Update on Electric Power Generation, Transmission, and Distribution Final Rule

1. Electric Power Generation, Transmission, and Distribution and Electrical Protective Equipment Final Rule Updated 2-18-2015 Effective Dates and Best Practice Revisions based on the Final Rule

2. Electric Power Generation, Transmission, and Distribution and Electrical Protective Equipment Final Rule Updated 2-18-2015 Final Rule was Published on April 11, 2014 Became Effective July 10, 2014 Temporary Enforcement Policies were issued on: June 20, 2014 Extended on October 28, 2014 and December 16, 2014 Revoked Temporary Citation Policy on February 18, 2015

3. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Training No Enforcement Delays per final rule but OSHA will not site employers that are training according to the Best Practices for the training provision necessary to comply with the Final Rule.

4. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Information Transfer No Citations will be issued to host employers under the information transfer provisions provided that after April 30, 2015 they provide all information other than maximum switching-transient voltages required by the standards.

5. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Information Transfer ET&D Best Practice PRACTICE DESCRIPTION: Contractor will ensure that the information (included but not necessarily limited too) listed on the attached form (or other types of records that provide to accomplish the objective of information transfer) has been collected from the Host employer and communicated to the person in charge of related tasks. The contractor must communicate hazardous conditions to the Host Employer unrelated to the original scope of work that were not communicated by the host during the information transfer and that will not be abated/corrected by the contractor. The form provided is an example of how to document this communication.

6. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Job Briefing No Citations until April 30, 2015 of the standards that require the employer to provide employee in charge with all available information on existing characteristics and conditions.

7. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Job Briefing ET&D Best Practice PRACTICE DESCRIPTION: The Person In Charge (or a designated representative) shall document job steps , hazards to be encountered, and steps taken to control/eliminate hazards by doing the following: NEW C. Existing characteristics and conditions (provided by host)

8. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Job Briefing ET&D Best Practice BENEFITS (Added) Ensures employees receive information about the known characteristics and conditions of the system they are working.

9. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Minimum Approach Distances Employers have until April 1, 2015 to comply with revised MADs for voltages of 5.1kV and above. No citations until January 31, 2016 for voltages of 169.1 kV and more for employer to determine the maximum anticipated per- unit transient overvoltage. If peer review is not available before May 1, 2015, OSHA may extend this deadline .

10. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Minimum Approach Distances No citations until January 31, 2016 for voltages of 79.6 to 169.1 kV for employer to determine the maximum anticipated per-unit transient overvoltage as long as the anticipated transient overvoltage, phase to ground is 3.0 per unit. If peer review is not available before May 1, 2015 OSHA may extend this deadline . Information to help employers establish minimum approach distances appears in appendices to the standards.

11. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Incident Energy Calculations No citations until March 31 , 2015 for the standards that require the employer to make a reasonable estimate of the incident heat energy exposures as a result of electrical arc hazards.

12. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Flame Resistant Clothing Employers must ensure outer layer of clothing worn by an employee is flame resistant under certain conditions. No citations issued before April 1, 2015 for employers for failure to wear flame resistant pants as long as employees are wearing 11-ounce or heavier weight cotton pants.

13. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Arc Rated Protection Employers have until April 1, 2015 to comply with the standards that require Arc-Rated Protective Clothing and other protective equipment. No Citations for failure to provide protective clothing or equipment rated higher than 8 cal/cm 2 until after August 31, 2015

14. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Fall Protection in Aerial lifts No Citations until March 31, 2015 for line clearance tree-trimming employers that ensures employee uses a body belt and lanyard attached to the boom or basket of the aerial lift.

15. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Fall Protection in Aerial lifts No Citations from March 31 to December 31, 2015 for line clearance tree-trimming employers that are actively testing fall restraint systems in the type of bucket at issue and ensure employees use a body belt and lanyard attached to the boom of the aerial lift until the fall restraint system is put in place.

16. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Fall Protection in Aerial lifts For work covered by the standards, the following enforcement policies apply to any bucket-type aerial lift that does not have a suitable anchorage built into the bucket. No Citation provided: 1. A fall arrest system is in place and complies with 1926 Subpart M 2. Aerial lift is parked and brakes set with outriggers extended 3. Employer has taken reasonable precautions to prevent an employee from being ejected out of the bucket

17. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Fall Protection in Elevated Locations on Poles, Towers and Similar Structures Employees must use personal fall arrest systems, work-positioning equipment or fall restraint systems on elevated structures located more than 4 feet above the ground. No citations until May 31, 2015 as long as employers comply with standards that were in effect on April 11, 2014

18. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Fall Protection When Performing Aerial Work on a Lattice Structures ET&D Best Practice New PRACTICE DESCRIPTION: Fall hazards associated with aerial work performed on lattice structures shall be assessed, and fall hazard mitigation plans developed when working in or on a horizontal or vertical position/surface .

19. 29 CFR 1910.269 and 29 CFR 1926 Subpart V Enforcement Dates Underground Installations, Work in Manholes and Vaults As of February 28, 2015 , work underground, in manholes and vaults must comply with the new standards.

20. 29 CFR 1910.269 and 29 CFR 1926 Subpart V OSHA Partnership Electrical Transmission & Distribution

21. General Partnership Goals Analyze accident and incident data and statistics Identify common cause factors related to: Fatalities Injuries and illnesses Develop recommended Best Practices for each identified cause. Develop Best Practice implementation strategies

22. Partnership Future Objectives Continue to perform the following: Monitor injury and fatality data and trends and identify additional cause factors Expand the training efforts and resources Developing additional Best Practices Increase communication, education, involvement Expand services provided on the Website. Visit: www.powerlinesafety.org

23. Final Rule General Industry 1910.137 Electrical Protective Equipment 1910.269 Electrical Power Generation, Transmission, and Distribution Construction 1926.97 Protective Equipment 1926 Subpart V Electrical Transmission and Distribution

24. Why Revise the Rule? The existing Electric Power Transmission and Distribution for Construction standard was issued in 1972 and referenced consensus standards of that time. The later Electric Power Generation, Transmission, and Distribution for General Industry (Operation and Maintenance) standard, issued in 1994, also needed updating based on advances in electrical safety technology.

25. Why Revise the Rule? As revised, the standards create a unified set of requirements to help employers more effectively establish effective safety-related work practices to protect their workers. Its all about improved safety and as leaders, we have no greater responsibility than the safety of our people.

26. Benefits of the Revised Rule OSHA expects the updated standards to prevent at least an additional 118 workplace injuries and 20 fatalities annually. The Agency estimates the net monetized benefits of the final rule to be about $130 million annually ($179 million in benefits minus $49 million in costs). Revised standards are easier to understand and to apply, improving safety by facilitating compliance.

27. Significant Changes to the Standards Definitions Host Employer: An employer that operates, or that controls the operating procedures for, an electric power generation, transmission, or distribution installation on which a contract employer is performing work covered by [the standard] Contract Employer: An employer, other than a host employer, that performs work covered by [the standard] under contract.

28. Significant Changes to the Standards Host Employers and Contractors New or revised provisions for host and contract employer meetings/job briefings to share safety- related information with each other and with line workers and other associated employees. Required job hazard and risk analysis and assessment will improve work operations and strategies to utilize the most effective methods and techniques for performing tasks.

29. Significant Changes to the Standards General Training The degree of training must be determined by risk to the worker for the hazard involved. Qualified workers must have training to recognize and control or avoid electrical hazards present at the worksite.

30. Significant Changes to the Standards General Training Line-clearance tree trimmers must have training to distinguish exposed live parts and to determine the voltage on those parts, and they must have training in minimum approach distances and how to maintain them. It is no longer necessary for employers to certify that workers are proficient in safe work practices.

31. Significant Changes to the Standards Fall Protection The standard now provides updated fall protection requirements for employees working from aerial lifts and on overhead line structures. Qualified workers must use fall protection when climbing or changing location on poles, towers, or similar structures unless climbing or changing location with fall protection is infeasible or creates a greater hazard than climbing or changing location without it.

32. Significant Changes to the Standards Fall Protection No Citations until March 31, 2015 for line clearance tree-trimming employers that ensures employee uses a body belt and lanyard attached to the boom or basket of the aerial lift. No Citations from March 31 to December 31, 2015 for line clearance tree-trimming employers that are actively testing fall restraint systems in the type of bucket at issue and ensure employees use a body belt and lanyard attached to the boom of the aerial lift until the fall restraint system in put in place.

33. Significant Changes to the Standards Fall restraint system A system that prevents the user from falling any distance Work positioning equipment A system rigged to allow an employee to be supported on an elevated vertical surface and work with both hands free while leaning Personal fall arrest equipment A system used to arrest an employee in a fall from a working level

34. Significant Changes to the Standards Fall Protection Fall protection equipment rigged to arrest falls is considered as one or more components of a fall arrest system and must meet the applicable requirements for the design and use of those systems.

35. Significant Changes to the Standards Fall Protection Fall protection equipment rigged for work positioning is considered as work positioning equipment and must meet the applicable requirements for the design and use of that equipment.

36. Significant Changes to the Standards Fall Protection Fall arrest equipment must be capable of passing a drop test after exposure to an electric arc with a heat energy of 405 cal/cm 2 if the workers using the fall protection are exposed to flames or electric arc hazards.

37. Significant Changes to the Standards Fall Protection On and after April 1, 2015 , work-positioning equipment must be rigged so that workers can free fall no more than 0.6 meters (2 feet). 1910.269(g)(2)(iv)(D) Information on the inspection of work-positioning equipment appears in appendices to the standards.

38. Significant Changes to the Standards Minimum Approach Distances and Insulation Revised minimum approach distances for voltages of 5.1 kV and more become effective on April 1, 2015 . No citations until January 31, 2016 for voltages of 169.1 kV and more for employer to determine the maximum anticipated per-unit transient overvoltage. If peer review is not available before May1, 2015, OSHA may extend this deadline.

39. Significant Changes to the Standards Minimum Approach Distances and Insulation No citations until January 31, 2016 for voltages of 79.6 to 169.1 kV for employer to determine the maximum anticipated per-unit transient overvoltage as long as the anticipated transient overvoltage, phase to ground is 3.0 per unit. If peer review is not available before May 1, 2015 , OSHA may extend this deadline. Information to help employers establish minimum approach distances appears in appendices to the standards.

40. Significant Changes to the Standards Employer must establish minimum approach distances based on the new requirements. For voltages up to 72.5 kV the default distances remain the same. For voltages exceeding 72.5 kV, the distances must be based on calculations in the revised standard. D = (TOV) x (C + a) + M

41. Significant Changes to the Standards MAD is based on the probability of 1/1000 of flash over. Maximum transient overvoltage (TOV) adjusted to 3.5 from 3.0. Appendix B includes TOV tables The Agency developed an online calculator.

42. Significant Changes to the Standards MAD Employees must put on and take off rubber gloves where the worker cannot reach in the MAD.

43. Significant Changes to the Standards Protection from Flames and Arc-Flash Hazards The employer must assess the workplace to identify workers exposed to flame or electric-arc hazards. No citations until March 31, 2015 for employers that make a reasonable estimate of the incident heat energy of any electric-arc hazard to which a worker would be exposed.

44. Significant Changes to the Standards Protection from Flames and Arc-Flash Hazards Employers must ensure outer layer of clothing worn by an employee is flame resistant under certain conditions. No citations issued before April 1, 2015 for employers for failure to wear flame resistant pants as long as employees are wearing 11-ounce or heavier weight cotton pants. Information on protecting workers from flames and electric arcs appears in appendices to the standards.

45. Significant Changes to the Standards De-energizing Transmission and Distribution Lines and Equipment Multiple crews working together on the same lines or equipment must either: (a) coordinate their activities under a single worker in charge and work as if all of the employees formed a single crew; or (b) independently comply with the standard and, if there is no system operator in charge of the lines or equipment, have separate tags and coordinate deenergizing and reenergizing the lines and equipment with the other crews.

46. Significant Changes to the Standards Protective Grounding Employers may use insulating equipment other than a live-line tool for placing grounds on or removing grounds from circuits of 600 volts or less under certain conditions. Information on protective grounding for de- energized lines appears in appendices to the standards.

47. Significant Changes to the Standards Underground Installations Special precautions apply when employees perform work that could cause a cable to fail.

48. Significant Changes to the Standards Electrical Protective Equipment The Electrical Protective Equipment for Construction standard applies to all construction work, not just electrical power generation, transmission, and distribution work. Replaces the existing construction standards incorporation of out-of-date consensus standards with a set of performance-oriented requirements that is consistent with the latest revisions of the relevant consensus standards.

49. Significant Changes to the Standards Electrical Protective Equipment The final rule recognizes a new class of electrical protective equipment, Class 00 rubber insulating gloves. The standards adopt new requirements for electrical protective equipment made of materials other than rubber.

50. Significant Changes to the Standards Foot Protection The Agency revised the General Industry Foot Protection standard to clarify that an employer must ensure that workers use protective footwear as a supplementary form of protection when the use of protective footwear will protect the workers from electrical hazards, such as static-discharge or electric-shock hazards, that remain after the employer takes other necessary protective measures

51. Electric Power Generation, Transmission, and Distribution and Electrical Protective Equipment Final Rule Additional information is available on OSHAs Electrical Power Generation, Transmission, and Distribution Standard webpage Questions and Answers on the final rule PDF * A memorandum to OSHA field offices regarding enforcement of some of the fall protection requirements in the final rule PDF * A memorandum to OSHA field offices regarding enforcement dates PDF *,

52. Electric Power Generation, Transmission, and Distribution and Electrical Protective Equipment Final Rule Updated 2-18-2015 Effective Dates and Best Practice Revisions based on the Final Rule