Regulations (Preambles to Final Rules) - Table of Contents|
| Record Type:||Electric Power Generation, Transmission, and Distribution;Electrical Protective Equipment|
| Title:||Section 1 - I. Background|
A. Need for Regulation
Employees performing operation or maintenance work on electric power generation, transmission, or distribution installations are not adequately protected by current OSHA standards, though these employees face far greater electrical hazards than those faced by other workers. The voltages involved are generally much higher than voltages encountered in other types of work, and a large part of electric power generation, transmission, and distribution work exposes employees to energized parts of the power system.
The existing electrical regulations contained in subpart S of the General Industry Standards address electric utilization systems - installations of electric conductors and equipment which use electric energy for mechanical, chemical, heating, lighting, or similar purposes. Subpart S protects most employees from the hazards associated with electric utilization equipment and with the premises wiring that supplies this equipment. However, subpart S does not contain requirements protecting employees from the hazards arising out of the operation or maintenance of electric power generation, transmission, or distribution installations(1).
__________ Footnote(1) Electric power generation, transmission, and distribution installations under the exclusive control of an electric utility (1910.302(a)(2)(v)) are specifically not covered by the electrical installation requirements contained in Subpart S 1910.303 through 1910.308. Industrial generation, transmission, and distribution installations, even though they are not included in the language of 1910.302(a)(2)(v), are also not covered under the Subpart S utilization requirements if they are the same type as those of electric utilities (46 FR 4039). Additionally, the safety-related work practice requirements of Subpart S exempt work performed by qualified persons on or directly associated with electric power generation, transmission, and distribution installations regardless of who owns or controls them (1910.331(c)(1)).
In contrast, telecommunications workers, who face similar hazards, are covered under a specific telecommunications standard in 1910.268. This regulation protects employees performing communications work from the two major hazards of falling and electric shock. These are the same two hazards accounting for most of the accidental deaths in electric power transmission and distribution work.
Employees engaged in the construction of electric power transmission or distribution systems are protected by the provisions of subpart V of the Construction Standards (Part 1926). However, this standard does not address operation or maintenance work, nor does it cover work in electric power generating plants.
Electric utility industry trade associations requested several times that OSHA adopt a set of rules on the operation and maintenance of power generation, transmission, and distribution systems. Toward this end, representatives of Edison Electric Institute (an association of investor-owned electric utilities) and of the International Brotherhood of Electrical Workers (a union representing electric utility workers) developed a draft standard, submitted it to OSHA, and suggested that it be used as a proposed rule. The Agency accepted the draft standard and used it to begin the development of a proposal on electric power generation, transmission, and distribution.
B. Accident Patterns
To establish a basis for the development of safety standards, accident data must be collected and analyzed. OSHA has looked to several sources for information on accidents in the electric utility industry. Besides OSHA's own accident investigation files, statistics on injuries are compiled by the Edison Electric Institute (EEI) and by the International Brotherhood of Electrical Workers (IBEW). Additionally, the Bureau of Labor Statistics (BLS) publishes such accident data as incidence rates for total cases, lost workday cases, and lost workdays. Analyses of accident data for electric utility workers can be found in the following documents, which (like all exhibits and hearing transcripts) are available for inspection and copying in Docket S-015 in the Docket Office:
(1) "Preparation of an Economic Impact Study for the Proposed OSHA Regulation Covering Electric Power Generation, Transmission, and Distribution", June 1986, Eastern Research Group, Section 4 (Ex.(2) 4).
__________ Footnote(2) Exhibit.
(2) "Assessment of the Benefits of the Proposed Standard on Electric Power Generation, Transmission, and Distribution - Coding Results and Analysis", October 5, 1990, Eastern Research Group (Ex. 6-24).
Overall accident incidence rates for the electric services industry (that is, the electric utility industry, SIC 491) are slightly lower than corresponding rates for the private sector as a whole. Furthermore, these rates are much lower than the traditionally more hazardous manufacturing, construction, and mining industries. However, although accident incidence rates can be used to compare relative risk between industries, they are not specific enough to be used to determine the types of hazards that need to be addressed by an occupational safety standard.
OSHA realized during the development of the standard that, except for electrical and fall hazards, electric utility employees face hazards that are similar in nature and degree to those encountered in many other industries. At the same time, OSHA recognized that the risk faced by some employees during certain electric-utility-type operations is greater than the risk faced by other general industry employees. For example, the risk of electric shock to an electric power line worker or cable repairer performing his or her routine duties is far greater than that faced by any other occupational group(3). It is the uniquely hazardous operations that are being addressed by OSHA's standard.
__________ Footnote(3) JACA Corp., "Regulatory Assessment of the Impact of the Proposed Electrical Safety-Related Work Practices Standard, Final Report," October 1983, pp. 4-8 to 4-10 (Ex. 2-6).
BLS's Supplementary Data System (SDS) provides some detail on the characteristics of accidents in the electric service industry. SDS files indicate that the three major sources of injury within SIC 491 are falls, overexertion, and being struck by or against an object. Information on the nature of injuries also can be obtained from SDS. For example, from these data, sprains/strains, cuts/lacerations, and contusions/bruises are the most frequent injuries encountered in the electric services industry. Similar data can be found throughout general industry. It is noteworthy that electric shock cases do not constitute a major injury category and are grouped under "all other classifiable." Although these data do indicate hazards that must be addressed by a standard, they provide little guidance with respect to the content of the standard.
More specific information on fatal and other serious accidents was gathered from IBEW, EEI, and OSHA files. Contrasting with the SDS data, these files indicate that electrical accidents are the most frequent type of fatal and other serious injuries, accounting for approximately one half of these. According to EEI and IBEW data, other accident types that occur frequently include motor vehicle accidents, falls, and "struck by/crushed."
OSHA also collected information on accidents in non-utility electric power generation, transmission, and distribution installations (Ex. 6-25). These data indicate that accidents involving such installations are similar in nature and degree to those in the electric utility industry.
C. Significant Risk
OSHA must show that the hazards the Agency addresses in a safety regulation present significant risks to employees. As part of the regulatory analyses for this standard, OSHA has determined the population at risk, the occupations presenting major risks, and the incidence and severity of injuries attributable to the failure to follow established standards. In keeping with the purpose of safety standards to prevent accidental injury and death, OSHA has estimated the number of accidents that would be prevented by the new regulation.
Although nearly all workers in the electric utility industry are exposed to various hazards common to the industry, some are at much greater risk than others. Eastern Research Group, Inc. (ERG), in their "Preparation of an Economic Impact Study for the Proposed OSHA Regulation Covering Electric Power Generation, Transmission, and Distribution", June 1986 (Ex. 4), characterized the frequency with which accidents occur in the industry and tabulated the relative risk among electric utility occupations. According to the ERG report, "there were more accidents associated with transmission and distribution [lines] than with substations or power generation [installations]." Within the first category, more fatal and serious lost-time accidents occurred among line workers, apprentice line workers, and working line foremen. Within the latter two categories, substation electricians and general utility mechanics experienced the most accidents. (See p. 4-23 of the ERG report.) The hazards that are directly covered by the standard are those of an electrical nature, causing electrocution and injuries due to electric shock. In addition, the standard directly addresses fatalities and injuries associated with four other types of accidents: (1) Struck by or struck against; (2) fall; (3) caught in or between; and (4) contact with temperature extremes. (A few requirements of the standard address some hazards common to general industry work. These provisions deal with hazards that are not currently addressed in the General Industry Standards but that are causing injuries in electric power generation, transmission, and distribution work.) OSHA has estimated that an average of 12,976 lost-workday injuries to and 86 fatalities of electric power generation, transmission, and distribution employees occur annually. (See Section V of this preamble.) Using these figures, OSHA has also estimated the number of injuries which could be prevented by the new regulations. Taking into account such factors as existing regulation and the differences in training levels among utilities, OSHA estimated that 1,634 lost-workday injuries and 61 deaths could be prevented each year through compliance with the provisions contained in or referenced by the standard. (A detailed analysis of the benefits of the standard and a description of the methodology used can be found in the Final Regulatory Impact Analysis of the Electric Power Generation, Transmission and Distribution and the Electrical Protective Equipment Final Rules (RIA) for the standard, which is available for inspection and copying in the Docket Office.) Based on this analysis, OSHA has made a determination that hazards of work on electric power generation, transmission, and distribution installations pose a significant risk to employees and that the standard is reasonably necessary and appropriate to deal with that risk.
Regulations (Preambles to Final Rules) - Table of Contents|