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 Post subject: Iowa OSHA Declatory Order on short sleeve shirts
PostPosted: Wed Aug 12, 2015 8:55 am 
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Attached is a recent declaratory order from Iowa's Division of Labor Services concerning the use of short sleeve AR clothing under rubber sleeves.


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 Post subject: Re: Iowa OSHA Declatory Order on short sleeve shirts
PostPosted: Wed Aug 12, 2015 9:47 am 
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I agree with the decision. I think it is consistent with the applicable standards.


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 Post subject: Re: Iowa OSHA Declatory Order on short sleeve shirts
PostPosted: Sat Aug 15, 2015 5:03 pm 
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Rubber gloves have been essentially "type tested" in open literature. There is a distinct difference with different colored gloves but it all meets or exceeds 40 cal/cm^2 by a wide margin. True that the sleeves haven't been tested as far as I know yet but my thought is that they will go down the same path and be "type tested".

Four thoughts occurred while reading this. First, I don't live in Iowa. I live in North Carolina on the coast. Lets just say I laughed when I read the part about the temperature sometimes getting as hot as 100 degrees. Linemen have been putting up with long sleeve shirts and rubber sleeves for years here. Perhaps corn fed linemen get fat and lazy and can't take the mild summers in Iowa. Fire them and let them starve. Once they get a little hungry they won't have any more problems. Second, during OSHA's review of the 1910.269 update they specifically addressed heat stress. Single layer arc rated PPE is no worse than non-arc rated shirts and in most cases specifically because it's a concern, the stuff is actually more breathable than the corresponding non-arc rated shirts. Neil had some data on this that is published in that document. Third, it would seem that the cuffs have to be secured and if the sleeves don't cover, the sleeves would have to be modified (perhaps with some elastic) to hold them down. Some creative taping in the field comes to mind, too. Finally the fourth thought is that the standards are based on avoiding a fatality. At 7.5 inches away (half the OSHA assumed working distance), incident energy is quadrupled. It keeps going up by a factor of 4 with each halving of the distance. Yet we are not ratcheting up the ATPV requirement to protect arms and hands, nor are we ratcheting down the legs and feet as they get further away from the work. Instead the requirement is for a UNIFORM, single incident energy number which is based on calculating the incident energy at the chest area. It is clear that the standard is based on survival, not uniform protection for all parts of the body. This is crazy. Either the standard should be to require the same level of protection for the entire body, as ludicrous and impractical as it is, or it should simply state the obvious that protection is oriented towards the trunk and face and stop worrying about arm pits, to say nothing of hands and fingers which are currently vastly underprotected. And don't try to explain this away with a "partial credit" excuse. No consideration for say 3rd degree burns to say nothing of 1st degree burns is given anywhere in any standard.


I have 2 long sleeve arc rated T-shirts. Both are Tingley. One is hi vis. The other is not. They are a lot more comfortable than the Indura Ultrasoft arc rated button down "work shirts" that I have, and just about as comfortable as a T-shirt. And when I'm not working energized. I used to push the sleeves up past my elbows when I wssn't working energized but they're actually more comfortable rolled down so I don't bother anymore.


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 Post subject: Re: Iowa OSHA Declatory Order on short sleeve shirts
PostPosted: Mon Aug 24, 2015 6:35 am 
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Location: Louisville, KY
I have done all the glove testing and we have also tested sleeves. Most will take between 20 and 100 cal/cm² but we can't guarantee any specific one since the research is limited and the brands make the gloves and sleeves differently. Long sleeved shirts under rubber sleeves are likely to provide almost no protection if the sleeves ignite. Have you ever seen a rubber fire?

OSHA should rethink this. We are working with the manufacturers and EEI to see if we can find a solution.

Hugh Hoagland
e-Hazard.com
502-716-7173


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 Post subject: Re: Iowa OSHA Declatory Order on short sleeve shirts
PostPosted: Mon Aug 24, 2015 2:53 pm 
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elihuiv wrote:
... We are working with the manufacturers and EEI to see if we can find a solution.


May I suggest the use of live line tools? No rubber sleeves to ignite or increase heat stress.

But if exposed rubber is a problem even over AR, what about the cuffs of rubber gloves that remain exposed past the leather protectors? ASTM requires this gap which increases with voltage class.


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 Post subject: Re: Iowa OSHA Declatory Order on short sleeve shirts
PostPosted: Wed Aug 26, 2015 8:25 pm 
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With respect to live line tools...

Under Z10 (hierarchy of controls) it would seem that this is the best approach...reduce or eliminate the hazard altogether. Take one look at a live line tool catalog and suddenly the tools available for non-live line work seem paltry by comparison.

But it can't be overemphasized...live line tool work is really challenging to do for more than the most simple and routine tasks. Mind you it can be done but its challenging to say the least. It increases the odds that mistakes can/will happen. In my opinion the best approach is to use the best tool for the job. Tasks that are relatively simple or require "brute force" such as pulling or closing cutouts are clearly best done with live line tools. That's the safest approach. But some tasks such as attaching saddles or replacing an insulator or a lightning arrester which requires detailed manipulation of hardware are best done with rubber glove work. Trying to do it with live line tools increases the likelihood of mistakes resulting in more faults or failures, and more exposures. In the end, the best answer is to use the best tool for the job, whether it's gloves or hot sticks.


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 Post subject: Re: Iowa OSHA Declatory Order on short sleeve shirts
PostPosted: Thu Aug 27, 2015 8:13 am 
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PaulEngr wrote:
In the end, the best answer is to use the best tool for the job, whether it's gloves or hot sticks.


I know of at least one state where such a choice is not available: Hot line work using rubber gloves is illegal.


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 Post subject: Re: Iowa OSHA Declatory Order on short sleeve shirts
PostPosted: Fri Aug 28, 2015 9:01 pm 
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stevenal wrote:
PaulEngr wrote:
In the end, the best answer is to use the best tool for the job, whether it's gloves or hot sticks.


I know of at least one state where such a choice is not available: Hot line work using rubber gloves is illegal.


Last I knew I think that was Alaska and although I'm usually at odds with labor unions in general, in this case we're both in agreement.

The ANSI Z10 argument against PPE in general goes like this. PPE in the end is specifically designed to reduce the hazard to an acceptable level. It does not PREVENT the hazard from occurring in the first place. And PPE itself is prone to a fairly high rate of failure even assuming that the user manages to use it correctly. In other words for example with rubber glove work, the lineman is being shocked 100% of the time. It's just that the rubber glove reduces the severity of the shock to an acceptable level (assuming it doesn't fail). This is in direct contract to hot stick work where although there is some residual current through the hot stick, the lineman is removed from direct contact and more importantly from an arc flash point of view, much farther away from the hazard. In effect the hazard is severely reduced or eliminated. In a similar fashion, cover up can be used effectively to eliminate exposed, energized parts and thus eliminate or minimize the exposure in the first place. And live line, bare hands work similarly eliminates the hazard imposed by the energized conductor by moving the hazard to the grounded structures.

As of the 2015 edition of 70E, ANSI Z10 must be taken into account. This means that instead of knee jerking into using rubber gloves and arc flash PPE, other methods of reducing and/or eliminating the hazard must be taken into consideration first before immediately jumping to PPE as the first, last, and only method used.


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 Post subject: Re: Iowa OSHA Declatory Order on short sleeve shirts
PostPosted: Wed Sep 02, 2015 12:59 pm 
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PaulEngr wrote:
stevenal wrote:
PaulEngr wrote:
In the end, the best answer is to use the best tool for the job, whether it's gloves or hot sticks.


I know of at least one state where such a choice is not available: Hot line work using rubber gloves is illegal.


Last I knew I think that was Alaska and although I'm usually at odds with labor unions in general, in this case we're both in agreement....


If Alaska is one, that makes two along with Oregon. Any others?


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