training new safety professionals, I always ask, “Who is your customer?” It’s become even more of a concern for me over the last 20 years as I have represented employers as an expert in OSHA actions and civil suits. This is because as I have worked these cases time after time, I have seen well-intentioned activities designed to protect workers that left employers without a defensible position when it came to regulatory or legal action.

It might seem odd to start a topic with the bottom line, but it’s appropriate here. The bottom line is that if you are a safety professional, you have two customers: the employee and the employer. Your work to protect either of them is not mutually exclusive. What you do to protect your employees can help them, but the same actions can hurt your employer if you do them incorrectly. What you do to protect your employees can also protect your employer from both OSHA actions and civil actions.

Here is a disclaimer: I, Jim Vaughn, the author of this article, am not a lawyer, and Utility Fleet Professional is not offering legal advice. I do serve as an expert witness defending employers in both OSHA and civil actions, so I have knowledge of what the expectations are and what does and does not protect the employer. Let’s begin with some of the most common examples.

Tailboard Records
Tailboard forms, job briefing records and job hazard analysis forms – all one in the same – are featured in every case I have been involved in for the last 20 years. I will refer to them here as tailboards. You should know there is no OSHA rule that requires you to use and file a tailboard form. That is usually news to lots of readers. I do agree with many experts that a form, properly designed and implemented, is an indispensable tool resulting in effective tailboards and safe work. The problem is that many forms I see are neither properly designed nor properly implemented. When that happens, crews are not safer, and neither is the employer. 

In the cases I have consulted on, tailboard records come to bear in three different ways with OSHA. Obviously, different results may come from state plan officers and certain regions, but here is what I have found. When a compliance officer arrives at what they call an inspection (we call it an investigation), they ask for OSHA 300 logs; safety program, safety manual and training records; and records of tailboards or what they call job briefing forms. If you don’t have tailboard forms, you will not hear a second request or a criticism. You are not required to use or retain them, so there is no violation. However, the officer will interview employees and supervisors, and from those interviews they will conclude whether you hold tailboards and if the tailboards meet the OSHA-mandated expectations found in 29 CFR 1910.269(c), “Job briefing.” The same requirements are found in 1926.952 for construction work. If their interviews determine that the job briefings were inadequate, OSHA will cite the employer. That citation is fodder for civil actions, which we will address later.

The second scenario follows the conclusion that tailboards were not held or were insufficient. If that’s the case, the training of the work crews becomes the second focus. Where training and tailboards are found to be insufficient, we typically see violations classified as serious or even willful.

The third scenario is that the employer has tailboard forms and proudly turns them over to OSHA, and OSHA analyzes them and uses them against the employer. That is because the record can work both ways. The forms themselves either support the employer’s contention that they perform job briefings, or they contradict the employer’s claim. I have spent untold hours in depositions and on witness stands, explaining an employer’s policies and procedures simply because the employer had poorly or inconsistently used forms that gave rise to the violation. So, if the safety manager wants to protect employees and the employer, the tailboard form and policy are great places to start. Here are some suggestions.

Tailboard Form and Policy Suggestions
First, set goals. We sometimes get so caught up in forms that we forget what we are trying to accomplish. The goal of the form should be to prompt the necessary safety-related hazard identification and response by the crew. The form itself should reflect the elements of 1910.269(c) and must be completely and competently filled out. It also must be reviewed by supervision, and inadequate responses must be brought to the responsible person’s attention and corrected if the forms are to be retained. We find numerous forms missing or not completed on the day of an incident. We find forms without completed sections or those that lack any reference to the work or task related to the incident that caused the injury. This is where training comes in. Procedures are only as good as the training you do when you roll them out to the workforce and the discipline you use in the policy’s execution. If you explain why the form is important, plus how the form itself prompts hazard recognition and improved safety through identification and remediation of hazards, the form becomes a tool that improves safety. Having done so, it also becomes an asset for the employer if the worst should happen.

Training records, equipment inspection records, work site safety policies and safety manuals are no different. Some training has associated record retention required by the state, like crane and forklift operation. OSHA requires the employer to ensure the employee has demonstrated safety-related skills, and that is typically done with a written record even though it is not required by the OSHA statutes. If you write or issue policies and manuals, they must apply to the work you do. Too many employers take another employer’s safety manual, distribute it to the field as their own and don’t even know what’s in it. The workforce must be aware of the policies and practices, and they must be following them in the field. This is where your supervisors must also be experts on the employer’s policies and enforce them in the field. These practices work to ensure the safety of the workforce, which is why OSHA places so much emphasis on them with employers. If you protect the workplace customer, you also protect the employer.

Civil actions are the last aspect of the customer’s protection. Incidents still happen even with our best intentions. When the worst happens, lawyers get involved. If they find any suggestion of negligence or willful violation of OSHA policies, they are going to parse every record and interview conducted by OSHA and try to create a case for negligence against the employer and often the employer’s supervisors. If you have done your job to protect your customers, there will be no merit to the civil claims. It doesn’t mean they won’t try, but it does mean that you will have a good prospect of prevailing in the civil case.

This is the world we live in today, and your employer needs you to effectively execute your job as much as your co-workers do. If you feel like you lack the knowledge to review and develop effective policies, consider consulting with an attorney who is an OSHA specialist or with consultants who have experience in OSHA compliance. There are many out there who can audit your safety program for effectiveness in protecting your customers, the field and the front office.

About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn, CUSP, has devoted the last 22 years to safety and training. A noted author, trainer and lecturer, he is a senior consultant for the Institute for Safety in Powerline Construction. He can be reached at

This entry is part 1 of 9 in the series October 2021

Writing an ATV/UTV Operating Safety Policy

This installment of “Focus on Fleet Safety” is a little bit different than usual in that we are going to write an operating safety policy. There are two goals here: to help you learn to develop policies that make a difference, and to prevent wrecked all-terrain vehicles (ATVs) and utility task vehicles (UTVs) on your job sites.

Over the last few decades, ATVs and UTVs have taken on a significant role in remote site access and large yard transportation. What have also occurred over the last few decades are serious and occasionally fatal injuries from the operation of ATVs and UTVs. In my own experience as a former transmission line contractor, we only had a few incidents with UTVs, but it was on every job where we used them. In my time since, I have received calls every year regarding incidents related to UTVs. They are probably involved more often because ATVs are not as useful on rights-of-way as they are in yards where managers employ them to get around more efficiently. In this article, we are going to discuss the elements of an ATV/UTV policy designed to address the most common issues related to ATV/UTV wrecks and how they can be prevented.

First, in any such policy, we must clearly identify the machines we are covering under the policy. Failing to identify particulars can lead to rationalization in the field and manipulation of the intent of a control policy to get around restrictions. So, here is what we are addressing: UTVs – also known as side-by-sides – are those all-terrain vehicles designed to carry two or more workers and equipment to off-road work sites. UTVs like the Polaris RANGER and John Deere Gator are specifically designed for off-road use for transport, but they may also be used to pull ropes or for other project-related work. UTVs may be wheeled or track-driven vehicles powered by combustion engines or electric motors.

ATVs, also known as three- or four-wheelers, are any all-terrain vehicles designed to carry an operator only plus a limited number of personal tools or equipment to off-road work sites. ATVs may be wheeled or track-driven vehicles powered by combustion engines or electric motors. Snowmobiles are considered ATVs for the purposes of this policy.

When writing definitions, it is sometimes possible and useful to be very concise in defining the equipment covered in a use policy. If your company has specifications, and you are confident that there are no other types of equipment to be used, you can be very specific by listing manufacturers, models and types of power sources.

The Purpose Statement
Next is the purpose statement, which identifies the intent of the policy. In OSHA actions and in litigation, the violations addressed are always examined using the intent of the prevailing standard. The prevailing standard is a rule, law or written standard of performance that regulates the incident at issue. The intent of a rule settles the defense argument of, “Well, I thought it meant …” A purpose statement sets out in clear language why the rule, policy or procedure is needed. Here’s what we might see in the purpose statement of an ATV/UTV policy:

  1. Prevent accidents and injuries resulting from careless operation of ATVs/UTVs.
  2. Establish policy for job site assignment and operation of ATVs/UTVs.
  3. Provide for enforcement and safety accountability in the operation of ATVs/UTVs.

Here we have decided on the three statements above. Statements 1 and 3 address the expectation that ATV/UTV operation will be careful, and if not, there will be consequences. I intentionally separated those two statements strictly to head off a common human response to rules. We have learned in what are known as “validation studies” that readers respond negatively to a series of perceived threats in an instruction. Validation studies ask random individuals from varied backgrounds and occupations to read a series of rules or statements. The readers are then queried about their impressions after reading the statements. This is also how validation of survey questions and test questions is studied. The responses from the readers are analyzed to see how many of the respondents had the same reaction. This does two things. First, it assures that the reader of the questions interprets the questions with the same intent as the writer. Second, this is also where the accuracy numbers come from when you hear a report on political or social issues in the news.

Now, back to the purpose statement. Statement 1 sets the standard, the intent of which is the prevention of any incidents. The second part of the intent of Statement 1 is to eliminate careless operation. Statement 1 doesn’t prohibit use of ATVs/UTVs, but it does establish rules for use.

Statement 2 sets the standard as an operating policy, indicating that it is the rule, not a suggestion. The statement is well-positioned for two reasons. The first reason, as described above, is that it separates two negative statements. But Statement 3 also serves to reinforce the importance of Statement 2. It subtly tells the reader that this is a policy for operating ATVs/UTVs, and failure to follow the provisions of the policy has consequences.

Administrative Policy Statements
Every written policy should include administrative policy statements. That means listing who is in charge of the policy, plus how revisions can be made and approved and who can make them. Without such guidelines, anyone can assume they have the authority to adjust or change employer policies. Here is what that section might look like:

Policy Revisions
This policy is administered by corporate safety. Revisions to this policy are controlled and approved by corporate safety.

This policy is subject to periodic review and update to improve safety for our workers and the public, to comply with changes in state and federal administrative law, and to meet the needs of the company and our clients.

The requirements of state and federal laws, local landowner agreements and client policy may supersede some or all provisions of this policy. Superseding rules shall not have safety-related requirements less stringent than the policies in this standard.

Where conflicts arise, the more stringent provisions apply, and regional business unit managers are responsible for approving changes and notifying the corporate safety department that changes have been made.

Criteria for ATV/UTV Use
Now that we have bulletproofed the administration of the policy, it’s time to establish the rules. Here are recommendations based on my experience and the standards that apply:

  1. ATVs/UTVs must be approved for use on a project by the respective regional manager with the acknowledgement of corporate and the safety department.
  2. Work site supervisors or safety personnel shall conduct a work site review of the ATV/UTV policy with site personnel and document the policy training on the work site acknowledgement form.
  3. Work site supervisors shall keep the ATV/UTV policy review acknowledgement page on-site with project documents for review by safety and administrative personnel.
  4. Work site supervisors must arrange for qualification of assigned ATV/UTV operators before operation.

Rule 1 above ensures that a high level of approval is required to create a high bar for acceptable use on work sites. Without some rigor in the process, UTVs can show up where they really are not needed, elevating the opportunity for incidents. Strong processes create an awareness and appreciation for having UTVs where needed and respect for the opportunity.

Rule 2 ensures that all personnel on the site understand the policy and who is approved to operate ATVs/UTVs and when. This review should fit right in with the site orientation of every worker on the job. Rule 2 also meets a longtime philosophy of my employer, the Institute for Safety in Powerline Construction (ISPC). A policy or procedure is only as good as the training you conduct when you roll it out. Every employee – not just the ATV/UTV operators – must be aware of the policy rules. If you don’t train everybody, someone who doesn’t review the policy will think there is no reason they can’t use the ATV/UTV.

In Rule 4, you read a reference to qualification of operators. It makes sense that the next section of the policy should be how workers are qualified as ATV/UTV operators.

Operator Qualification Rules

  1. Operators must be assigned as an ATV or a UTV operator by the project general foreman or the foreman’s designee.
  2. ATV/UTV operators shall be qualified by a regional safety supervisor or designee.
  3. ATV riders shall have completed the ATV Safety Institute’s online adult rider ATV safety course at Under certain remote site conditions, this requirement may be waived.
  4. ATV/UTV operator candidates shall demonstrate inspection and knowledge of machine operation observed by a licensed competent operator assigned by site management.
  5. ATV/UTV operators shall not operate an assigned vehicle until they have received the required qualification and read the operator’s guide for the equipment they are assigned to operate.

Rule 4 is an important rule, and here is an example why. I once had a crew on a job site that did not read the UTV operator’s manual, assuming they were experienced enough to handle the task. Before they took the UTV out on the mountainous right-of-way, they checked over the machine. They found that each of the tires had only about 8 pounds of air. The crew filled them to 25 pounds, not knowing that the manual stated 8 pounds and that 8 pounds was critical to control of the vehicle. At 25 pounds of air per tire, a bump in the road can bounce the machine off the ground surface, and on return the machine will continue to bounce until you could lose control. That is exactly what happened to this crew. Going downhill on a new right-of-way road covered in crushed granite, they started bouncing, and yes, they were going too fast, which didn’t help. Eventually, the machine turned sideways and rolled over three times downhill on the granite road. The occupants were wearing their seat belts, but their upper torsos were pushed outside the protection of the frame, so they repeatedly did upper body and face plants on the road during each roll. We were fortunate to have a former paramedic on the crew, plus trauma kits, so the injured occupants were fairly stabilized by the time the helicopter arrived to take them to a week’s stay in the hospital. The entire loss of control was precisely due to the air pressure in the UTV’s tires. Had the crew read the eight-page operating manual, they would have known that. Later, in his hospital interview, one of the crew members said he didn’t know how much air was in the tires because the air gauge with the machine was only 0 to 15 pounds, so they pumped them up until they felt solid.

Rule 5 above ensures compliance with OSHA 29 CFR 1926.950(b)(7), “Demonstration of proficiency,” which states, “The employer shall ensure that each employee has demonstrated proficiency in the work practices involved before that employee is considered as having completed the training required by paragraph (b) of this section.” This requirement that the employer ensure proficiency is also in the General Industry standard at 1910.269(a)(2).

ATV/UTV Operating Requirements
Now that we have administration and operator qualification out of the way, let’s take a look at operating policy rules:

  1. Operators, selected by site supervision, shall be licensed, shall be familiar with the operating characteristics of the equipment they are to drive and shall have reviewed the operator manuals for such equipment.
  2. ATVs/UTVs shall not be operated unless the operator manuals are on-site and readily available to operators.
  3. ATVs/UTVs shall be trailered to off-road work areas (transport of ATVs/UTVs on trucks is permitted when properly loaded and secured).

Rule 3 is practical in that it keeps ATVs/UTVs off roads to the right-of-way for two reasons. The first is that ATVs/UTVs must be registered and licensed to operate on a roadway. Second, roadways are high-speed and present unnecessary risk. ATVs/UTVs are there for the right-of-way, so keeping them off the roadways lowers risk.

  1. Other than rights-of-way to access terrains that can’t be navigated by conventional trucks, ATVs/UTVs shall not be operated on dirt roads, improved or paved roads, or any roadway where a truck can be driven.
  2. ATV/UTVs shall be operated at speeds and in a manner reasonable for the prevailing ground and weather conditions. When the option is available, UTVs shall be speed-governed to less than 20 mph.
  3. All seats on a UTV shall be installed or approved for aftermarket installation by the UTV manufacturer.
  4. All riders on a UTV shall be seated and wearing seat belts while the vehicle is in motion.
  5. Unsecured cargo shall not be transported in compartments with UTV passengers.
  6. UTVs shall have at least a three-point seat belt comprised of a lap belt and shoulder strap. When a three-point belt system is not available and cannot be installed, drivers and riders must wear helmets with face protection that are approved by the U.S. Department of Transportation.
  7. ATV/UTV use and limits of use shall be discussed in the daily job briefing and task hazard analysis.
  8. The designated operators of ATVs/UTVs shall be noted in the daily job briefing.
  9. An ATV/UTV operator shall wear work boots, long pants, a long-sleeved shirt, work gloves, ANSI-approved safety glasses and a traffic safety vest unless wearing an approved high-contrast safety-color shirt.
  10. ATV operators shall also wear a properly fitting DOT-approved helmet with face protection.
  11. In high-dust areas, ATV/UTV operators shall wear goggles.
  12. ATVs/UTVs shall be inspected daily and shall not be operated with safety defects.
  13. UTVs shall have a first aid kit and fire extinguisher on board during operation.
  14. ATVs/UTVs shall be operated with spark-arresting mufflers.
  15. ATVs/UTVs shall not be used recreationally or loaned out during off days.

I hope that you have a policy such as this in place if you use ATVs and/or UTVs. If you don’t have a policy in place, I hope that you will establish one, and I encourage you to use this one if you wish to. If you are using ATVs/UTVs without a comprehensive policy, don’t think that just because you haven’t wrecked one yet, it’s not going to happen. Having a policy sets goals, provides examples of good practices and encourages safe work with a reminder that breaking the rules can get you in trouble – if not hospitalized.

If you decide to adopt the recommendations in this edition of “Focus on Fleet Safety,” you may also be interested in the qualification record that ISPC uses in our ATV/UTV training. Utility Fleet Professional will make it available for download, and I can send you a copy, too. Feel free to contact me at

About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn, CUSP, has devoted the last 22 years to safety and training. A noted author, trainer and lecturer, he is a senior consultant for the Institute for Safety in Powerline Construction. He can be reached at

Web Table

A Practical Guide to Using Outrigger Pads

I’ve met a lot of people over the years while working in the utility industry. One of those people is in management with a respected manufacturer of aerial devices. Back when OSHA published 29 CFR 1926 Subpart CC, “Cranes and Derricks in Construction,” he and I and a few others were discussing how a utility operation could best comply with some of the standard’s requirements. The OSHA rules were formed with the perspective of typical construction sites in mind. In particular, we discussed the rule’s expectation that the site’s general manager will tell the crane operator about underground obstructions that might collapse and cause a crane to become unstable. It’s obvious that a crane operator setting structures on a right-of-way doesn’t have that luxury, so we were thinking about things we could do. The discussion landed on auxiliary outrigger pads. At the time, my friend from the aerial device company had this to say: “We have occasionally been sued by folks who turned over one of our cranes or aerial devices, but we have never been sued by anyone who had set up on auxiliary pads.”

I don’t know if that’s still the case with that company, but at the time I began to research why auxiliary pads appeared to be an important part of stable setup for aerial devices. Basically, it’s because sometimes even a few square inches of additional pad dimension can increase ground support by tons per square foot. When it comes to the four-point support of an aerial device that weighs in at tons, tons-per-square-foot increases are a good thing.

The expectation for the stability of cranes is clearly demonstrated by the language OSHA uses in the Subpart CC standard. Take 1926.1402, “Ground conditions,” for example. In the preamble, OSHA explains that due diligence in determining ground conditions will prevent numerous overturns, which are the most frequent cause of crane-related fatalities. The preamble also mentions OSHA’s recognition of the utility industry and our good record of low-incident operation compared to the rest of industry.

On bucket trucks, boom trucks, digger derricks and cranes, the manufacturer-supplied outrigger foot is designed to be used as a bearing surface against an auxiliary pad placed by the user. The fixed factory outrigger foot is optimally sized to provide support for all boom configurations on solid foundations. The fixed outrigger foot size also takes into account space and weight, and the qualified operator is expected to be able to determine what additional support is needed to assure stability. The fixed foot on the outrigger is not designed to accommodate all ground conditions and should always be used with an outrigger pad.

Practical Considerations for Stability
In our industry, OSHA’s expectation for stable setup of bucket trucks and digger derricks is not called out literally. Setup stability is expected to be covered as a collective part of the OSHA standards regarding qualification and work-related safety skills that the employer must certify after observing an employee’s demonstrated skill. So, let’s take a look at some practical things that can improve your bucket truck and digger derrick setup stability.

I need to clarify here that there is little – if any – consensus guidance that a policy writer can turn to. The information that follows are workable methods I used for years when I served as the safety director for a big line construction company. So, keep that in mind. The guidance in this document is based on practices common to the lifting industry, information available from public sources and industry experience. I am providing this guidance as a tool to help the reader in developing their own training or policy because I haven’t found any detailed guide on device setup. Also keep in mind that it is the employer’s responsibility to devise policies and practices to establish workplace safety, including performing due diligence in setting up cranes and aerial equipment in accordance with the equipment manufacturers as well as state and federal requirements.

First, outrigger pads should be used under all outriggers in all surface conditions. If you purchase an aerial device today, it is likely to come with synthetic outrigger pads. They should not be relegated to use in sandy areas only. Bucket truck and digger derrick operating rules often call out setting up on manufacturer-provided outrigger pads. Cribbing (dunnage) is additional support used under an auxiliary outrigger pad. It is added in muddy conditions and stacked to achieve leveling on sloped ground. Cribbing is convenient to add additional size because you can build a 4-foot-by-4-foot pad over a soft spot or mud without having to cart around a 4-foot-square, 200-pound auxiliary outrigger pad. Cribbing also comes out of mud easier (tie a rope to one end) than a 3- or 4-foot-square outrigger pad, and it can be used to raise a pad to level a truck. During my time as a safety director for construction, I would survey the site before mobilization. If we weren’t using crane mats, I would frequently identify a local sawmill that could run a truckload of 3-foot 4x4s to keep on-site for our cranes and buckets used to perform transmission construction. These green wood dunnage pieces are inexpensive, environmentally friendly and can be left behind or given away when no longer needed. They also become a handy goodwill tool for the people you have been inconveniencing for the last few months, although there are rarely any left because lineworkers tend to burn them during winter for heat in the laydown area.

Below is a table that offers guidance on minimum cribbing lengths for digger derricks, bucket trucks and light boom trucks when supplementing factory outriggers with built-up pads or when providing additional support for factory-provided pads. There is no guarantee this table is foolproof since it relies on the proper performance of certain ground conditions. However, after years of following these guidelines, they seem to work well since no bucket or derrick I was overseeing failed to remain upright. Check your operator manuals and you likely will find similar guidance. This table is based on the widths of outrigger feet and a pad dimension increased safety factor of 2.5.

Note: Minimum cribbing lengths shall be 2.5 times the width of the digger derrick/truck crane outrigger foot. Use this table to select minimum lengths of cribbing planks.

Cribbing Under Pads
As I noted earlier, digger derricks and bucket trucks often come from the manufacturer with outrigger pads. Manufacturer pads have historically performed well in support of the bucket trucks and derricks they accompany. However, manufacturer-supplied pads do not relieve the employer of the responsibility to assure pads and cribbing under an outrigger will safely support the vehicle in the conditions present. The operator still must carefully observe the manufacturer’s pads for sinking or deformation during loading. Adding cribbing as described above will limit sinking and bending of the auxiliary pads in soft conditions. If you see one of your pads sink or bend, add dunnage supplement pads as needed. A competent person should attempt to quantify the load-bearing capacity of the soil when conditions are suitable for making those calculations.

Calculations for Outrigger Pads
I was qualified as a crane operator many years ago and recently found some training materials from that class, which provide the following recommendations. 

When compaction information is available or a pocket penetrometer is used to measure soil compaction, lift planners may use the following calculations to compute support limits by outrigger pad area for constructed pads. This method was published by NCCCO CraneTech in April 2006. 

Method for Determining Crane Outrigger Pad Dimensions When Soil Compaction is Known
The total loaded weight of a crane is divided by the total number of outriggers in touch with the earth to determine the maximum weight that will be placed on each outrigger. The total weight on the outrigger must be less than the weight that can be supported by the earth without further compressing. If the earth beneath an outrigger should further compress during a lift, the rig will become unstable. The weight-load capability of compacted soil, known as the soil’s compressive strength, usually is rated in tons per square foot (tsf). The following process requires that soil compaction be stated in pounds per square inch (psi) in order to estimate the pad dimensions in square inches needed to support the weight to be applied.

The weight of a crane and load cannot be evenly divided among the outriggers because swinging over a single outrigger loads that point more than all of the others. Crane manufacturers design each outrigger to handle the total weight of the crane and load. Using the total weight of the crane plus the load weight computed against the ground resistance to calculate pad size matches the manufacturer’s capacity for the outrigger and ultimately provides a good safety factor for pad applications.

Step 1: Convert tsf to pounds per square foot (psf).
Formula: tsf * 2,000 = psf
Example: 1.5 tsf * 2,000 = 3,000 psf

Step 2: Convert psf (when known) to psi.
Formula: psf ÷ 144 = psi the soil will support
Example: 3,000 ÷ 144 = 20.83 psi 

To compute pad area for a lift for calculated crane-plus-load weight:
Formula: square root of total crane weight ÷ soil psi = pad dimension

For example, let’s say the crane and load weight are 78,000 pounds and soil compaction is 20.83 psi. Given that Ö(78,000 ÷ 20.83) = 61, the pad size is 61 inches by 61 inches (approximately 5 feet square).

Cribbing Best Practices
If you are using outrigger pads for cranes that are constructed of wood cribbing (beams or blocks), the following best practices should be followed:

  • Cribbing planks should not be less than 3-inch-thick hardwood or built-up plywood.
  • Cribbing assembled on-site shall be a minimum of three layers for 3-inch-thick planks or two layers for 4-inch-thick planks.
  • Cribbing shall not bend or deform in any manner under loading.
  • Each successive layer of cribbing shall be laid at a right angle to the layer below.
  • The top cribbing layer in contact with the crane outrigger foot shall be at least as wide as the outrigger foot.
  • Cribbing should not be used if it is split, warped or excessively worn.

Guidance on Cribbing Constructed Pads
Cribbing is laid at a bias (right angle) to evenly spread out the load from the crane outrigger foot. Using three layers for 2-inch planking distributes the stresses across all of the boards in the lower two layers, creating a single, larger unit of resistance.

Pads constructed of cribbing (dunnage) planks that are 4 inches thick may be constructed in two layers, provided that the top layer of cribbing is wider than the crane outrigger foot and that the bottom layer is at least as wide as the length of the top layer. If a built-up pad bends under load, additional layers must be laid.

When to Crib, When to Excavate
Cranes, derricks, boom trucks and bucket trucks must be set up levelly in accordance with manufacturer standards. Cribbing alone will not always solve leveling problem, and in some cases, cribbing will make the setup less stable than an incline.

There are no national standards or limits regarding how to build cribbing or how high cribbing can be built. The operator must understand the physics at work to determine how and when cribbing and excavating must be used.

Soil finds its natural slope in accordance with its granular weight, granular shape, moisture content and organic content. This slope is called the angle of repose. The angle of repose can be disturbed by pressure and cause the soil to slide or otherwise be displaced. The greater the angle of repose, the greater the chance the soil can be disturbed.

When setting up a crane on a slight angle, the use of cribbing stacks can level the crane with careful placement of interlocked cribbing of two or three layers. The more cribbing layers used, the less stable the cribbing may be if not properly interlocked and constructed. In addition, cribbing can be destabilized by the outriggers opposite the cribbed outrigger, especially where high angles are concerned. If the angle is too great, an articulating outrigger may engage the soil at a fairly high angle. The higher the angle, the more push is created toward the opposite-side outrigger set up on cribbing.

Sometimes a better choice is to excavate a pad into a slope on which to set up a crane. There is no standard for the size of a pad excavation, but experience teaches that a pad three times the longest length of the equipment to be set up is reliable.

About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn, CUSP, has devoted the last 22 years to safety and training. A noted author, trainer and lecturer, he is a senior consultant for the Institute for Safety in Powerline Construction. He can be reached at

Understanding Radio Frequency Energy Exposure

Are you concerned about cellular antennas? Decades of research on cellphones and cancer have not found a link between the two, but that hasn’t stopped some communities from creating laws and public service campaigns regarding protection of the public from cellular system threats. What these actions have done is created a sense that the risk exists, leading to much concern and confusion for the public. There are risks, and they are not to be ignored, but many of them are misunderstood.

As communications technology continues to develop, its next iteration – 5G – is already here. The idea of 5G is better coverage using smaller, low-power, overlapping range with multiple antennas. This is the same technology used in large offices and hospitals to overcome the cellphone signal shielding caused by buildings. The buildings have numerous low-power, overlapping antennas that ensure cellular signal communications. The communications industry needs more mounting locations, and utility poles are the obvious answer. 5G is more of a physical hazard than a radio frequency (RF) hazard because it includes a powered cabinet on the pole wired to the antenna above, creating more congestion on the structure for climbers. I receive lots of questions and rightly so because line personnel are finding themselves looking at antenna installations where they have never seen them before. 5G is very low energy compared to other RF emitters but should not be ignored. Most of the 5G hazard is the antenna at the top of the pole, which can be anything from a 30-foot light pole to a 60-foot transmission pole. The obvious precaution, as with any antenna, is to not put yourself in the antenna beam. So, a 360-degree 5G antenna is like any 360-degree antenna: Don’t put your body in the beam.

Ionizing and Non-Ionizing
Since we can’t address all types of energy or antennas in this article, let’s look at some general information and precautions. Panel antennas are easier to avoid because they have a directional focus. The tubular 5G antenna is a little more difficult to avoid because it operates at 360 degrees.

Radiation that’s non-ionizing is of little risk. It is too weak to affect chemical bonds in the human body. That includes ultraviolet, visible light, infrared and everything with a lower frequency, like radio waves. Technologies like power lines, FM radio and Wi-Fi also fall into this range. Microwave falls into this class, too, but is an exception. It is the only non-ionizing radiation that can cause tissue damage. That’s because microwave is precisely tuned to resonate with water molecules. Frequencies above ultraviolet, like X-rays and gamma rays, are ionizing.

Microwave, radio, cellular tower and television tower antenna signals are ionizing RF energy. RF radiation will blind workers and quickly burn and destroy human tissue – both external and internal – depending on the frequency and strength of the RF energy field. You can’t see RF energy nor can you hear it. There are personal RF energy exposure detectors available. But even with a detector, you can boom into a high-energy field and be injured before the detector can warn you. You must understand what RF hazards are and be able to recognize where the energy is to avoid a hazardous exposure.

RF Health Effects
The Health Physics Society explains that the quantity used to measure how much RF energy is absorbed in a body is called the “specific absorption rate” (see According to the HPS, “It is usually expressed in units of watts per kilogram (W/kg) or milliwatts per gram (mW/g). In the case of whole-body exposure, a standing human adult can absorb RF energy at a maximum rate when the frequency of the RF radiation is in the range of about 80 to 100 MHz.”

In the same article, the HPS also states that “[b]iological effects that result from heating of tissue by RF energy often are referred to as ‘thermal’ effects. It has been known for many years that exposure to very high levels of RF radiation can be harmful due to the ability of RF energy to rapidly heat biological tissue. This is the principle by which microwave ovens cook food. Tissue damage in humans could occur during exposure to high RF levels because of the body’s inability to cope with or dissipate the excessive heat that could be generated. Two areas of the body, the eyes and the testes, are particularly vulnerable to RF heating because of the relative lack of available blood flow to dissipate the excessive heat load.”

RF Hazard Training
All employees working in the vicinity of RF sites shall be trained to recognize and be aware of the presence of RF/microwave exposures. In 29 CFR 1910.268(p)(2), “Hazardous area,” OSHA requires placement of warnings, stating the following: “Accessible areas associated with microwave communication systems where the electromagnetic radiation level exceeds the radiation protection guide given in §1910.97 shall be posted as described in that section.” The issue is that the rule is for “areas associated,” which are the microwave facilities themselves. There is no requirement for the owner of the antenna to look downstream and post warnings. That leaves the task of warning up to the employers of potentially exposed employees. OSHA requires that all employees exposed to such hazards have awareness training prior to working in the vicinity of transmitting antennas. Specifically, rule 1926.967(k)(1)(iii) states the following: “When an employee works in an area where the electromagnetic radiation could exceed the radiation protection guide, the employer shall institute measures that ensure that the employee’s exposure is not greater than that permitted by that guide. Such measures may include administrative and engineering controls and personal protective equipment.” Of course, this is not always easy to accomplish when the antenna is a foreign installation on a pole or structure. It is often the case that the utility department that approved the installation is not in touch with the people that work on the structures – thus the OSHA rules. Part of the exposure issue is that when workers are on a transmission structure, that structure may be remote from an antenna, but it may still be within the hazard range for workers even over a short period of time. 

What to Look for in the Field
Antennas used for cellular and paging/personal communications service (PCS) transmissions are typically located on towers, water tanks and other elevated structures, including rooftops and the sides of buildings. A cellular base station may utilize several omnidirectional tube antennas that are 4 or more inches in diameter and 10 to 15 feet in length.

In urban and suburban areas, cellular service and PCS providers commonly use sector antennas for their base stations. These antennas are rectangular panels, about 1 foot by 4 feet in size, typically mounted on a rooftop or other structure, but they also are mounted on towers and poles. Panel antennas are usually arranged in three groups of three each. It is common that not all antennas are used for the transmission of RF energy; some antennas may be receive-only.

The RF emissions from cellular or PCS base station antennas generally are directed toward the horizon in a relatively narrow pattern in the vertical plane. In the case of sector (panel) antennas, the pattern is fan-shaped, like a wedge cut from a pie. As with all forms of electromagnetic energy, the power density from the antenna decreases rapidly as one moves away from the antenna.

Radio and television broadcast stations are always antennas mounted on purpose-built towers 100 to 500 feet tall. Broadcast stations transmit their signals via RF electromagnetic waves at various RF frequencies, depending on the channel, ranging from about 540 kHz for AM radio up to about 700 MHz for UHF television stations. Frequencies for FM radio and VHF television range from less than a watt to more than 100,000 watts. Some of these transmission systems can be a significant source of RF energy within the antenna beam for hundreds of yards. That is usually where lineworkers become exposed.

The level of exposure depends on several factors, including the type of station, design characteristics of the antenna, power transmitted to the antenna, height of the antenna and distance from the antenna. Since energy at some frequencies is absorbed by the human body more readily than at other frequencies, both the frequency of the transmitted signal and its intensity are important.

The antenna’s wave signal is pie- or cone-shaped and aimed at the horizon. If you are near an antenna, imagine a line from the center of the antenna to the earth’s horizon. That will be the beam center. You cannot know how wide the beam is. It widens as it leaves the antenna, but it also weakens. 

RF Warning Signs
Look for RF warning signs at antenna facilities. The warning sign symbol for RF radiation hazards shall consist of a red isosceles triangle above an inverted black isosceles triangle, separated and outlined by an aluminum color border. The words “Warning: Radio Frequency Radiation Hazard” appear in the upper triangle. There is no standard requirement, but safety information is expected in the lower black panel and can include wattage output, safe clearances or contact information for the operator. You will most likely find operator contact information. 

Cell Sites
Where lineworkers may be exposed above safe limits, cell transmitters should be locked out to protect workers from radiation energy hazards. Quality of service can be diminished for the cellular customer, but in metropolitan areas, cellular system operators usually can continue service to customers even if one tower in a local area is offline. Remote areas often relay in a hopscotch mode, so one antenna offline may have more impact, especially for the crew working in that area, so keep that in mind if your rescue plan relies on cellphones.

When you know their contact information, cellular transmitter owners/operators can provide energy hazard information, approach angle and minimum approach proximity to prevent radiation hazards to workers.

Pre-job hazard analysis near cellular sites shall include recognition of radiation energy hazards, the safety practices to be employed, the limits to radiation exposure and how to protect exposed workers from radiation hazards.

Where RF warning signs are present, look for information on the signs advising of the nature of the potential hazard, how to avoid the potential hazard and who to contact for additional information. Warning signs also may provide instructions that direct individuals as to how to work safely in the RF environment of concern. RF energy warning signs typically are located prominently in areas that will be readily seen by persons who may have access to an area where high RF fields are present.

General Antenna Clearance Guidelines
Following are some general antenna clearance guidelines that readers should familiarize themselves with:

  • Unless the operational characteristics of a particular antenna are understood and exposures are known to be below the appropriate maximum permissible exposures, personnel should remain at distances greater than the standoff distances shown below:
    • Within 10 feet or less directly in front of a directional (sector or square-face, panel-type) antenna.
    • Out of the center beam and more than 50 feet from the main beam of a horn-reflector or parabolic-reflector (dish) antenna.
  • Leave the area if you sense unusual heating of the skin from the direction of an antenna.
  • Check Federal Communications Commission warning signs at antenna facilities to see if site modeling or monitoring has been performed and the clearances listed.
  • Use personal monitors if work is to be performed where the possibility of exposure exists.
  • Assume all antennas are active unless you have contacted the operator and performed a lockout and tagout of the antenna power supply.
  • Use of a personal monitor can detect the presence of strong electromagnetic energy fields.
  • The FCC’s OET Bulletin 65 establishes human exposure limits for various types of RF energy (see Many personal RF monitors are calibrated to these standards.
  • Do not rely on field-strength personal RF monitors to determine if an antenna is active. If not locked out, an antenna can begin transmissions at any time without warning.
  • If a personal RF monitor issues an alarm, the affected employees shall immediately remove themselves from the vicinity of the antenna.

OSHA Rules on Microwave Energy
OSHA has several rules regarding microwave energy that readers should be aware of.

Paragraph 1926.967(k)(1)(i) regarding microwave transmission states the following: “The employer shall ensure that no employee looks into an open waveguide or antenna connected to an energized microwave source.” 

Paragraph 1910.268(p)(3), “Protective measures,” states, “When an employee works in an area where the electromagnetic radiation exceeds the radiation protection guide, the employer shall institute measures that insure that the employee’s exposure is not greater than that permitted by the radiation guide. Such measures shall include, but not be limited to those of an administrative or engineering nature or those involving personal protective equipment.”

Maximum permissible exposures are measured by centimeters of skin exposure in milliwatts squared. That is body or skin exposure. OSHA has published a rudimentary guide in 1910.97. These limits may not be enough to protect the eyes of a worker looking toward a transmitter while in the antenna’s transmitting beam.

In 1910.97(a)(2)(i), which focuses on a radiation protection guide, OSHA states the following:

“For normal environmental conditions and for incident electromagnetic energy of frequencies from 10 MHz to 100 GHz, the radiation protection guide is 10 mW/cm.2 (milliwatt per square centimeter) as averaged over any possible 0.1-hour period. This means the following:

  • “Power density: 10 mW./cm.for periods of 0.1-hour or more.
  • “Energy density: 1 mW.-hr./cm.(milliwatt hour per square centimeter) during any 0.1-hour period.
  • “This guide applies whether the radiation is continuous or intermittent.”

Paragraph 1910.97(a)(2)(ii) states, “These formulated recommendations pertain to both whole body irradiation and partial body irradiation. Partial body irradiation must be included since it has been shown that some parts of the human body (e.g., eyes, testicles) may be harmed if exposed to incident radiation levels significantly in excess of the recommended levels.”

There is a hazard to power-line workers from RF energy. It may not be at every location, but workers must be able to recognize where it is. Just like all worker safety programs, the employer must have a defensible training plan in place proportional to the exposure of the employees. If you are an employer or hold the employer’s safety role, survey your system for RF hazards. Work with antenna owners to identify the nature of the hazards and establish training and protections for workers who may be exposed.

About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn, CUSP, has devoted the last 22 years to safety and training. A noted author, trainer and lecturer, he is a senior consultant for the Institute for Safety in Powerline Construction. He can be reached at

Trailers, Brakes and Common Usage Errors

I perform audits of both utilities and contractors. When I work with them to do those audits, we include trucks and trailers. The trailers I’m talking about here are not the box vans behind tractors, but the general-duty trailers used to haul trenchers, backhoes, wire reels and padmount transformers. It’s no surprise that the trailer issues we discover are in keeping with the types and frequencies of violations that enforcement officials find on the roadways: those involving lights, load securement and brakes. Auditors also get a lot of questions about trailer safety, or more specifically, trailer rules, which are in place for trailer safety. I almost always receive those questions after an enforcement action has occurred.

Many enforcement actions have come about due to the efforts of states that have noticed trends in trailer-related incidents. The incidents didn’t involve semi-trailers pulled by tractors; they involved smaller trailers used in commercial environments where enforcement had not spent much focus. Without that focus, there was a lack of accountability, and now it’s caught up with us. States are enhancing their observations of commercial trailering, making stops and taking trailers out of service for numerous issues, most often related to brakes.

The inspiration for this article was a recent training visit I made to a central U.S. utility. On the way to the training location, I saw a utility crew on the side of the road with a state trooper. It turned out they were my training class for that day, so I got to ask them about the stop. It was about brakes. The trooper was getting ready to pull out from a doughnut shop (really, he was) when the crew passed in front of him. The trooper noticed the lack of a battery box and a battery, so he stopped them. He didn’t check to see whether the brakes were working because the lack of a battery on the electric braking system meant the breakaway emergency system wasn’t functional. The crew got a ticket, but they also caught a break. Since the yard was two blocks away, the state trooper allowed the crew to continue to the yard instead of putting them out of service. He also stopped by later that afternoon to see if the trailer brakes had been repaired. They had been.

Once during an audit, I came across a contract line crew with a malfunctioning pole-trailer braking system. The reason I knew it was malfunctioning was because the blue wire in the trailer’s electrical plug was pulled out of the plug and very noticeably hanging from the cord. The reason for that, the crew explained, was that the trailer brakes had locked up and wouldn’t release. They had to get 70 poles delivered to the right-of-way before the day was over, so they had no choice but to disconnect the brakes and “just be careful.” There are several unacceptable issues here, but the worst likely was not the crew’s fault. There were five crew members who held commercial driver’s licenses: one truck driver, two apprentices and three journeymen. This was not a fly-by-night operation, but for all the company did right, not one person on the crew realized the gain was dialed all the way up on the controller in the cab. That’s why the brakes locked up.

How many crews does your company send out with equipment they are not familiar with? How many crew members in your company will solve a problem like stuck brakes in a similar way? As we say at the Institute for Safety in Powerline Construction (ISPC), even the very best programs you create are only as good as the training you conduct when you roll them out. To me, the issue with brakes is seriously overlooked and underrated. Big trucks handle very poorly in emergency maneuvers, and almost nothing makes an emergency more unmanageable than a 10-ton trailer pushing a truck where the driver doesn’t want to go.

Brakes Are Required
Federal Motor Carrier Safety Regulation 393.42 is the rule on brakes. Any trailer over 3,000 pounds is required to have brakes. Trailers under 3,000 pounds must have brakes if the trailer axle weight exceeds 40% of the combined axle weight of the tow vehicle. The under-3,000-pounds rule and the 40% rule likely won’t apply in the line industry unless we get carried away with this electric truck thing. Trailers used in the line industry typically exceed 3,000 pounds.

While we are on this topic, I want you to take safety home with you, so keep in mind that an 18-foot fiberglass boat with a single outboard motor on a trailer typically weighs over 3,000 pounds. Since safety is the reason for brakes, it’s a safety issue if your boat trailer’s brakes are not functional or properly adjusted, even if enforcement doesn’t check privately owned trailers not used in commercial operations. Privately owned trailer crashes are just as deadly as commercial trailer wrecks.

Now, back to big trucks, trailers and brakes. In addition to brakes, the trailer must have an emergency breakaway system that applies the brakes in the event the trailer becomes disconnected from the tow vehicle. Electric braking systems use a controller that supplies 1 to 12 volts into the actuator system that delivers a proportional magnetic or hydraulic applied friction brake to the trailer wheels. On the electric system, a breakaway-system battery mounted on the trailer is actuated by a lanyard connected to a switch. If the trailer breaks away, the lanyard is pulled, activating the switch that applies the full battery voltage to the actuator, locking the brakes on the trailer.

Trailer surge brakes use the weight of the trailer against a hydraulic piston mounted in line with the trailer tongue to proportionally apply braking pressure to the trailer’s wheels. The emergency breakaway on a surge system uses a master cylinder actuated by a lanyard that applies full brake pressure to the trailer brakes. Now, not new but not as familiar are electric-over-hydraulic trailer-braking systems that use a combination of proportional electrical signal to hydraulic pressure device, usually a motor that produces the hydraulics to the drum or disc brakes. But as I wrote earlier, even the best systems that are periodically inspected and maintained by good mechanics are only as good as the training of the people who use them. That is often where we find issues in audits and roadside inspections. And speaking of roadside inspections, I’m aware of two recent reports of the Department of Transportation using empty school parking areas to pull over trucks with trailers for brake tests. Using the requirements of the table found in FMCSR 393.52, they set up a brake test zone and have the driver demonstrate the stopping ability of the loaded trailer.

Four Common Trailering Errors

So, with that message delivered about trailer brakes, here are four common trailering issues to be aware of:

1. Overloading the Trailer
With lineworkers, the policy often is, “if it fits, it flies.” This is not an uncommon problem. I sometimes remind lineworkers that when they are loading, securing and driving trucks, they are not lineworkers – they are CDL truck drivers. They know the rules, or at least they knew the rules when they qualified for their CDL. That’s not a criticism of lineworkers as much as it is a deserved criticism of employers. Of all the posters and safety topics you see in a year, how many are dedicated to calculation or review of trailering and trailer loads? On several occasions, I have heard lineworkers assume that if they gave me this trailer and these two 15,000-pound reels of wire, they must fit.

Recommendation: Periodically review trailering, load securement, calculations and weight labels. Even better, stencil axle ratings and load limits on trailer tongues for ready information access for crews.

2. Load Securement
Securement devices are called out in FMCSR 393.104. I frequently find loads secured with straps and chains or binders rigged over lightweight side rails that already are bent from previous tie-downs. These rails will bend further or fail during what should have been a manageable emergency maneuver. When rails fail, the load shifts, creating dynamic forces that can result in loss of trailer control.

Recommendation: Fleets should conduct periodic training on and reviews of load securement and rigging equipment for crews. In addition, they should ensure appropriate tie-downs compatible with issued rigging equipment are available at multiple points on trailers. Even better, paint designated tie-downs with contrasting paint so they are easily visible to operators.

3. Trailer Breakaway Check (FMCSR 393.43)
I have never found a crew that has performed a trailer breakaway test. Trailer breakaway systems are required to be applied for 15 minutes post-breakaway. To test the system, a worker actuates the breakaway lever while a second person listens for or observes the actuation of the armatures on the trailer and then times it out. If a battery does not maintain a charge for 15 minutes, it likely needs to be replaced. If hydraulics fail to maintain the brake for 15 minutes, the system is probably leaking. Either way, the system failed and will not perform in a breakaway or roadside inspection.

A related issue is that the brakes are not always properly functioning even though most braking systems automatically adjust. When ISPC audits utilities, we have drivers roll slowly ahead and manually apply the trailer brake controller to test the brakes. Occasionally we find drivers who don’t know how to do that. On rare occasions we find brakes that don’t work properly. If that’s the case, even if the breakaway works, it’s not going to stop the lost trailer from hitting that school bus. Trailer brakes and breakaway systems are part of a daily DOT driver’s inspection, but we rarely find the trailer getting the scrutiny given to the truck.

Recommendation: In your inspection documents, include prompts to periodically examine braking systems and conduct breakaway checks.

4. Trailer Connection Safety Chains
This gets confusing because of some clarity issues in the FMCSR. General-use trailers are covered in FMCSR 393.70(d). A reading of that paragraph makes it sound as though it only applies to semi-trailers and tow-dollies except for one “shall” reference in 393.70(d)(6) that references “tongue eye or other hitch device.” General-use trailers are “semi” trailers, meaning the rear is supported on its own axle and at least some of the load is supported by the towing vehicle. When it comes to securement devices, typically chains, this rule prevails. Some people also read FMCSR 393.71(h)(10)(ii) that requires crossed chains and think it applies to our trailers. It does not. There is nothing wrong with crossed chains, but in this case, the rule only applies to hinged tow bars used in drive-away/tow-away operations. The rule that applies to utility trailers – 393.70(d)(6) – does not require chains to be crossed. In fact, it doesn’t even require two chains. Two chains usually are used to meet the strength requirement of the rule. Strength of the chain is not spelled out, but it is required that the chain provide strength, security of attachment and directional stability. Strength is defined in rule 390.70(d)(3) as not less than the gross weight of the vehicle being towed, and that includes the means of attachment of the chain to the trailer tongue. I once found a 7/16th-inch safety chain pair connected to a trailer tongue with a 5/16th crossarm carriage bolt. I think that’s what the rule was intended to prevent.

Whether you cross them or not, here is what the chains are to accomplish in simple language:

  • They should be strong enough to hold the trailer in case of disconnect.
  • They should only be long enough to allow turns.
  • They should be short enough that the tongue will not strike the ground if disconnected.
  • They should be reliably connected to the towing vehicle.
  • If one chain is used, it must be attached to the right of the centerline to prevent the tongue of the trailer from projecting into oncoming traffic in case of a disconnect.

A Final Piece of Advice
Here is my final advice that also comes from experience. When I bring up these issues to utilities and contractors, I often get pushback because there have not been instances of these issues causing incidents in their fleet. That may be true, but it is worth noting that these rules were established after considerable review and debate among industry professionals. It’s also important to realize that most of these rules were developed in post-incident investigations. Crashes are not caused by the parts that work correctly.

About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn, CUSP, has devoted the last 22 years to safety and training. A noted author, trainer and lecturer, he is a senior consultant for the Institute for Safety in Powerline Construction. He can be reached at

A Practical Review of the ANSI A92.2 Standard

This is a review of ANSI/SAIA A92.2-2015, “American National Standard for Vehicle-Mounted Elevating and Rotating Aerial Devices.” As a consultant, investigator and auditor, I have been surprised time and again that people who should know this standard do not know it that well. Most fleet managers are familiar with the rules, which is important because the A92.2 standard obligates owners of aerial lifts to be held liable for equipment they sell in certain scenarios. On the employee side, a working knowledge of A92.2 can prevent incidents and loss of life. In fact, a recent live-line barehand training class was what inspired this topic. We found that a bucket truck had the leasing company’s logo sticker adhered down both sides of the insulated boom section. That bucket truck was designed and rated for barehand use at 500 kV, yet a vinyl-plastic printed logo installed by the leasing company, spanning two-thirds of the insulated length, could have had some serious implications for the safety of that boom.

In this article, we are going to review some of the information covered in the A92.2 standard. Readers should recognize that ANSI/SAIA consensus standards are protected by copyright, so we will not directly reproduce the text of the standard itself. The A92.2 standard can be purchased directly from the ANSI website (

The target audiences of this review are the owners and users of aerial lifts (bucket trucks) as well as safety departments, with the goal of familiarizing those parties with both the safety aspects and owner responsibilities regarding aerial lifts. Unlike many consensus standards, A92.2 has been incorporated by reference into the OSHA standard, meaning that certain parts of the A92.2 standard are enforceable by compliance officers. In addition, the incorporated parts of the standard essentially are “living” – they have been published in the Federal Register and made available to the public so that updates to the A92.2 standard are automatically part of the legally enforceable federal OSHA standard. Now that we have the applicability of the standard covered, let’s take a look at what the standard requires.

A92.2 Requirements
The various sections of A92.2 are specific to different groups and their relationship with an aerial device. The manufacturer is the principal audience for Sections 4 and 6. Section 7 is for dealers and the installer who puts the aerial device on the vehicle. The owner is primarily responsible for Section 8, which covers inspection and maintenance plus training of operators. Owners also are responsible for having a unit inspected and repaired if it is overloaded, turned over or makes an electrical contact (see 8.2.5). User responsibilities are addressed in Section 9 and include ensuring that only trained personnel are allowed to operate the aerial device; the section also states what those trained personnel are required to know. Owners and users share the Section 9 and 10 responsibilities.  

Paragraph 1.1.1 of the A92.2 standard defines the equipment covered. Those covered devices are vehicle-mounted aerial devices, including extendable (telescoping) and articulating boom platforms, and ladders and towers mounted on trucks, trailers and all-terrain vehicles.

Paragraph 1.2 sets out the purpose of the standard, which is to prevent accidents and injuries by standardizing ratings for the aerial lifts covered, and to assure an understanding of the responsibilities of manufacturers, dealers, brokers, installers, lessees, lessors, maintenance personnel, operators, owners and users.

While the design and manufacturing standards covered by A92.2 affect those units newly manufactured after the June 2016 effective date, all other provisions of A92.2 apply to both new and existing units delivered by sale, lease, rental or by any other form of beneficial use on or after the effective date.

Part 2 of the standard covers references related to design; Part 3 covers definitions particular to the standard; and Part 4 is about controls. Operators of aerial devices are familiar with many control schemes of various manufacturers, but there are a few rules that need particular attention as I have seen some of these controls “tricked out” by operators.

Paragraph 4.3.1 requires controls to be clearly identified and protected from damage and unintentional operation. That means when trees or an operational error knocks off the enclosure surrounding the controls, the bucket is out of service. It’s the same for the control labels. If you can’t read them, the boom doesn’t fly, no matter how familiar you are with the controls. The labels are readily available, so there isn’t any reason they can’t be replaced well before they are no longer legible. Every aerial device must have controls at the bottom of the boom that are labeled and protected from inadvertent operation or damage.

Paragraph requires controls to have an enabling or unlocking action designed to prevent inadvertent movement of booms by bumping controls. This is where some users have tricked out controls by taping down levers or actuators. As with any safety mechanism, defeating it is against the rules, but those levers and actuators get taped down more than you might think.

Paragraphs 4.4.2, “Boom Securing,” and 4.4.3, “Platform Security,” are related to each other and critical. Transport creates impact stresses on buckets that result in mount failures and loss of buckets, usually when they’re in the air with people inside them. Securing the boom not only protects weldment-to-fiberglass fatigue at the elbow, but it also keeps the boom from slamming down the bucket during rough road travel. All of us have seen buckets stowed with no landing support, but it is now a requirement to provide support, and for good reason: stabilizing the bucket and protecting it from stress that can shear the bucket from the boom mount. If your crews tend to leave hoists and tools in the bucket during transport, these two features – boom straps and bucket support – will help to relieve the stress that bouncing tools contribute to bucket mount damage.

Anchorage/fall protection requirements are found in paragraph 4.9.4. Attachments are to be designated by the manufacturer and rated at 3,600 pounds per person. An important inclusion here is that the attachment itself is to be rated but not necessarily the boom or bucket it is attached to. As the rule states in a note to paragraph, “Strength Requirement,” this does not imply that the aerial device is meant to meet or comply with this load requirement. It is imperative that employers look closely at the fall protection they provide and ensure it is the best choice for bucket use.

Bucket Design and Application
The A92.2 standard is the final word on design and application of buckets and booms used in line work. There are three types of buckets: non-insulating for use with insulating liners; non-insulating for use without insulating liners; and insulating buckets. 

Paragraph, non-insulating with liner: This bucket is made from non-conductive materials with a tested, insulated liner installed. The basket must be identified as non-insulating. The liner must be supported by the bottom of the bucket, and the bucket cannot have drain holes or an access opening.

Paragraph, non-insulating, not designed for use with liners: This bucket may be constructed of conductive or non-conductive material, must be identified as non-insulating, and may have drain holes and access openings.

Paragraph, insulating buckets: These buckets are constructed from non-conductive material and have no drain holes or access openings.

5.1.2: Insulating Aerial Device Categories
There are five categories of insulating aerial devices. Each category has special design characteristics to accommodate the design use. They are not all created equal, and how a device is used in the field must match its design category.

Category A: This is a bucket designed for barehand use. In Category A buckets, the boom – not the bucket – is the primary means of protection for the worker. These buckets must have all of the conductive components bonded together at the boom’s working (hot) end. Category A buckets have an electrical testing system installed at the lower end of the insulating upper boom. For Category A booms designed for work above 138 kV, a corona ring is required to be installed at the upper end of the boom and bonded to the conductive components. Category A booms may be used as gloving platforms if they meet the cover requirements of paragraph 4.1 of the A92.2 standard. The cover specified in 4.1 is an insulating cover over the lower metal boom tip that is exposed to conductor contact to prevent the upper end of the conductive boom from contacting energized conductors.

Category B: This bucket is commonly referred to as a gloving bucket, but the criteria for Category B is related to the boom, not gloving use. Category B buckets have an insulating boom equipped with a test electrode system at the lower end. The boom itself is considered a secondary level of protection for the worker. Here, the primary means of protection is use of insulating tools, which can be hot sticks and rated insulating cover. A Category B bucket can be designed and used for gloving if it meets an additional requirement of paragraph 4.1: an insulating cover over the lower metal boom tip that is exposed to conductor contact. Category B insulating buckets and insulating booms are not designed for direct uninsulated contact with energized conductors even though they are tested for insulating value.

Category C: Like Category B, the designation for Category C is the design of the boom – not use. Category C is a boom with a lower test electrode, and the boom and basket are designed as secondary protection, whereas insulated tools are primary protection for the worker. Category C is limited to work on electrical systems below 46 kV. For Category C booms to be used for gloving (below 18kV), the lower metal boom tip must be covered with insulating cover.

Category D: Category D booms are insulating but do not have test electrode systems installed, and no metal boom-tip covers are required for use as a gloving platform. These booms are a secondary means of protection, whereas the primary means of protection is use of insulating tools – better known as “sticking” – not distribution gloving work methods. Work from this platform is on systems less than 46 kV.

Category E: Category E aerial booms are designed for low-voltage applications. The primary means of protection are insulating guards or isolation. Category E booms are nameplate-rated at voltages of 20 kV, 5 kV, and 1 kV and below.

5.2.2: Hydraulic Vacuum Prevention
Hydraulic vacuum is a phenomenon that can happen with loss of hydraulic pressure in the boom or controls. It happens when a high-reach aerial device, configured in a high angle, leaks hydraulic fluid due to pressure loss or a leak at the lower end of the boom. With the boom elevated, the weight of the hydraulic fluid in the hoses is sufficient to pull a partial vacuum in hydraulic lines. The issue is that the partial vacuum is conductive and can result in a flashover of the hydraulics if the boom or basket is energized, particularly in Category A barehand applications. For this reason, a vacuum prevention system is installed. If a vacuum should occur, the control system opens and admits air into the leaking line, lowering the conductivity of the hose by eliminating the vacuum. These valves – commonly known as atmospheric valves – are mounted so that they can be readily checked, tested and replaced in the field.

A note here: The A92.2 standard does not specifically call out inspection of vacuum prevention systems as a frequent inspection item. The frequent-check items include safety devices, which the vacuum valves are. In A92.2, paragraph 6.4, “Manuals,” the location of and methods for testing the valves are required information for operator manuals. Here, the testing of vacuum valves is listed as a periodic check. However, most barehand operators, recognizing the nature of vacuums in hoses as compromising the upper boom, perform these checks every day before use.

8.2: Frequent and Periodic Inspections and Tests
Frequent inspections are those daily to monthly inspections. The frequency is determined by the employer according to frequency of use of the equipment and wear and tear. In any case, the frequency of inspection established by the employer should guarantee that worn or deficient components will be found before they reach failure mode. The A92.2 standard lists those pre-use daily frequent inspections as including walkaround visual inspection; controls in operation; labels and covers; fiberglass inspection; hydraulic leaks and hoses; warning and instructional tags and signs; safety devices (like atmospheric valves); electrical systems, including test and gradient protection (corona rings and bonding); aerial operation setup using lower controls; emergency stops; outriggers; and interlocks. There is no requirement in A92.2 for records of frequent inspections other than deficiencies being tagged, reported and repaired.

Periodic inspections are those typically conducted by qualified mechanics. The frequency of periodic inspections is established by the manufacturer and employer, and inspection and maintenance records are required to be kept for five years.

8.1: Owner’s General Responsibilities
I mentioned at the beginning of this article that the A92.2 standard established some very specific responsibilities for the owner of an aerial device, including those regarding transfer or sale of the device. In particular, the rule requires owners to comply with the testing, maintenance, modification, training and inspection requirements. It calls out the responsibilities of the owner to meet the requirements above and repeats the rules for frequent and periodic inspection, requiring those tasks to be conducted by a qualified person. Owners should be advised that these requirements are known in civil litigation as standards of care, upon which claims of negligence are based.

8.2.5: Post-Event Inspection and Tests
This section requires that a device exposed to any stress in excess of design stress, both structural and electrical, must be removed from service, inspected and tested. The obligation is to assure the integrity of the stressed components or permanently remove them from service. The required tests are outlined in 8.2.4, but any additional non-destructive tests that may be indicated by the type of incident also are required.

8.7: Change of Ownership
When an owner sells an aerial device, the owner must provide the manufacturer’s manuals with the unit at transfer of ownership. The new owner has 60 days to notify the manufacturer of the transfer and their contact information. The purpose of this rule is to leverage the detailed informational records maintained by the manufacturers of aerial equipment. The manufacturers have committed to keeping detailed records of the ownership and transfer of their equipment so that they can readily inform owners if an issue is discovered. The notifications required by this rule help to meet that end.

8.1.2: Training, Retraining and Familiarization of Operators
In the training of employees, with the exception of powered industrial trucks as well as cranes and derricks in construction, OSHA does not detail the specifics. The employer is expected to establish requirements, conduct training and be able to defend their programs to OSHA. Of all the utility-related consensus standards, the A92.2 standard is singularly detailed in its requirements for training of operators. Keeping in mind that this consensus standard is the civil liability standard of care, you should consider incorporating this training agenda into your company’s training curriculum for bucket truck operators. The curriculum includes more than a dozen topics. Prescribed in more detail than described here, the topics include the purpose, use and care of operator manuals; responsibilities with malfunctions; safety features and prohibited override; operating systems; stability factors; placards and decals; daily inspections; safety rules of the NESC; authorizations to operate; securing equipment; operator warnings and instructions; fall protection; practical demonstration of skill; and proper stowage for transport.

The committee that developed the A92.2 standard recognized that users play a significant role in the safety of aerial devices and that they also play a role in the performance and safety of used equipment sold on the market. As we have seen, the A92.2 standard does exactly as its published purpose states: It prevents accidents and injuries by standardizing ratings for the aerial lifts covered and provides an understanding of responsibilities for manufacturers, dealers, brokers, installers, lessees, lessors, maintenance personnel, operators, owners and users. We hope you will do your part and help the A92.2 standard do its part by incorporating the provisions of the standard into your operating procedures.

About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn, CUSP, has devoted the last 22 years to safety and training. A noted author, trainer and lecturer, he is a senior consultant for the Institute for Safety in Powerline Construction. He can be reached at

Arc Flash and Face Masks

Recently I have received numerous emails and phone calls regarding respiratory air-filtering masks rated for arc flash. I’m sure everyone reading this, no matter what country you’re in, is aware why that’s the case: the COVID-19 pandemic.

If you are a regular reader, you know it is my methodology to address topics by first citing the related safety standards in effect and then discussing the issue from a practical perspective typically related to the utility industry. This time is no different – for the most part.

Initially, the use of masks during the pandemic was limited as effective respiratory protection and still is for the public per the Centers for Disease Control and Prevention. As far as OSHA was concerned regarding workplaces, the only approved mask was the NIOSH-approved N95 filtering facepiece respirator (FFR). The N95 rating means that the mask meets the criteria for effective filtering of airborne particulates and moisture at 95%. The rating system also was established by NIOSH. It is important to understand that the N95 rating is based on the assumption that the masks are utilized by trained users meeting the OSHA respiratory protection worker training and fit-testing standard, which also can require a medical evaluation of the user.

As a result, no authority in government recommended public use, later adding that N95 masks needed to be available to trained health-care and emergency personnel who could put them to their best use. It also is important to understand that the N95 mask was not tested as a viral barrier; it was recognized as effective at preventing the spread of an individual’s exhaled, airborne droplets that could contain the SARS-CoV-2 virus that causes COVID-19.

At the time of this writing, OSHA is still recommending engineering, administrative and procedural changes to limit the need for N95 respirators in an effort to preserve them for the health-care industry.

Limited Protection
With that knowledge in place, let’s move forward. In our industrial environment, even the N95 mask has limited protection for the user. The mask is more effective at capturing water droplets in the breath of an infected person who wears it. The CDC is now recommending that members of the public use simple cloth face coverings when in a public setting to slow the spread of the coronavirus. Doing so will help prevent people who may unknowingly have the virus from transmitting it to others.

Based on the above, we know that the FFR has limited use and that cloth coverings, such as a neckerchief, are recognized as an effective alternative. Now, let’s get to an analysis of the exposure. Arc flash assessments drive the level of protection based on distance and arc energy. It is fair to assume that an arc flash with the energy to ignite a face covering likely means you should be wearing an arc-rated face shield and a balaclava. From a practical perspective, if you are wearing a face shield, the energy passing the shield would not likely ignite a face covering made from cotton or another natural-fiber cloth.

A Valuable Technical Treatment
For the rest of this installment of “Focus on Fleet Safety,” I decided to turn to Hugh Hoagland, an industry-recognized source of information and guidance for all things related to arc flash. He is a senior consultant at ArcWear ( and a senior partner at e-Hazard (, both recognized authorities in the utility industry. Hugh penned the following valuable technical treatment of testing performed by his companies, and I decided it was worth publishing here in its entirety.

Hugh Hoagland: Did I ever think I would write an article or a paper on this subject? Absolutely not. Fortunately, over the past 25 years of arc testing, I have come across some odd situations that required electrical workers to wear respirators. The first testing was for a mining association; the second was done at U.S. Department of Energy sites that contained radioactive beryllium dust exposures; and the most recent was this past summer when the state of California instituted guidance that utility workers in wildland fire exposures need to have proper respiratory protection from smoke. These workers, who could be disconnecting power to prevent further damage, are what we now refer to as “essential workers.” The ways in which we protect them, as best we can, are critical.

There is no ASTM, IEC or NFPA standard for testing respirators for arc flash. There is an NFPA standard for firefighters’ self-contained breathing apparatuses, but it does not cover arc flash. An e-Hazard blog found at contains help on the COVID-19 crisis as it relates to electrical workers, with assistance from publicly available ArcWear test data. The blog provides the public test reports and a peer-reviewed paper that support using firefighter respirators as non-contributory in an arc flash to certain levels, as well as reports showing a low risk for using common respirators, including N95 masks, under a face shield or hood at certain levels. 

The ASTM F18 committee is attempting to address concerns by providing an easier labeling requirement for the cloth face coverings recommended by both the CDC and a special OSHA COVID-19 document indirectly recommending CDC guidelines, if needed, in work settings. The ASTM F18 committee asked David Wallis – who is now an electrical safety consultant after retiring from OSHA – for his opinion. Wallis said, “I can give you general industry cites for requirements prohibiting ignitable face masks under certain conditions:

“§1910.269(l)(8)(iii) prohibits ‘clothing that could melt onto his or her skin or that could ignite and continue to burn when exposed to flames or the [employer’s estimated] heat energy.’ The note following that provision generally prohibits clothing made from acetate, nylon, polyester, rayon and polypropylene, either alone or in blends. Consequently, any face mask, at a minimum, would generally need to be made from all-natural fabrics regardless of the presence of any arc-rated head and face protection.

Ҥ1910.269(l)(8)(iv) requires the outer layer of clothing worn by an employee to be flame resistant if the employee is exposed to contact with energized parts operating at more than 600 volts or if two other less likely conditions are present. There is an exception for clothing covered by an exception to paragraph (l)(8)(v), but none of those exceptions would apply to face masks. Thus, when there is no arc-rated protection, any face covering would generally need to be flame resistant.

“Subpart V contains equivalent requirements. The standards don’t require face masks to be arc rated as long as any required arc-rated protection is otherwise provided, but the masks would typically need to be FR or worn under arc-rated protection if made from non-prohibited fabrics.”

So, flame-resistant cloth face coverings, or FR CFCs, meeting ASTM F1506 would meet the OSHA requirements and CDC recommendations. A proposed change recently balloted in ASTM F1506 would allow smaller labels for these items. This change passed the committee with only one negative ballot and should be published in the next 60 days or so.

Non-Utility Operations
For non-utility work, NFPA 70E states the following: “130.7(C)(12) under the title Clothing and Other Apparel Not Permitted: Clothing and other apparel (such as hard hat liners and hair nets) made from materials that do not meet the requirements of 130.7(C)(11) regarding melting or made from materials that do not meet the flammability requirements shall not be permitted to be worn …

“Exception No. 2: Where the work to be performed inside the arc flash boundary exposes the worker to multiple hazards, such as airborne contaminants, and the risk assessment identifies that the level of protection is adequate to address the arc flash hazard [italics added], non-arc-rated PPE shall be permitted.” As long as these vital devices are covered, it is likely they will comply with both OSHA and NFPA requirements. Using FR CFCs that are compliant with ASTM F1506 will assure it.

So, every industry has options with the wording of current regulations to meet the needs of workers with little risk of creating another hazard in a potential arc flash.

Cloth face coverings assist in reducing your chances of spreading the coronavirus, if you are infected, and may reduce risk of contracting the virus, but only a true particulate respirator can offer complete protection. ArcWear testing indicates that wearing N95 masks under face shields, balaclavas and hoods can meet the requirement for complete protection, but there is some risk of ignition in certain conditions. Many utilities are using face shields and/or balaclavas, cloth face coverings with an arc rating, and true respirators to protect their workers and meet OSHA requirements as well as the CDC guidelines. All we are doing should be to keep workers safer. You are essential. Thank you all for your service!

And thanks to you, Hugh, for sharing your expertise. Readers, you should now have the information necessary to make good decisions regarding this topic for yourself, your co-workers and the industry. Don’t hesitate to contact Hugh ( or me ( if you have any questions.

About the Author: After 25 years as a transmission-distribution lineman and foreman, Jim Vaughn, CUSP, has devoted the last 22 years to safety and training. A noted author, trainer and lecturer, he is a senior consultant for the Institute for Safety in Powerline Construction. He can be reached at

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