By : John “Grizzy” Grzywacz, Professor Emeritus OSHA Training Institute
OSHA has been working on the updates for its “Electric Power Generation, Transmission, and Distribution” as well as the “Electrical Protective Equipment” standard. OSHA began the process in 2003 and issued the notice of proposed rulemaking in 2005. This proposal has been slowly making its way through the rulemaking process and according to sources in OSHA it has cleared the final hurdle of approval by the Office of Management and Budget (OMB). While OSHA has delayed the final rule announcement, this rule will certainly be published at some point, sooner rather than later, given its current status along the rule-making timeline.
Pro-active companies have been following the proposed OSHA updates and moving forward with implementation, in order to be well-positioned once the changes take place. Not only will this place them in a position of immediate compliance, but it also keeps them on the leading edge of safety.
This rule-making update for the “Electrical Protective Equipment” (Electrical PPE) standard, includes both the OSHA General Industry Codes of Federal Regulation (CFR) as well as creating an entirely new section in the OSHA Construction Codes of Federal Regulation. Historically regarding “Personal Protective Equipment” (PPE) OSHA frequently makes reference to specific consensus standards including the date of the edition of these standards. OSHA cannot require compliance with future editions which have yet to be published. Since all consensus standards are typically updated every couple of years, whereas OSHA standards take decades before they are updated, OSHA wanted to insure that the in-service care and use of electrical PPE was reflective of the most updated and latest ASTM consensus standards.
Instead of referencing specific ASTM standards which would have to include the date of a specific edition of these standard(s) to be complied with, as it has historically done, OSHA is taking a new approach in its regulatory language. In an unprecedented effort to affect compliance with the latest edition of these continually changing ASTM consensus standards OSHA is using performance-oriented requirement stating that “whatever test is used must reliably indicate that the equipment can withstand the proof-test voltage involved”. This would place the ‘burden of proof’ on the employer to establish that reliability which would be accomplished by following the most recent ASTM standards regarding the in-service care and use, which includes the proof testing of electrical PPE rubber goods (gloves, sleeves, blankets, etc.). This testing reliability would also presumably extend to the quality and accuracy of the testing.
Reputable testing laboratories such as Hi-Line Utility Supply, pro-actively update their protocols to conform with the latest editions of these ASTM testing standards and additionally have laboratory certification to further insure the accuracy and quality of their testing protocols.
Both employers whose employees use electrical PPE and now many utilities are sending their rubber goods to testing labs for the required periodic electrical proof testing. It is becoming imperative that you know more about your test lab. Especially since the burden of proof for regulatory purposes rests with the employer.
Be Prepared for Inquiries from OSHA. Always Ask Your Testing Lab:
Is your test lab, testing rubber goods to the latest edition of the ASTM standards?
Whether its gloves, sleeves, blankets, line hose, or hoods your test lab should be following the requirements of the most recent ASTM test standard for each product.
Is your test lab certified and accredited?
The Association of North American Independent Laboratories for Protective Equipment Testing (NAIL-PET) has very stringent requirements for accreditation and certification. NAIL for PET Accredited Rubber Goods Testing Labs, such as Hi-Line Utility Supply, have to undergo an extensive certification process on criteria such as the expertise of the staff, lab practices, and equipment calibration. Equipment maintenance, including traceability to the National Institute of Standards and Technology (NIST), combined with periodic site visits for verification. Accreditation is no easy task. How does your Rubber Testing Lab maintain compliance with ASTM and OSHA standards? Do you know what your lab is doing? Have you ever asked?
Have you ever visited your test lab to see their operation and how they test you rubber goods? Hi-Line Utility Supply, for example, not only welcomes its customers to visit their test lab, but frequently hosts open house events and safety seminars for their customers to observe, first hand, the pride and professionalism that is the foundation of the test lab.
How well you know your test lab may affect not only the safety of your workers but also your regulatory compliance vulnerability. This new OSHA requirement will change the way you look at your electrical testing lab. By implementing the new requirements early, you will be positioned for safety and compliance when the changes go into effect.
About the Author: John “Grizzy” Grzywacz or “Grizzy”, as he likes to be called has been recognized by OSHA’s National Office in Washington D.C. as both a National Electrical Code (NEC®) historian as well as “the best electrical safety trainer in the country!” Certainly at the very least Grizzy has been OSHA’s electrical safety guru and has been instrumental in shaping and interpreting OSHA policy and regulations over the years. Grizzy has appeared as an expert witness for OSHA, and served as chief OSHA investigator on complex electrical fatality investigations. For over two decades he has trained OSHA compliance officers in numerous areas, including Electrical Safety Standards, Power Generation Transmission and Distribution, Machine and Machinery safeguarding, and he has provided forensic analysis on electrical fatalities and accidents for OSHA. His electrical expertise has not only shaped OSHA policy but also OSHA’s Electrical Standards. Grizzy is currently a member of the ASTM F-18 Committee which writes the “Electrical Protective Equipment for Workers” standards. Currently, in addition to training numerous Federal Agencies as well as private sector Grizzy continues to train OSHA compliance officers and personnel coast to coast, as well as still providing investigative assistance to the Agency on fatality investigations and significant cases.
About the Contributing Author: Matt Dell is the owner of Hi-Line Utility Supply, a provider of lineman’s transmission and distribution tools, equipment, and services since 1960. Hi-Line’s two full service testing labs (Illinois & Massachusetts) test over 150,000 rubber gloves, sleeves, blankets, line hose, hoods and boots each year. With over 10,000 products in stock, Hi-Line guarantees every in stock order placed by 4PM Eastern ships the same day guaranteed. Hi-Line also offers custom grounds, tool repair, and fiberglass restoration. Matt can be contacted at (800)323-6606 email firstname.lastname@example.org. www.hilineco.com