The American Wind Energy Association (AWEA) is developing a series of best safety and health practices designed to bring standardization and uniformity to the wind industry.
The guidelines, which establish minimum technical requirements for member companies, were developed by AWEA’s environmental health and safety (EHS) committee, whose 14 subcommittees, taskforces and forums are responsible for the formation of several key programs designed to protect wind industry employees and technicians, according to Michele Myers Mihelic, AWEA’s director of worker health and safety policy and standards development.
The effort began in 2013 with the issuance of best practices for working in confined spaces. This year, the safety committee completed best practice guidelines for lockout/tagout (LOTO) and dropped objects. Mihelic says the best practice program will extend to minimum personal protective equipment for climbing safety, fall protection systems and rescue. She expects additional white papers to be completed for driver safety programs and wind farm construction by WINDPOWER 2014 in May.
Notably, while the EHS committee incorporated feedback from the Occupational Safety and Health Administration (OSHA), the agency has not technically approved the guidelines. The hope is that OSHA will participate with the industry to develop so-called consensus standards per the American National Standards Institute (ANSI). According to a recent circular from the Office of Management and Budget, a government agency can adopt the consensus standards as part of its formal rule-making.
The guidelines are AWEA’s most ambitious plan yet to demonstrate to federal agencies, such as OSHA, the importance it places on worker health and safety.
Since the formation of a joint venture AWEA formed with OSHA in August 2011, the wind industry has increasingly worked to educate the agency on the nuances – and idiosyncrasies – of wind farms. In September 2012, for example, AWEA trained more than 40 OSHA representatives at Suzlon Wind Energy Corp.’s Elgin, Ill.-based training center on various aspects of working in and around wind turbines. The two-day program included climbing, rescue, self-descent and fall arrest exercises, as well as lectures on permit-required confined-space entry and energy isolation procedures, such as LOTO.
The rationale is simple: The more OSHA understands about the unique challenges facing wind turbine technicians, the better. AWEA is hoping that OSHA will use its wind-related knowledge when considering future enforcement-related infractions. Because AWEA only recently began to keep track of safety-related incidents on wind farms, AWEA’s 325-member EHS committee set out on a fact-finding mission from wind farm owners and operators, original equipment manufacturers (OEMs), and independent service providers. Intent on establishing a set of industry best practices, the EHS committee boiled down the most complex technical issues into their most basic form, Mihelic notes.
She explains that the committee found itself asking, “What are the basic requirements needed for this issue? What should be included, and what should be left out?”
A matter of design
One of the biggest challenges centered on design specifications, which encompass all aspects of a wind turbine, from its structure to the electrical systems.
As wind turbines began arriving en masse from Denmark, Germany and Spain during the mid to late 1990s, the machines were not compliant with all applicable U.S. standards, such as those of ANSI, according to Bob Rugh, a long-time wind industry executive who worked for Zond Wind at the time.
“Many notable competitors felt that they already complied with the requirements of their respective countries of origin – which they believed were superior – [so] they did not feel compelled to comply with U.S., state or local requirements,” Rugh recalls. “A few states were strict and stringent in their requirements for compliance, and consequently, some OEMs were forced to comply to those specific state requirements, but by and large, the offshore-based OEMs did not necessarily comply with all U.S. standards and requirements.”
At the time, he says, overall compliance enforcement was not stringent, “so many of those offshore-based OEMs continued to bypass the expense of compliance, which in many cases, enabled them to operate their businesses at a lower unit cost basis than [Zond],” he explains. “Obviously, this was a sore point for us, not only from a cost-competitiveness perspective, but more importantly, from the worker-safety perspective.”
Non-enforcement has resulted in a hodge-podge matrix of OEMs that comply and those that do not. Today, there are still some notable compliance gaps, such as acceptable ladder clearances inside wind turbines.
Per OSHA standard 29 CFR 1910.27, fixed ladders require a clearance of 30 inches from the ladder to allow technicians to safely ascend and descend. OSHA defines minimum clearances from fixed ladders to the “nearest permanent object” on the climbing side of the ladder and states that there shall be no potential hazards within 24 inches.
A typical wind tower is manufactured in three sections and is fastened together by a series of bolts and flanges. However, the flanges – some of which protrude several inches into the technician’s safety space – may reduce clearance on the climbing side of the fixed ladder to less than 30 inches, creating a protruding hazard for workers ascending or descending the ladder on the climbing side of the fixed ladder.
In February 2013, OSHA notified AWEA that the agency clarified its position in a letter of interpretation (LOI).
OSHA wrote, “Ladders found in wind turbine generators installed in the United States must be designed and constructed to comply with 29 CFR 1910.27, as well as [with] any other applicable OSHA standards. 29 CFR 1910.27 (h), which also applies to wind power generating facilities, specifically requires that the ladders used at power generation facilities, such as wind turbines, comply with OSHA subpart D requirements.”
Although the LOI clarified OSHA’s position, the ruling did not include specific instructions for how owners and operators can comply with the rules.
“The LOI was narrow in scope,” Mihelic explains. Although towers and turbines perform similar functions, each has a different design that has to be taken into account. The so-called ladder clearance issue has led to a deeper discussion regarding the importance of design and what role it should play in safety requirements.
According to Mihelic, AWEA is currently applying for an industry-wide variance on the ladder clearance distance.
“When you start to get into some of these issues, you better be careful in how you arrive at the letter of the law,” explains Gary Lee, senior health and safety manager at EDP Renewables, and a member of the EHS committee.
To underscore his point, Lee notes that OEMs have differing views on the placement of transformers – which increase, or step up, the output supplied by the turbine to the grid – on a wind turbine. Some OEMs, such as Vestas and Gamesa, place the transformer up-tower inside the nacelle. Other manufacturers, such as GE, typically place the transformer at the base of the tower.
“The equipment on the turbines varies, and so do the hazards,” says Lee. “So it’s difficult to arrive at a one-size-fits-all solution.”
Another seemingly rudimentary consideration was establishing base-level criteria for industry-wide benchmarking. Committee members theorized that if organizations freely shared safety-related data, such as the rate of safety-related incidents, such disclosures would help other companies compare themselves against the industry as a whole.
However, the concept proved to be anything but simple, explains Krys Rootham, managing director of wind generation at Edison Mission Energy, and a member of AWEA’s safety committee.
By its nature, he says, some safety-related information can be highly sensitive. As such, getting member companies to share safety-related data and statistics information with AWEA – or with one another – could be difficult. Seemingly innocuous questions, Rootham says, could have compliance implications.
For example, one of the questions asked which companies had a qualified electric worker (QEW) program. If companies answered “no,” such a response could be construed by OSHA as a violation, Rootham notes, adding that not having QEWs on-site is a violation of OSHA requirement 29 CFR 1910.269.
By its own admission, AWEA says the formation of the safety program is far from perfect. For example, some have groused that AWEA relies too heavily on its member companies that occupy the volunteer committees.
“My concern is that from a standpoint of staffing and support, there’s a great reliance on the volunteer group,” according to Gary Wolf, group director of EHS at Gamesa Technology Corp. “Most of [the committee members] have day jobs,” he explains. To ensure the best outcome, Wolf maintains the presence of full-time staff could shoulder some of the committee’s responsibilities. “We’ve underestimated the resources required to do the job in an effective manner.”
For her part, Mihelic maintains that AWEA may revisit an issue in the future as methods change or technology improves. “The [white papers] are living and breathing documents. They will evolve and develop as the industry evolves.”
The encouraging news is that AWEA’s safety program is off and running. Industry participants say that establishing a consensus regarding worker health and safety will benefit the entire wind sector.
“We are going in the right direction,” Wolf explains. “There’s a growing sense of trust amongst OEMs. We have a common denominator: the safety of our people.” w
Marketplace: Safety Equipment
Best Practices Establish Baseline Safety Requirements
By Mark Del Franco
The American Wind Energy Association is working on best safety practices for its member companies.
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