Document RaJxV5LLea0j8qzm6MZ7KXJbV

volume 20 PLAINTIFF'S EXHIBIT NSC-225 national Safety Congren Tranjactionj PUBLIC UTILITIES runOTML SAFETY COUflCIL 425 North Michigan /Ivenue , Chicago. IL 60611 , volume 20 [1ahonal Safety Congreo Tramactionj PUBLIC UTILITIES 1 MTIOIM SAFETY COUHCIL 425 North Michigan Avenue l Chicago, IL 60611 , OCCUPATIONAL SAFETY AND HEALTH ACT (OSHA) AS IT RELATES TO PUBLIC UTILITIES By RAYMOND W. WHITE Attorney-at-Law, Manager, Claims and Safety Department, Pacific Gas and Electric Company The Occupational Safety and Health Act has been described by some people as an "an swer to a need" and by others as a "damaging infringement on private enterprise." Howev er, OSHA (which I am using hereafter to include both the statute (Act) and the ad ministration of the Act by the Department of Labor), as I view it, is neither of these ex tremes. On the whole, the men who have been assigned the responsibility to administer the Act, from the Secretary of Labor, Mr. James D. Hodgson, and the Assistant Secretary for OSHA, Mr. George G. Guenther, on down to the individual Area Compliance Officers, in my opinion, have done a credible job under the statutory restrictions of direction and timing set forth by Congress. This does not imply that I agree with the present status of the Act or the standards, for I do not. I do believe, however, that generally there is an attitude of fairness and concern on the part of the OSHA people that can resolve inequi ties as they are identified and brought to the attention of the proper parties. The few exceptions of "intransigents" in OSHA are being revealed and dealt with as "people" problems the same as in industry or any other place. It is essential that industry understand and exercise its responsibilities to properly inform OSHA of necessary facts and needed changes in the standards togeth er with good reasons therefor. Since this meeting involves gas, water, and communication utilities, as well as electric utilities, I will try to cover all of them as now affected by OSHA with a few special exam ples. To the extent that time permits, I will review and emphasize the special application of Subpart V - Power Transmission and Dis tribution and related sections in Part 1910 and Part 1926, which is the only so-called "vertical" industry standard which has gone through the due process procedures of Sec tion 6(b) o the Act. History It might be well to review for a moment the chain of events and circumstances that have occurred up to this point. On December 29, 1970, the President signed into law the Occupational Safety and Health Act of 1970. The Act authorizes the Federal Government to set and enforce occupational safety and health standards applicable to businesses af fecting interstate commerce. The Act be came effective on April 28, 1971. There were 35 documents published in the Federal Reg ister in 1971 which changed or added to the OSHA program. (The Federal Register is the official media for the dissemination of Federal regulations to all parties in interest.) This rate of approximately three documents a month for 1971 has increased with the is suance of 109 changes in the first 8 months of 1972. This number does not include the dozens of Proposed Rules presently being considered. Some of these changes or proposed changes were only one column of one page of the Federal Register, however, each doc ument required full review and analysis, particularly if future public comment was solicited in the publication. All of these re leases are regulatory in nature and are issued under the statutory authority of the Act. The Act itself has not been altered since it was signed into law by President Nixon on De cember 29, 1970, although a number of pro posed changes are pending in Congress. The Act does not contain the detailed safety and health standards of OSHA. It only 1 1972 National Safety Congress provided for their promulgation. It does con tain, however, the Section 5(a) General Duty clause which is the essence of this legislation. This clause reads as follows: "5(a) Each Employer- (1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees; (2) shall comply with occupational safety and health standards promulgated under this Act. (b) Each employee shall comply with oc cupational safety and health standards and all rules, regulations, and orders issued pur suant to this Act which are applicable to his own actions and conduct." Standards The first nine to ten months of 1971 were required to publish and bring some detailed safety and health standards into effect. In this interim period, OSHA inspections were being made and citations were being issued against employers alleging violation of the previously quoted General Duty clause. A few such "General Duty" citations are still being used where there is no specific standard covering a generally accepted unsafe expo sure. The Occupational Safety and Health Act of 1970 authorized three general methods to be used for standard-setting- (1) The Secretary of Labor was required to promulgate as soon as possible, and within two years from the effective date of the Act, existing "national consensus standards" and "established Federal standards," unless he determines that those standards will not im prove safety and health of employees (Sec. 6(a)). This means of issuing standards will expire April 28, 1973. (2) At any time after the effective date of the Act, the Secretary may promulgate new standards, or modify or revoke any existing standards with the assistance of advisory committees by following a formal and lengthy procedure specified in the Act (Sec. 6(b)). (3) The Secretary may also promulgate emergency temporary standards if he de 2 termines that employees are exposed to grave dangers from toxic or physically harmful agents or new hazards (Sec. 6(c)). Such an emergency standard must be replaced by a permanent standard developed through the (Sec. 6(b)) process within six months of its issuance. To date, this has been done only once - for Asbestos. The emergency standard covering Asbestos was issued on December 7, 1971, and the final standard was issued on June 7, 1972. General Problems Generalization is always dangerous, whether about individuals, or nations, or OSHA. To say that OSHA standards are all bad or all good is such a generalization. It has been estimated that there are more than ten thousand individual standards promul gated in Parts 1910 and 1926, plus untold thousands of related standards incorporated by reference, such as documents issued by such consensus organizations as the National Fire Protection Association (NFPA) and American National Standards Institute (ANSI). Perhaps the most time-consuming and frustrating experience in reviewing the OSHA regulations to decide their applicabil ity to a particular company or industry is the referencing in the standards of "consensus" and "Federal safety standards" such as ANSI, NFPA, Construction, Maritime, etc. There are in existence several thousand sep arate consensus standards varying from one or two pages to more than 100 pages each. Each of these may potentially become an OSHA-referenced standard. Failure to read one of these, which has been adopted by OSHA (assuming you have succeeded in se curing an up-to-date copy), can make a 100 per cent difference in whether it is properly determined that a company or an industry is or is not covered. To give just one example of the problem of "reference" standards, most utility line trucks use a hoist, crane, or derrick. At the present time, we have been advised that this lifting equipment brings these vehicles under the Crane and Derrick Subpart N sections of Part 1910 and 1926. In turn, these standards refer you to ANSI and Power Crane and Public Utilities Sessions Shovel Association Standards, as follows: 1926.550(b)(2) & 1910.180 - Truck Cranes - ANSI B30.5 (24 pages) 1926.550(e) & 1910.181 - Derricks - ANSI B30.6 (18 pages) 1926.550(a)(17) Cranes & Derricks - Power Crane and Shovel Association Mobile Hydraulic Crane Standard No. 2 (47 pages) In reviewing these documents and a relat ed ANSI B30.7 (19 pages) which is not ref erenced in OSHA but covers Hoists, there is an unobtrusive requirement that sets forth the minimum ratio that must be maintained between the hoist drum or sheave pitch di ameter and the nominal rope diameter as 18:1 in most cases. There are in service today, thousands of truck mounted hydraulic cranes and derricks which cannot meet this requirement but have been operated safely for many years with ratios of 9 and 10 to 1. Eighteen to one is good engineering design, but all it really does is provide longer life to the cable. Modifi cation of many of these units could be fairly difficult, and would hamper operations by restricting the amount of rope that could be carried, and the pulling power of the winch. What is needed is a standard for Truck Mounted Cranes andDerricks offrom 10 to 15 Ton Capacity. Such a standard should be based on the existing equipment that has been field tested and proven to be of safe design for the type of work being performed. This problem will require action on the part of the electric utilities particularly since Subpart V of 1926 as proposed brings Sub part N requirements into V and applies them to electric line trucks in 1926.952(c). This paragraph in Subpart V is titled, "Derrick trucks, cranes, and other lifting equipment." In 1926.952(c)(l)(ii), "Derrick ti icks" are parenthetically defined as "electric line trucks." Specific Problems sic set of Federal Safety or Health Regula tions applicable to all employers. Cities and political subdivisions of the states are not cov ered per se but are to be covered in State OSHA Plans if state law so allows. Each in vestor-owned public utility is included in this general category of employers. All of the Part 1910 standards apply to such utilities except the inapplicable "vertical" or special indus try standards, unless (and this is a very im portant unless) we are performing work that can be classified as "construction, alteration, and/or repair" AND there is a standard cov ering the issue in Part 1926 which is an appli cable "vertical" construction standard. To make this point in reverse, if we are doing construction work and a standard is published in Part 1926, it will prevail over any other similar standard in Part 1910. If we are doing construction work and there is no standard published in Part 1926, then any standard in Part 1910 that covers the issue will apply to that task or work situation. This is a restatement of Part 1910.5, page 10468, and seems reasonable until an attempt is made to separate normal utility work into "construction" and "nonconstruction''-type work. For example, most utilities do welding of one type or another, such as gas pipelines, pipelines in steam or water plants, and equipment repair. Now, our question is, what standards apply to these jobs? The Depart ment of Transportation (DOT), Office of Pipeline Safety (OPS), has primaryjurisdic tion over gas pipelines. Other pipelines and other types of welding can be covered by the SubpartJ standards of Part 1926 or the Subpart Qstandards of Part 1910, both of which cover the subject of weld ing. I wish I could give you a clear answer to the question as to when Part 1910 or Part 1926 will control, but this is one area where we have been unable to secure a firm inter pretation from OSHA. Part 1910 of Title 29 of the Code of Feder al Regulations is referred to 'as the "General Industry Standards." This Part 1910 was published in the Federal Register on May 29, 1971, and was just brought up to date in the Federal Register of October 18, 1972. It pro vides, as amended from time to time, the ba Hydraulic Fluids This becomes a very real and serious prob lem for electric utilities that will be working under Subpart V, which is a "vertical" stan dard for "construction" within a "vertical" standard covering "construction" in general. 3 1972 National Safety Congress As an example of this type of problem, pro poser! Subpart V, 1926.950(i), requires the use Gas Utilities of insulating-type hydraulic fluid in trucks doing electric transmission or distribution construction. This means that all the hy draulic hand tools used with such trucks must have compatible seals and connectors for this type of fluid. If this same truck should be used in gas construction or the construction and/or repair of power generation equip One of the unique problems that face the gas utility companies is the question of juris diction between OSHA and The Office of Pipeline Safety (OPS). Fortunately, this matter has received attention by both OSHA and OPS. The position of OPS was stated by Mr. Joseph C. Caldwell, Director of OPS in OPS Advisory Bulletin No. 72-6 dated June ment (the latter tasks not being covered by Subpart V), the standard that would apply would be 1926.302(d)(1), which calls for fire resistant-type hydraulic fluid to be used. This fluid is highly corrosive and very hard on paint, seals, etc. To follow the two requirements literally 1972 as follows: "'The Occupational Safety and Health regulations apply to the safety of the worker. However, where safety in the transportation of gas demands regulations affecting work conditions of workers then the Department of Transportation assumes jurisdiction.' This would result in insulating fluid being used in the truck hydraulic system in the morning when "used on or around energized lines second sentence expresses an exception to the sentence immediately preceding it. Any reg ulations developed by the Office of Pipeline ..." [1926.950(i)]; but, in the afternoon Safety of the Department of Transportation when the truck would be used on gas con affecting work conditions of workers would struction, fire resistant fluid would have to be be based upon the need for safety in the used [1926.302(d)(1)]. transportation of gas. These two standards are inconsistent. This "Section 4(b)(1) of the Occupational operating problem is being called to the at Safety and Health Act (29 U.S.C. 653(b)(1) tention of the OSHA standards people in delineates the regulatory interface between Washington, D.C. OSHA and OPS. This section states: 'Noth Standards Common to All Utilities Some specific OSHA standards that are of interest to all utilities, either because of their impact on prior operating practices or be ing in this chapter shall apply to working conditions of employees with respect to which other Federal agencies exercise stat utory authority to prescribe or enforce stan dards or regulations affecting occupational cause of their controversial nature, are: safety or health.' Therefore, OSHA regula Trenching and shoring. tions will not conflict or overlap with regula Gasoline dispensing nozzles - latch open. tions promulgated by the Office of Pipeline Fixed ladders in manholes and on micro- Safety." wave towers. The OSHA position has been stated in Manhole ventilation and testing. OSHA Program Directive 200-2 dated April Crane boom angle indicators. 20, 1972 addressed to Regional Administra Asbestos pipe and lagging. tors, National Office Directors, Area Direc OSHA's entrance into the health field has tors and District Supervisors. The key para been very emphatic. There are many health graph reads as follows: standards included in OSHA regulations. Two of them involve many Company opera tions. One relates to noise levels and the other "Upon receipt of any other complaint or other correspondence concerning working conditions in industries which are apparently to handling and use of toxic and hazardous the subject of regulation by another Federal materials. We have been making a number Agency to some degree, the OSHA official of surveys of our properties in connection who receives such correspondence shall with these standards to assure compliance. transmit a copy of same to the Director, Of fice of Compliance. 4 Public Utilities Sessions "The Office of Compliance will then transmit such correspondence to the Associ ate Solicitor for Occupational Safety and Health, who will discuss any jurisdictional questions with any other Federal agency which may be involved." It is clear that if OPS has specifically covered a subject, its rules will control. How ever, I find nothing that precludes OSHA standards from supplementing OPS rules when to do so enhances employee safety without conflict with such OPS rules. For example, OPS, in Part 192, sets forth welding certification requirements and requirements for testing welds. OSHA, in Part 1926.351(e), requires shielding of arc welding and cutting operations to protect employees and others in the vicinity from the direct rays of the arc. This is not inconsistent or in conflict with OPS rules and, in my opinion, both sets of rules can be enforced under these circum stances. Electric Utilities - Subpart V The set of rules identified as Subpart V of Part 1926 (formerly 1518) first appeared in its present context in the Federal Register Vol. 36, No. 22 - Tuesday, February 2, 1971, as part of a Notice of Proposed Rule Making issued by the Department of Labor, Bureau of Labor Standards under the authority of Section 107 of the Contract Work Hours and Safety Standards Act (86 Stat. 96; 40 U.S.C. 327), commonly known as the Construction Safety Act. The proposal was to add to 29CFR, Chapter XIII, a new Part 1518, ti tled Safety and Health Regulations for Con struction. Within thisproposed Part 1518 there was a Subpart V, titled Power Distribution and Transmission Lines. This Subpart con sisted of two sections, 1518350 - Power Distri bution Lines and 1518351 - Transmission Lines. It took up only three and one-fifth columns of print in the Federal Register, or the equivalent of just over one full page, and covered such items as minimum clearances for working voltages from 4-kv up to 500-kv. The standard also covered grounding and bonding, as well as the use of such equipment as aerial lifts and hot sticks. This proposed text of Subpart V was not printed in the Notice of Rule Making when Part 1518 was published as afinal regulation in the Federal Register Vol. 36, No. 75 Saturday, April 17, 1971. The subject matter was left in Part 1518, however, by the reten tion of the title "Power Distribution and Trans mission Lines (Reserved)" under the heading Subpart V. As issued, Part 1518 only applied to "Fed eral and federally assisted advertised con tracts" issued under the Construction Safety Act. As an "established Federal standard", however, this set of construction standards was blanketed into the Occupational Safety and Health set of General Industry Stan dards, Part 1910, issued a month later in the Federal Register Vol. 36, No. 105 - Saturday, May 29, 1971, under Sec. 6(a) of the Act covering "national consensus standards" and "es tablished Federal standards". Thus, under Sec tion 1910.12 of Part 1910, the reserved Sub part V of Part 1518 became a part of OSHA along with the other Subparts of Part 1518 covering construction activity. B. General Since Subpart V had not been printed and issued as an "Existing Federal Standard" prior to OSHA, and since it was not based on an American National Standards Institute or National Fire Protection Association consen sus-type standard, it was necessary for the Department of Labor to follow the formal Sec. 6(b) type of procedure to promulgate this standard. The Sec. 6(b) type procedure authorized the Department of Labor to ap point a special Construction Safety Act Stan dards Subcommittee on Subpart V to pre pare and review with the industry representatives and associations a set of stan dards that would be applicable to Power Transmission and Distribution Lines. The procedure followed under the Construction Safety Act applicable to Subpart V is similar to the procedure for OSHA regulations un der Sec. 6(b)(1). The subcommittee activity, and the indus try and union involvement in the delibera tion process, culminated in an official version being published for public comment on May 10, 1972, in the Federal Register. Many of the future OSHA standards and many of the desired changes in present stan- 5 1973 National Safety Congress dards will come into the Federal regulations through the consensus standards organiza safe work procedures and has a positive com tions such as ANSI and NFPA. This is where we need to place our efforts. We should have strong representation on the variousstandard setting committees to assure the recognition mon sense and conscientious safety program he will be complying with most of the OSHA standards. The "thrust" of OSHA is to pro tect employees from injury or death. of our industry's position as it relates to the The technical points of whether a toe- various standards being considered. Further, board should be 3 inches or 4 inches or there should be vigorous industry association whether a railing should be 40 or 42 inches attention and ACTION on ALL existing and proposed OSHA regulations which raise any substantial question as to adequacy,justifica is not of primary importance. The main "thrust" should be the taking of necessary and basic action to minimize possible injuries tion, or applicability. When you make com or deaths. OSHA representatives have stated ments, don't limit yourself to objections. that their primary objective is the reduction When the proposals are favorable or positive, of injuries and deaths and not enforcement of let OSHA know that you approve of their action or proposed action. Similar action is needed on all proposed "State OSHA" Plans. technical requirements solely to exact com pliance. OSHA did not "invent" safety. OSHA could be scrapped or drastically curtailed at There is no shortcut or panacea to the any time by an Act of Congress, but this assimilation of the thousands of OSHA reg would not eliminate the need for any of the ulations promulgated to date. The pertinent standards, as a very minimum, must be stud ied and applied by every employer. Howev present emphasis on safety in the work place. Safety must be our first concern and OSHA should be considered as a valuable tool to er, as a starting place, it is reasonable to as accomplish that end rather than as an end sume that if an employer is practicing good unto itself. Public Utilities Sessions SAVE YOUR SIGHT--ON THE JOB OR OFF By ELIZABETH R. VAUGHN, M.D., Ophthalmic Consultant, Texas Instruments, Inc., Dallas, Tex. I always welcome the opportunity to tell people about their own eyes, because so much blindness is needless and could be pre vented if people were made aware of a few simple aspects of eye diseases. Let's start by discussing some common-sense type safety precautions and emergency procedures for eye injuries. One common eye injury is getting some irritating substance in the eye, whether it be a strong acid or alkali, gasoline, deodorant, hair spray, or an endless list of commonly used items. The wisest course of action is to wash out the eye as quickly as possible with water. Copious amounts of water should be used immediately, either by cupping your hand and splashing it in your eye or by put ting your head under a water faucet, or, as one of my patients did when he got insect spray in his eye, jump into a swimming pool and open your eyes under water. So, simply remember that any method you can devise to wash the irritant out quickly if the best possi ble thing to do. After you have washed out as much as possible, you should see your ophthalmologist right away. The majority of these injuries, with proper care, heal nicely without visual impairment. Let's suppose you're on a long-awaited camping trip and you are stalking through the trees demonstrating your scouting tech nique by getting wood to build a warm fire for your family. Suddenly a tree limb snaps back unexpectedly and hits you in the eye, scratching your cornea. A bad scrape to your cornea can be one of the most painful injuries imaginable. You don't have to be in the woods to get your cornea scratched. A few months ago one of my patients confessed in a very embarrassed tone that he was drying himself with a bath towel and stuck his thumb in his own eye. Two days ago a lady came to see me with a bad corneal scratch from a tupperware cake pan which fell into her eye as she was reaching up on a kitchen shelf. So you see, potential danger lurks in the confines of your own safe home. If you ever get a corneal scratch or abrasion you will know it, because every time you blink it will feel like ground glass in your eye. The best thing to do is to patch the lid tightly shut over the eye and see your ophthalmologist as soon as possible. This is also the best course of action if you ever have a penetrating inju ry into the eye, as with a sharp object. Patch the eye shut until you get to the doctor. Many men work with power tools, either on thejob or at home. Power drills are espe cially bad about throwing off small pieces of material which frequently lodge in the eye. Even hammering on metal can hurl foreign particles into the eye. Also, working under a car or on overhead pipes or light fixtures is a perfect set-up for having a foreign particle fall into your eye. Several months ago, an employee of the telephone company came in to see me. He had opened an outside tel ephone installation and the Texas wind picked up many particles and blew them into his eye. All of these situations will find a wise man wearing safety glasses for protection. It will take only one episode where it was "just too much trouble to dig out those glasses," and that may be the one time you get a flying piece of metal penetrating your eye. If you are lucky, it may lodge on the front surface of the eye and be removed with relative ease by an ophthalmologist. If you are not so lucky, it may go inside the eye and you may very well lose your vision completely. In this instance, the old saying that an ounce of pre vention is worth a pound of cure is certainly true. So, please don't take a chance with the only two eyes you will ever have. Wear pro tective glasses. Welders are usually made aware of the need for protective glasses while welding. Ul- 7 o 5 o I o aa I fcj-s S jfs .5 fiJS ll 0 3 H 60 8 U*O'ju,S'SbM S 6 " 2 S 2 a c ga 30 .S3 .2 8o j|, p o o u jq 5 ep G u H w i a, is 18 . 1 !-" 2 8.: l-S* d? c 3a8 s.s| 18 S'i-S e &.51 9 * a 2 S^| Nisi 4&rSill a ir , 511 i | 8 g J. ! 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HIPP Staff Supervisor, Safety, Training & Organization, Chesapeake & Potomac Telephone Co., Washington, D.C. I suppose we can all easily talk about safety - the trick is to do something that will drive the message home and influence our people to work safely. I maintain that this can be easily accomplished, if our people firmly believe that we know what we are doing. Any supervisor can tell his people to work safely, to wear insulating gloves or safety glasses. And I imagine that any one of us can tell them how to test manholes and to venti late them while working in them. But it doesn't take a lot of brains to tell someone to be careful when climbing poles or driving a motor vehicle. The big question is, do we actually know the proper procedures our selves? More importantly, do the supervisors of these people know the proper procedures? Are we experts on the subject? Sure, we might know all the answers. Most likely, we know what a safety practice states. But, can the supervisors of our people actually perform the various operations? Can they demonstrate the proper way to do the job? Could we do if? Think about that for a moment! Could they, for example, perform the proper test to insure that a gas indicator is functioning properly? Could they demon strate the proper method of placing a splicing platform on a strand--or a simple task of carrying an extension ladder? I'm sure you've found, as we have, that improper car rying of ladders causes many of our disabling injuries. To be more exact, are we positive that our supervisors--those directly related to a spe cificjob--have sufficient knowledge to recog nize when any employee isn't working safely? How many who aren't directly related to a specific job would be able to recognize a safe ty hazard, and do something about it? Not many, I'm afraid! Wouldn't it be great if every supervisor in our industry could recognize an unsafe act and do something about it right on the spot? That's what our "Day with Safety" is all about. It is designed to develop manage ment's ability to recognize safety deviations in the "complete job" through "hands-on" experience. In short, it develops a sense of responsibility. This higher sense of responsibility is not only a practical necessity these days, with the birth of OSHA. It is our obligation and part of the price for the privilege of doing bus iness. Yesterday's rule book and its related demands on safety knowledge are as outdat ed as short hair. Giving the "best possible service to the cus tomer at the lowest cost"--a phrase we've heard many times--doesn't mean the same to us today as it did yesterday. Today, we must "factor in" the cost of complete safety training and retraining of employees and su pervisors. We must accept the fact that this requires time and money--accept it, then do it! But, be smart about it. Make the most of the training dollar. We can't afford to rely on pieces of paper stating the "do's and don'ts" of safety to train our people. Train them with actual "hands-on" techniques. Today, we live in a world of "instant" ev erything. Unfortunately, training doesn't fall in this category. It takes time and money to ensure the safety of our people. Don't train just "for the record". Train for "the big pay off"--an accident-free company. With a lot of work and concentration, this can be done! How? Start by thoroughly training your supervisors. It's costly, but as the young lover said to his girlfriend, "Look at it as an oppor tunity, not as a proposition." In G&P, we gave ourselves this opportuni- 10 Public Utilities Sessions ty with the implementation of "A Day with Safety". Coupled with this training we have a brand new Bell System "Accident Preven Drop wire (how to raise, carry up poles, cross streets) Setting poles. tion Plan", used to test the safety knowledge and performance of our people through in terviews and demonstrations. Here's how it works: 1. A site is selected for training, and training stations are established for selected work op Training Station No. 4: Aerial Platforms How to raise and secure platform Examination of rigging Proper method of lashing ladder to strand Use of handlines. erations. 2. Knowledgeable training station instruc tors are chosen well in advance of the course, giving them time to review safety practices and prepare their presentations. 3. Actual equipment to be used in the dem Training Station No. 5: Power-aerial Clearance Voltage tester Insulating gloves (use and test) Insulating blanket (use and test) onstrations is assembled. 4. A time limit is established for each training station demonstration. 5. A schedule is prepared. 6. Advertise it--and gal Trainees are supervisors at all levels of management, including our company Vice President. Eight training stations were set up for demonstrations of selected work operations, as follows: Training Station No. 6: Ladders Inspection and test Use of ladder foot Placement of ladder on building Placement of ladder on strand How to raise and lower Carrying Transporting Training Station No. 7: Aerial Lifts Operation and placement Training Station No, 1; Manholes Testing of gas indicator Testing for gas in manhole Use of forced ventilation Use of manhole ladder Entry and exit of manhole Training Station No. 2: Work Area Protection Use of warning devices Various work area protection plans Positioning of vehicles and warning de vices Training Station No. 3: Poles Pole test (pike, hammer, prod) inspection, markings Climber cut-out inspection and test Body belt and safety strap inspection and test Use of safety strap Clearance Use of insulating blanket Training Station No. 3: Motor Vehicles Inspection Parking Backing Housekeeping Seat belts Safety knowledge Keep in mind, there are no quick remedies that will prevent accidents over the long haul. Continual daily adherence to accepted safe principles and procedures, coupled with knowledgeable supervisors and employees, has proven to be most effective in our acci dent prevention efforts. A "Day with Safety" is one of our efforts. Try it--you'll like it. 11 CL. act E < to & O TO CO Oh u. b o LU 6, u Du Q .a E <c t/J CO .x W S3 Q < t2 Z >-) ,, < m" 8 LU =D to 5. Z c_o3* O tx 3 co CO o> a uao*^j3 c ooy w. og -8--.c>XXrlt 2U o ~ s sS *S3 UI 5 e|-g2 5E 3 aC. .?*wo i3 " Srt 4) .g4/ *5 r*s3 o '1 8 ^ g as .S5S<5 Hg b ao 2 K S S" 3 s .S^-q o o o ^ ._ G 5 jWb *tp-o* *j5- +2 -S g -a -g S.2.S S TbOos,sU Mo) .i' 6w>.2tf "-' 32 O 4)*'' S TOG -- ^ (W4 e 6r-J3Qe. u"> 5CeLv,-> V5> 2 J S <O5 ^ 8 j*g5 352 *- --* w , to y *aojDdortw 1 "I'-s jr"" o s^'S-g f I ,S^>de2s HrCS?1.*2S^:s."2-ur "sOc8MroC 2 >-S cToO *vr5j j.a -r3-"5aeSi jsia--S3.S5 o bao -, 0 oag +- -p -- C "S < 2 w o- ~ o 60 j1:5,i G_.-- OgG-JOt3) *TT03O --g 5 bb2 'I CHi; b g>..s 11 g sass^ ^^boa^TO3 u<f1l TGji S,3 ^-2 .2 TO * S g2 5.5* ? J> V ^C fi .5 4) rt O T1 1 &!"w 1*1 S5Vf 60 K .2 - .S X "O >. g"S?SoJ"i g` >' 1 S <g -Q < 4? 1 wCG >CtuK>4n)TO*Oroui^-*> O TU3 *S4> ~O e~ 4) d>i l>3o>:i*,>--o>3J3*b^d ao SG C25P ^"_^5 B!wo-to3-S S 7o63 a g -I " < .a -a S So 4) S 6 g,g. y3 ti CP S-S^ V2>ho4> _---OL^>s;T S+,,oo- fi O ^ S&2.S T2.2cxrt o ts 2 <9 O .5 J3 C w **3 2 &,,v 2S '3p Gcujs4> *^pG j-i 2*C o fl w TO iG?.^2O -CS0.-S"j*j oyo O<.-.> -4CE)i ^ T3 3 * ^ " T> 3 umco bco 3 w _. Ob) - w -- ^ u tM- rj *,S, *iz5 O **y-< <-> -a u c o ill-S* g rt M t) t> a a i js 0 rt - rSt . *0 o* s | : rt JB tj s _ ; .*3J H. TeP -O c 2 3 is .2 6 .a g 3 .53 j S. 2 d.-5 a ^ sg. 8p p 0a eo 8 a. atu B - " o J 8 Ijj-S-S - ,, > bo-2 a Jp pM.3 0.&8.TP" CJ o Jl-I 1 g|; , Icglf-S 8 ! Z b S' g"8 s^^ C loo, ! .-2 r'j a j 8 xT'jS -D ; -Oaa swi Tsg3 -9 Su r ! ;B *i i-S 8. yw --oyi- -yt ---- fc.EPaSS Srgl I +5 o s ! Isis g> s-2 Oo *>~ Si .fya yr*t y -a -> 8-g s 2 s," g ? is c2 D S rt XS rt O II I'll 2U pg GO .S5 'foe toi 3i O a c c<3 6 %woc ^. o(h -g2 j> Hip x s"? 8*o8a|83sS?*Ss -.2o *I 11 s i wu M U* f^pp-gs "I S-" "p-? ! | % G?3"?iSiSCL, ^W Sr* O "3 o fa JJ &* s a I* g.2 g +* O 8y -S,, 3>=.J5 8 -3 .>.88.^3 8 .& p3gp x5Uf:aj .*2C? T3 >eov- C ~ T> . 2 g a 8 > *3 5 . -g o asWC*5 8 |1 03 b_p XoS .X5S <4 ? s c s^ SJ 8 lJBs8 _4Jngills! "3o -iai ra>t -y3 8y jf-a w, rn 8.S *s2-9^. 8 >S%' u"goC.US*Q g||^ 4J o* O S3 i >25P J> TO .5 'S 73 *;z; Z>'3'as i c3 g-,c3-oO Sa 7<34 -s- 3H !l"-||p|'S fa fa Q, w bO .5g o ><. .-G2s 1-o.Sj * 3 'rt e a-5^ i> =l3 8B 8s g p's sl's iLnntj-SjSp if E3 o 63s03 gOrt ao.,;,g3 TJ .5 g oy c3 " O 5c O ,, M-P O ~ i 3 HE3 Erst-ri t5-0S 05> |---TsJ*>j ! g si-s-s 3 a** fot>f cufi & Jllllsl-e.g1 .^ u g 25 3 ^ .ssfe'SsiS > 1112 l o" i'*-Jg'-g3 |"QSb ,Si? Sil J3 T3 8 'B z 5 DC Q. (/) 35 in is U|/l u.!= o l/> 5 Z /) o < *0 Gd o G o 5 (/> xa ii -Sars0-*0 3r| s * 'Z.I a S > o 3 8 S -c i-S S3 a `.s.o 3 rl j s js s 3 ; a-g a ^`g o 11^2 ^ U G J2 S 32S _OE 3rgg No,,ino-f>l ^go s3 a.t'i 9 888 si. i.i'll 4 |l< l1 &* ,-s` iifsai JS b 11 * 5S t5 3 Itl-i iB- r-t 83 -aS 23 2 - .o* Z 5 G-S fi 3 . JS o w SS'S fr s I Ro>f 1972 National Safety Congress safety aspects of this equipment. An example of this would be our articulated-frame rubber tire tractors. This equipment was originally designed for skidding logs, and is used exten sively in the timber industry. We found that, if we loaded a conventional rectangular spray tank on a standard model timberjack or tree farmer, the center of gravity was too high for safe operation of this equipment on our rights-of-way. Consequently, both the frame of the tractor and the design of the spray equipment were modified to lower the center of gravity and thereby improve its handling characteristics. This has worked ex tremely well. The same type of vehicle is also used as transport for bucket equipment, which is used by our tree-trimming crews. Another piece of equipment that is used in our spray operations is the portable mist blower. Aside from the hazards of having one of these units on your back while travelling rough terrain, operators can receive burns unless the hot metal parts are guarded and the operator is made aware of this hazard. Each year we apply herbicides to about 3,000 acres of right-of-way using Hydroowned and crewed helicopters. The use of such equipment calls for instruction as to safety practices that must be followed by per sonnel working around this equipment while it is on the ground. "Tailboard conferences" discuss smoking regulations, the need for high protection and the avoidance of the danger zones created by both the tail rotor and the main rotor blades. The selective herbicides we use for brushcontrol work are low in toxicity, the most toxic of which has an acute oral LD 50 of between 350 and 500. At the concentrations specified, we do not believe that the use of these materials constitutes a hazard to the operator or to the environment. We stress the need for good personal hygiene habits and supply wash-up facilities on the trucks. There has been much in the press during the last few years about the health hazards associated with pesticides in general and herbicides in particular. The Canadian government has strict regulations governing the sale and use of these materials. We adhere to these regula tions very strictly and will not use any pesti cide that is not registered for use in Canada or one that has, in our opinion, unacceptable hazards, even though it may be registeredTwo materials that were once used by Hydro in its vegetation and insect control programs, which are no longer used for this reason, are arsenic trioxide and DDT. Hydro spends considerable time, effort and money in training its trades personnel regardless of the nature of their work. Those involved in the application of herbicides re ceive a formal training program which covers such things as development of spray tech niques, the spray operator's responsibilities, accident prevention, herbicidal properties and formulations, weed and tree identifica tion, etc. In addition to this, those responsible for the supervision of spraying operations must be licensed under our Provincial Pesti cides Act. Experience has shown that accidents re sulting from chemical brush-control work falls into three categories: 1. Slips, Trips and Falls Because of the nature of the work and the terrain, it is inevitable that we have had employees suffer injuries of this na ture. However, they are infrequent. 2. Vehicles We have tried to minimize accidents in volving spray vehicles by driver educa tion, design modifications, and by making them topics for safety meetings. 3. Skin and Eye Irritations Some of the herbicide mixtures used can cause skin irritation to some employees. Protective clothing and barrier creams are supplied. As well, the crew is made aware of any label precautions and oth er pertinent data relative to the safe use of these pesticides. In summary, it has been our experience that a large program of chemical vegetation control can be carried out safely, provided that you are prepared to invest in training of your employees, the development of vehicles and equipment that are designed to meet the requirements of the job, and provided that great care is taken in the selection of the chemicals used. 18 OFFICERS OF THE PUBLIC UTILITIES SECTION NATIONAL SAFETY COUNCIL 1972-73 General Chairman--Robert H. Ward, Safety Director, Omaha Public District, Omaha, Nebr. First Vice-Chairman--Colon F. Stanley, Safety Manager, General Telephone Co. of Florida, Tampa, Fla. Second Vice-Chairman--John R. Yeaman, Jr. Division Safety Engineer, Virginia Electric & Power Co., Alexandria, Va. Secretary--'Jack B. O'Neill, Director of Safety, Transcontinental Gas Pipe Line Corp., Houston, Tex. Program Committee--Vern A. Sielert (Chairman), Loss Prevention Manager, GTE Service Corp., New York, N. Y.; Hiram G. Tripp (Vice Chairman-Electric), Safety Director, Chattanooga Electric Power Board, Chattanooga, Tenn.; Ashby B. Randolph (Vice Chairman-Gas), Manager of Safety, Consolidated Gas Supply Corp., Clarksburg, West Va.; Clarence O. Lind (Vice ChairmanCommunications), Personnel Supervisor, Illinois Bell Telephone Co., Chicago, 111.; Howard G. Husted (Vice Chairman-Water), Safety Engineer, Dept, of Water & Power, City of Los Angeles, Los Angeles, Calif. Technical Publications Committee--Ernest G. Shearer (Chairman), Director, Training & Safety Educa tion, Indiana Statewide R. E. C., Indianapolis, Ind.; R. Paul Bolerjack (Vice Chairman-Elec tric), Safety Director, Illinois Power Co., Decatur, 111.; T. L. Powers (Vice Chairman-Gas), Safety Engineer, Public Service Electric & Gas Co., Newark, N. J.; Edmund J. Kelly (Vice ChairmanCommunications), Staff Supervisor-Safety, AT&T Long Lines, New York, N. Y.; Paul Burdan (Vice Chairman-Water), Manager, Dedham Water Co., East Dedham, Mass.; Alex Pierson, Safety Engineer, Philadelphia Gas Works, Division UGI Corp., Philadelphia, Pa.; *J. E. Appel, Safety Engineer, Commonwealth Edison Co., Chicago, 111. Training Committee--Charles S. Bolick (Chairman), Manager-Safety Training, Metropolitan Edison Co., Reading, Pa.; RalphJ. Richey (Vice Chairman), Staff Supervisor-Safety, AT&T Long Lines Dept., Pittsburgh, Pa.; Stanley BallouAssL Manager of Personnel & Safety, Industrial Generat ing Co., Fairfield, Texas; Darrel R. Barnes, Safety Director, City of Colorado Springs, Dept, of Utilities, Colorado Springs, Colo.; Hugh Burke, Training & Safety Supervisor, Dairyland Power Cooperative, LaCrosse, Wise.; Richard Greenlund, Safety Coordinator, Minneapolis Gas Co., Minneapolis, Minn.; Frank E. Johnson, Safety Training, Administrator, General Telephone Co. of Michigan, Muskegon, Mich.; Carl W. Luckowmk, Plant Supervisor-Safety, Wisconsin Tele phone Co., Milwaukee, Wise.; Ric iard J. Ouphant, Safety Director, Denver Water Dept., Den ver, Colo.; Ashby B. Randolph, Manager of Safety, Consolidated Gas Supply Corp., Clarksburg, W. Va.; Jack B. O'Neill, Director of Safety, Transcontinental Gas Pipe Line Corp., Houston, Texas Off-the-Job Safety Committee--Joseph F. Mahoney, Jr., (Chairman), Safety Representative, Philadelphia Electric Co., Philadelphia, Pa.; Ernest W. Traut (Vice Chairman), Safety Director, General Telephone Co. of Pennsylvania, Erie, Pa.; John T. Cappio, Safety Officer, City of Philadelphia Water Dept., Philadelphia, Pa.; Hugh Burke, Training & Safety Supervisor, Dairyland Power Cooperative, La Crosse, Wise.; Carl W. Luckowiak, Plant Supervisor--Safety, Wisconsin Tele phone Co., Milwaukee, Wise. Membership Committee--Bruce G. Gallagher (Chairman), Accident Prevention Coordinator, Ontario 19 Hydro, Toronto, Ontario, Canada; T. L. Powers (Vice Chairman), Safety Engineer, Public Service Electric & Gas Co., Newark, N. J. Publicity Committee--William W. Williford (Chairman), Safety Methods Supervisor, The Chesapeake & Potomac Telephone Companies, Washington, D. C.; Darrel R. Barnes (Vice Chairman), Safety Director, City of Colorado Springs, Dept, of Utilities, Colorado Springs, Colo. Audio Visual & Training Aids Committee--Gerald R. Thomas (Chairman), Safety Director, Columbus & Southern Ohio Electric Co., Columbus, Ohio; Tom J. O'Donnell (Vice Chairman), Safety Director, El Paso Natural Gas Co., El Paso, Tex.; Charles H. Tupper. Director, Safety Dept. International Brotherhood of Electrical Workers, Washington, D. C.; Wayne L. Chadbourne, Director of Safety, Central Maine Power Co., Augusta, Me.; Louie A. Hallford, Jr., Asst. Manager of Safety, Texas Power & Light Co., Dallas, Tex.; James G. Anderson, Safety Director, Arkansas Louisiana Gas Co., Shreveport, La. Newsletter Committee--Ralph J. Richey (Editor), Staff Supervisor-Safety, AT&T Long Lines Dept., Pittsburgh, Pa. 15219; Richard V. Molen (Associate Editor), Supervisor-Safety Services, Consol idated Edison Co. of New York, New York, N. Y. Research Committee--H. E. Spaulding (Chairman), Safety Director, Central Vermont Public Service Corp., Rutland, Vt.; Hiram G. Tripp (Vice Chairman), Safety Director, Chattanooga Electric Power Board, Chattanooga, Tenn.; Q. Ray Bowers, Morton, 111.; C. Richard Chapin, Accident Prevention Administrator, Long Island Lighting Co., Hicksville, N. Y.; Leo A. Barner, Safety Supervisor, Laclede Gas Co., St. Louis, Mo. Contests & Awards Committee--Richard J. Oliphant (Chairman), Safety Director, Denver Water Dept., Denver, Colo.; A. L. Furanna (Vice Chairman), General Manager, Public Utilities Commission, London, Ontario, Canada; Harold E. Poike, Senior Safety Representative, Detroit Edison Co., Detroit, Mich.; Charles J. Popke, Safety Director, The L. E. Myers Co., Chicago, 111. IndustrialHygiene Committee--RobertJ. Owens (Chairman), Safety Engineer, Pacific Gas & Electric Co., San Francisco, Calif.; Clarence O. Lind (Vice Chairman), Personnel Supervisor, Illinois Bell Telephone Co., Chicago, 111.; Richard V. Molen, Supervisor-Safety Services, Consolidated Edison Co. of New York, New York, N. Y.; Gene Mire, Safety Specialist, Columbus Gas Transmission Corp., Houston, Tex. Nominating Committee--`Robert F. Mills (Chairman), Safety Consultant, T. A. Pelsue Co., Englewood, Colo.; *B. J. Lorenz:, Manager of Safety, Northern Indiana Public Service Co., Hammond, Ind.; Charles W. Schweickart, President, Hoosier Engineering Co., Dublin, Ohio; `Paul Windsor. Chicago, 111. Cameron Award Coordinator--John R. Yeaman. Jr. (Chairman) Special Representatives American Gas Association--Alex Pierson Canadian Electrical Association--Bruce G. Gallagher National Job Training & Safety Association--Ernest G. Shearer American Public Power Association--Herbert Blinder, Washington, D. C. American Water Works Association--Richard J. Oliphant; Harry W. Becker (Alternate), Safety Director, New York, N. Y. Smff ReptesaWiUtx--Ralph M. Coe, National Safety Council, 425 N. Michigan, Ave., Chicago, 111. 60611 U| National Safety Council A Membership Organization Dedicated to Protecting Life and Promoting Health March 21, 2001 Baron & Budd, P.C. The Centrum 3102 Oak Lawn Avenue, Ste. 1100 Dallas, TX 75219-4281 To Whom It May Concern: The attached records are kept and maintained in the regular course of business ofthe National Safety Council, and it is the regular course ofbusiness ofthe National Safety Council to keep and maintain the attached records. The attached photocopied material is an authentic reproduction of an original file copy of: NATIONAL SAFETY COUNCIL CONGRESS TRANSACTIONS 1972, VOLUMES 1-5,7-16, 19-22,25. National Safety Council, Chicago, IL. Respectfully, Robert J. Marecek Manager, Library Si- \L" \ 1121 Spring Lake Drive Itasca. IL 60143-3201 (630) 285-1121 FAX (630) 285-1315 SAFETY ) Air BAG SAFETY: &UCKLE EVERYONE! CHILDREN IN BACK! httpy/www.nsc.org