OSHA Enforcement – “A Look Back for Electrical Contractors”
By: Paul Satti, M.S.,CHST – Technical Director, Construction Safety Council (CSC)
According to OSHA (www.osha.gov), electrical contractors paid over $ 750,000.00 in fines during a one year period, October 2011 through September 2012. The most frequently cited Federal OSHA standards to electrical contractors was to the Occupational Safety and Health Standard for the Construction Industry general wiring methods 29 CFR 1926.405, “Wiring Methods, Components, and Equipment for General Use” and unauthorized exposure to hazardous voltage as outlined by 1926.403. Other notable violations issued were related to electrical safe work practices and procedures referenced in NFPA 70E pursuant to the Occupational Safety and Health Standards for General Industry Section 29 CFR1910.333 “Selection and Use of Work Practices”. Any violation where exposure to hazardous voltage exists could be considered serious; a “serious” violation is issued where conditions are such that there is a substantial probability that death or serious physical harm could result. Serious violations carry a maximum penalty of $7,000.
Here are some general rules to remember when complying with OSHA’s general wiring methods standards and guidelines:
- Live parts of electric equipment operating at 50 volts or more must be guarded against accidental contact by cabinets or other forms of enclosures. 1926.403(I)(2
This means a panel cover equivalent to that used in permanent wiring is in place or a closed and locked door prohibits access by those who are not qualified electrical workers.
- Conductors entering boxes, cabinets, or fittings must be protected from abrasion, and openings through which conductors enter must be effectively closed. Unused openings in cabinets, boxes, and fittings shall also be effectively closed. 1926.405(B)
Make sure all cords are protected from abrasion and prohibit the use of wire, nails or staples to secure cords in place. When stringing up temporary lighting use the nobs provided by the light strand manufacturer and secure them with plastic zip-ties.
- Boxes must be closed by covers securely fastened in place. 1926.405(B)
Use the finished door to protect against hazardous voltage. If damage to the door could occur, use an old permanent door in its place then switch it out when the project is nearing completion; beware of cardboard temporary doors that can be put in place with magnets. These temporary panel covers have been shown to be less than effective in preventing unauthorized access and may be easily by-passed.
Aside from the electrical related work, the next most frequently cited OSHA standard to electrical contractors was aerial lift violations. Only authorized person shall be allowed to operate an aerial lift and remember that all boom type aerial lifts require the operator to be protected from falls by wearing a full body harness and attaching a lanyard to the manufacturer’s identified anchorage point. OSHA defines an authorized person as someone who has been approved or assigned by the employer to perform a specific type of duty or duties or to be at a specific location or locations at the jobsite. To help identify your “authorized persons” and to ensure the proper training of aerial lift operator’s, an employer must follow this training curriculum:
- The purpose and use of manuals
- That operating manuals are an integral part of the aerial lift and must be stored properly in the weather resistant compartment when not in use
- A pre-start inspection
- Responsibilities associated with problems or malfunctions affecting the operation of the aerial lift
- Factors affecting stability
- The purpose of placards and decals
- Workplace inspection
- Safety rules and regulations
- Authorization to operate
- Operator warnings and instructions
- Actual operation of the aerial lift
Proper aerial lift training has recently been addressed by OSHA; in 2010 a student attending Notre Dame University died while filming a football practice. The scissor lift that the young student was using to film the practice tipped over from high winds; proper training could have prevented this fatality. Since this tragic event, OSHA has been looking into contractor’s training programs to see if these types of hazardous conditions are being addressed and if aerial lift operators are being properly trained. Just being familiar with the controls of an aerial lift is not necessarily proper training. Some would agree that proper aerial lift operator training is much more detailed and involves hands-on practice. The familiarization that one would get from a supervisor on a job-site or a truck driver whose job is to simply deliver the equipment may not satisfy OSHA’s training requirements.
To help contractors with their aerial lift operating training, an Aerial Lift Operator Authorization Record worksheet has been created by the Construction Safety Council (CSC); email Paul Satti at psatti@buildsafe.org and he would be happy to send it to you.
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