1. Fall Protection Program Western’s fall protection program evolved in 1992. As with many employers, it was prompted by a serious fall and a lack of knowledge about fall protection. A group of managers, supervisors, engineers and representatives from Western’s crafts came together and developed a formal and comprehensive program which was implemented soon after. At the time, there was little guidance related to fall protection for overhead utilities. OSHA and ANSI standards had not evolved and fall protection for overhead utilities was generally considered to be infeasible. Applicable fall protection equipment was minimal but Western obtained what they could, determined how to make it work and trained the crafts to use it when it could be used. Fall Protection Program Western’s fall protection program evolved in 1992. As with many employers, it was prompted by a serious fall and a lack of knowledge about fall protection. A group of managers, supervisors, engineers and representatives from Western’s crafts came together and developed a formal and comprehensive program which was implemented soon after. At the time, there was little guidance related to fall protection for overhead utilities. OSHA and ANSI standards had not evolved and fall protection for overhead utilities was generally considered to be infeasible. Applicable fall protection equipment was minimal but Western obtained what they could, determined how to make it work and trained the crafts to use it when it could be used.

2. Fall Protection Program Once it was implemented the program remained static up to 2005. Lack of incidents supported that the program was effective and didn’t need to change. Unfortunately, several serious incidents between 2005 and 2007 prompted a review of the program and it was determined that it needed to be revised and updated. During the review process the program morphed from a management based to a user based program in that Western’s Fall Protection Committee was developed. The committee consisted of a Safety representative performing as the Chair, a Maintenance Management representative and the rest of the members were regional representatives from the crafts. A Charter was developed to make the committee responsible for maintaining the fall protection program, facilitate all applicable training, review and recommend equipment needs, investigate any fall related incidents and most importantly develop and maintain Western’s fall protection policies. Additionally, Western adopted a ‘Train the Trainer’ to improve it’s fall protection training program.

3. Fall Protection Program The effort from 2007 also identified the need for Western’s fall protection program to be an aggressive and constantly evolving process. It also prompted the craft members of the fall protection committee to dedicate themselves into becoming Subject Matter Experts in fall protection design, engineering, technics and application to overhead utilities. Again, Western’s program proved effective up to 2012 when a serious incident on a wood pole occurred. Up to that time, wood pole fall protection had not been adequately addressed by the overhead utility industry or the fall protection manufacturers. Fall protection for vertical transition on wood poles was mostly considered to be infeasible. Western’s fall protection committee went to the manufacturers, determined what was available and worked with them to develop better products for wood pole climbing that were effective and user friendly. By the end of 2013, 100 percent fall protection on wood poles was not only feasible but had also resulted in the development of ‘fall restrict’ devices. The devices were not only very effective for climbing and work positioning, they were well received by the linemen using them. Western mandated 100 percent fall protection on wood poles by mid-2014. The effort from 2007 also identified the need for Western’s fall protection program to be an aggressive and constantly evolving process. It also prompted the craft members of the fall protection committee to dedicate themselves into becoming Subject Matter Experts in fall protection design, engineering, technics and application to overhead utilities. Again, Western’s program proved effective up to 2012 when a serious incident on a wood pole occurred. Up to that time, wood pole fall protection had not been adequately addressed by the overhead utility industry or the fall protection manufacturers. Fall protection for vertical transition on wood poles was mostly considered to be infeasible. Western’s fall protection committee went to the manufacturers, determined what was available and worked with them to develop better products for wood pole climbing that were effective and user friendly. By the end of 2013, 100 percent fall protection on wood poles was not only feasible but had also resulted in the development of ‘fall restrict’ devices. The devices were not only very effective for climbing and work positioning, they were well received by the linemen using them. Western mandated 100 percent fall protection on wood poles by mid-2014.

4. Fall Protection Program OSHA drops a bomb. Contrary to what the overhead utility industry had been lead to believe since 2005, OSHA issued a Final Rule on April 1, 2014 which mandated 100 percent fall protection for employers falling under 1910.269 and 1926, Subpart V for Power Generation, Transmission and Distribution. Compliance for non-transmission structures (transformers, circuit breakers, switches, etc.) was required by July 10, 2014 and for transmission structures by April 1, 2015. While the industry and the manufacturers were ill prepared for this, Western was a step ahead and was already mostly compliant. Unfortunately, the lack of systems specific to ‘first man up’ for transmission structures and for transformer tops was the main culprit preventing Western from being 100 percent compliant. OSHA even provided an ‘infeasible’ option for employers in the Final Rule. None the less, Western responded by developing and initiating an OSHA Compliance Plan in early May of 2014 that included expanding efforts with the fall protection equipment manufacturers and working with a small group of other utilities in the western US to fill the gaps in providing 100 percent fall protection for both non-transmission and transmission structures. The effort also identified the need for Western to expand the fall protection committee into three subcommittees to individually cover transmission structures, communication structures and substation/facility structures. Luckily, Western’s commitment to fall protection in advance of the new requirements resulted in not only fully meeting OSHA’s compliance dates but we also stepped out as a leader in fall protection for overhead utilities prompting other utility entities to come to us for guidance. OSHA drops a bomb. Contrary to what the overhead utility industry had been lead to believe since 2005, OSHA issued a Final Rule on April 1, 2014 which mandated 100 percent fall protection for employers falling under 1910.269 and 1926, Subpart V for Power Generation, Transmission and Distribution. Compliance for non-transmission structures (transformers, circuit breakers, switches, etc.) was required by July 10, 2014 and for transmission structures by April 1, 2015. While the industry and the manufacturers were ill prepared for this, Western was a step ahead and was already mostly compliant. Unfortunately, the lack of systems specific to ‘first man up’ for transmission structures and for transformer tops was the main culprit preventing Western from being 100 percent compliant. OSHA even provided an ‘infeasible’ option for employers in the Final Rule. None the less, Western responded by developing and initiating an OSHA Compliance Plan in early May of 2014 that included expanding efforts with the fall protection equipment manufacturers and working with a small group of other utilities in the western US to fill the gaps in providing 100 percent fall protection for both non-transmission and transmission structures. The effort also identified the need for Western to expand the fall protection committee into three subcommittees to individually cover transmission structures, communication structures and substation/facility structures. Luckily, Western’s commitment to fall protection in advance of the new requirements resulted in not only fully meeting OSHA’s compliance dates but we also stepped out as a leader in fall protection for overhead utilities prompting other utility entities to come to us for guidance.

5. Fall Protection Program Western’s fall protection committee remains very busy moving the program forward. They are anticipating OSHA issuing the Final Rule for 1910, Subpart D and I in April of 2016. The following are other notable activities and efforts of Western’s fall protection committee: Adopted the motto ‘No One Falls’. Assisted Bonneville Power and Southwestern Power to develop their fall protection programs. Expanded the Power Marketing Administration’s fall protection partnership to include an ever-growing group of utility companies and manufacturers. Has participated as a voting member on the ANSI/ASSE Z359 Fall Protection Committee for over 10 years. Have had a number of features and articles in a variety of industry publications including Transmission and Distribution and Incident Prevention.. A number of committee members also have achieved Certified Utility Safety Professional (CUSP) status and are SPRAT certified for rope access. Worked with several manufacturers to develop harnesses specifically designed to work on wood poles, lattice steel structures and to work from helicopters. Worked with manufacturers and other utilities to review, develop and implement ‘first man up/last man down’ systems to access lattice steel structures. Developed and having a modified ‘Y’ lanyard manufactured to use for connection to the sternum harness attachment point and utilized step bolt or step bolt anchor flanges as anchorage while ascending/descending lattice steel towers. Designed and have step bolt anchor flanges manufactured for installation on steel ‘mono-poles’. Have worked with manufacturers to develop better fall protection equipment and systems for use on the top of transformers. Have included the use of cranes and aerial devices as anchor points on substation equipment. Have produced two highly regarded fall protection training videos with another to be released this month. Additional videos are in the works. Hosted a symposium for fall protection on transmission structures back in July of 2014. There were more than 100 participants representing utilities, consultants and vendors from across North America and Europe. After receiving numerous inquiries, Western is currently planning another symposium for May of 2016 that will include transmission, substation and communication structures. It is anticipated that attendance will exceed 300. Provide assistance and give presentations to other utilities regarding fall protection. Developed a user friendly interactive website and SharePoint team site to greatly improve communications and provide access to pertinent document, especially in regards to the crafts working in the field. Also intend to develop an App that will allow access via smartphones. Are currently developing a ‘Train the Foreman’ program to assist on site supervisors to improve hazard recognition and problem solve on the work sites. Western’s fall protection committee remains very busy moving the program forward. They are anticipating OSHA issuing the Final Rule for 1910, Subpart D and I in April of 2016. The following are other notable activities and efforts of Western’s fall protection committee: Adopted the motto ‘No One Falls’. Assisted Bonneville Power and Southwestern Power to develop their fall protection programs. Expanded the Power Marketing Administration’s fall protection partnership to include an ever-growing group of utility companies and manufacturers. Has participated as a voting member on the ANSI/ASSE Z359 Fall Protection Committee for over 10 years. Have had a number of features and articles in a variety of industry publications including Transmission and Distribution and Incident Prevention.. A number of committee members also have achieved Certified Utility Safety Professional (CUSP) status and are SPRAT certified for rope access. Worked with several manufacturers to develop harnesses specifically designed to work on wood poles, lattice steel structures and to work from helicopters. Worked with manufacturers and other utilities to review, develop and implement ‘first man up/last man down’ systems to access lattice steel structures. Developed and having a modified ‘Y’ lanyard manufactured to use for connection to the sternum harness attachment point and utilized step bolt or step bolt anchor flanges as anchorage while ascending/descending lattice steel towers. Designed and have step bolt anchor flanges manufactured for installation on steel ‘mono-poles’. Have worked with manufacturers to develop better fall protection equipment and systems for use on the top of transformers. Have included the use of cranes and aerial devices as anchor points on substation equipment. Have produced two highly regarded fall protection training videos with another to be released this month. Additional videos are in the works. Hosted a symposium for fall protection on transmission structures back in July of 2014. There were more than 100 participants representing utilities, consultants and vendors from across North America and Europe. After receiving numerous inquiries, Western is currently planning another symposium for May of 2016 that will include transmission, substation and communication structures. It is anticipated that attendance will exceed 300. Provide assistance and give presentations to other utilities regarding fall protection. Developed a user friendly interactive website and SharePoint team site to greatly improve communications and provide access to pertinent document, especially in regards to the crafts working in the field. Also intend to develop an App that will allow access via smartphones. Are currently developing a ‘Train the Foreman’ program to assist on site supervisors to improve hazard recognition and problem solve on the work sites.

6. Western’s Fall Protection Webpage

7. Western Fall Protection Committee Team Site