EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

1910.269 Revision Implementation

Utility Line Clearance Contractors Perspective

Joseph F. Tommasi Corporate Director of Safety – The Davey Tree Expert Company President – The Utility Line Clearance Coalition Chair – Rigging and Tree Removal Task Group ANSI Z133 Committee

EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

The Utility Line Clearance Coalition

Asplundh Tree Expert Company, Burford’s Trees, Inc., The Davey Tree Expert Company Lewis Tree Service, Inc., Lucas Tree Experts, Inc. McCoy Tree Surgery, Inc., Nelson Tree Service, Inc. Penn Line Service, Inc. Townsend Tree Service, Inc. Trees, Inc. Wright Tree Service, Inc.

EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

Line Clearance Arborist at Work

EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

Line Clearance Work Methods

Pruning and Sectional Removal from Aerial Device

Pruning and Sectional Removal by Climbing Crew

Tree Removal by a Felling Team from the Ground

Mechanical Pruning with Boom Mounted Saws

Manual Brush Cutting & Mechanized ROW Mowing

Herbicide and Tree Growth Regulator Treatment

Site or Project Specific per Contract w/ Utility

EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

Line Clearance

Section 1910.269(x) defines line-clearance tree trimming as “[t]he pruning, trimming, repairing, maintaining, removing, or clearing of trees, or the cutting of brush, that is within the following distance of electric supply lines and equipment: (1) For voltages to ground of 50 kilovolts or less – 3.05 meters (10 feet); (2) For voltages to ground of more than 50 kilovolts – 3.05 meters (10 feet) plus 0.10 meters (4 inches) for every 10 kilovolts over 50 kilovolts.”

EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

1910.269 Application for Line Clearance

Paragraphs (a)(2), (a)(3), (b), (c), (g), (k), (p), and (r) of this section apply to line-clearance tree-trimming operations performed by line-clearance tree trimmers who are not qualified employees. (a)(2) Training (a)(3) Information Transfer (b) First Aid (c) Job Briefing (g) Personal Protective Equipment (k) Materials Handling and Storage (p) Mechanical Equipment (r) Line Clearance Tree Trimming Operations

EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

1910.269(a)(2) Training

LCTT employees: Safety practices of 1910.269 that pertain to

their respective job assignments Determine Live Parts, Nominal Voltage, MAD,

and Safe Practices to maintain MAD Emergency Response Procedures Other necessary safety practices, see ANSI

Z133-2012 Arboricultural Operations – Safety Requirements, Training Outline

Risk Exposure and Work Method Based Continued Voluntary Documentation of

Demonstrated Proficiency by Employers

EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

1910.269(a)(2) Training

Education and Skills On-Job-Training

Use of e-LMS expands but is supplemental

Regular supervision and annual inspection to determine compliance

Follow-up training and retraining: New work procedures or equipment

Tasks performed infrequently

Performance based

EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

1910.269(a)(3) Information Transfer

New provisions require the host and line clearance contractor to share safety-related information

Of importance to the LCTT from the Host Utility

Locations of Circuits and Equipment

Nominal Voltages and Utility Specific MADs

Emergency Contacts and Procedures

Line Crew work activity that could affect our LCTT operations or vice versa

Process to Request De-energize, Ground and Test

EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

1910.269(a)(3) Information Transfer

Sharing Information from LCTT to the Host Utility

LCTTs do not work on the lines

They may not recognize the same hazardous conditions as a line worker

Would share information about downed lines, or broken poles that might be observed

Would share information about work activity such as tree removal risk and procedure, and staying out of the LCTT work area if host employees are present

Communications are usually verbal, email, or by Host specified means and process

EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

1910.269(c) Job Briefing

Subjects: Hazards associated with the job, work procedures

involved, special precautions, energy-source controls, and personal protective equipment requirements

Information learned from Host that pertains to specific job / project performed by LCTT Contractor

Number of briefings: Before start of work for each day or shift

Additional job briefings if significant changes occur

Based on nature and complexity of work

Job planning for one-person crews

EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

1910.269(g) Personal Protective Equipment

Employer PPE Hazard Assessment

Eye, Head, Hearing

Aerial Lift Fall Protection Fall Restraint, or Fall Arrest Systems???

LCTT Employer Must Assess, Determine, and Implement System by December 31, 2015

OSHA does not consider trees and wires lower level, however, we work over buildings, etc.

Minimize Possibility of Fall to Lower Level

Lanyard short as practicable, no more than 6ft.

Tree Climbing Fall Protection - (r) and Z133

Chainsaw Leg Protection - Z133

EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

1910.269(r): Line Clearance Tree Trimming Operations

EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

1910.269(r)(1)(iii) Electrical Hazards

Inspection of site and tree prior to work LCTT shall maintain Minimum Approach Distance Paragraph (l) does not apply to LCTT, nor do the FR

or arc-rated protective clothing requirements apply to LCTTs

Aerial devices, and ladders maintain MAD (r)(1)(iv) Insulated Pole Tool vs. Conductive Tool

Branches contacting energized conductors or within MAD may only be removed using insulating equipment

Tools constructed of a material with insulating qualities employer can demonstrate meet (j)(1)

Conductive tool (chainsaw) used after MAD is attained

If LCTT cannot maintain MAD, request the line be De-energized, Grounded & Tested by the Utility

EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

1910.269(r)(1)(iii) Electrical MAD

Historically LCTT MAD Tables Published In ANSI Z133, 2012 current edition, 5 yr. cycle

MAD Tables and Z133 are Under Revision OSHA Verified Phase to Ground Exposure Tables R-6 and R-7 Alternative MADs Includes Altitude Correction to 5, 10, 14k Ft Current Table Distances are similar to or

greater than R-6 and R-7 Customer Provided MADs

EEI Fall 2015 OSH Committee Conference 1910.269, Utility Line Clearance Contractors Perspective

Arborist Tools and Equipment

Chainsaws, also see 1910.266(e) No Drop Starting

Two Handed Grip

Leg Protection Required For Ground Operations - Z133

Climber Fall Protection

Rope, climbing, and rigging

Brush chippers

Sprayers for Herbicide Applications

Stump cutters

Brush Saws

The Z133 Standard contains Arborist Safety Requirements for Work Aloft, Pruning, Rigging, Tree Removal, Ground Work