In a recent conversation, I had the opportunity to catch up with an acquaintance of mine. Ben is the safety compliance & loss prevention manger for a mid-western electric utility. During our chat he related an incident that occurred recently while one of his utility line crews was performing a transformer change out.
As it turns out, the inception point of this incident was put in motion a few weeks back when some members of the utility crew had attended a trade show in Louisville, Kentucky. After over a year of lockdowns and masking, a couple days out was a welcome reprieve and a great opportunity for the crew members to see people and learn what’s “new” in the industry.
The results, he said, were as expected; Members of the crews were able to see new equipment, attend some training classes and have a few good meals to boot. They met up with friends and perused the rows and rows of vendor booths, chatted with sales people about their products or services with the requisite situational story swapping, and telling of tall tales. With bags of marketing giveaways, hats, brochures, catalogs and vendor promises, the crew returned home safely.
The following Monday, the rest of the utility crew got a rundown of the events, training highlights, and products that were of interest. Ben said the operations manager and himself spent the better part of an hour talking with the line crew.
They discussed the information provided on products and services and how they might help the utility. One such product that piqued some interest from the crew that attended the show, was an FIBC bag (Flexible Intermediate Bulk Container) sold for lifting leaking transformers. The brochure and vendor sales person claimed “...you can lift the transformer with the bag because of a patented self-lifting design” and it is UN rated for shipping transformers. Some crew members thought this would be interesting and that it might save time in the field during change outs. So, the necessary calls were made and a few days later a couple FIBC samples showed up. Ben said, they did not have any change outs scheduled, so their evaluation was going to have to wait for the opportunity.
They did not have to wait too long, just a week later they were able to test this FIBC bag out. The line crew went about their normal process and removed the transformer from service, detached it from the pole and began lowering the transformer down to the ground using the bucket truck hoist and their approved lifting strap. With the transformer placed in the waiting FIBC the line crew then attached the hook to the woven fabric FIBCs’ bag straps and proceeded to lift the transformer per the manufacturer’s directions. As the slack was taken up, the woven bag’s sides closed in on the heavy transformer and the bottom of the bag climbed up the transformer’s side.
The bag’s strain under the weight of the transformer was visible from the sewn lifting strap attachment points down the sidewall to the base of the bag. Just a about a foot or so off the ground, the bag gave way and the transformer ripped through the sidewall and base crashing to the ground on its side with a shattering thud of metal hitting cement. With all eyes staring in amazement at what just happened, only the gurgling sound of transformer oil pouring out of the fallen transformer broke the silence. What was a routine change out became a reportable spill incident! “Thank God no one was hurt!”, said Ben.
What is an FIBC?
Let’s begin with understanding the basics of an FIBC.
First the term FIBC, as indicated above, is an anacronym for Flexible Intermediate Bulk Container. FIBC is a class of packaging designed to transport bulk materials. The specifications for this can be found in the International Standard, IS0 21898:2004, which details out the indispensable reference documents regarding FIBCs.
The Scope section of this ISO document indicates an FIBCs intended use – a packaging solution for bulk materials in granular, powder or paste form. Additionally, the 30 plus pages cover everything from material construction, filling, discharging, handling devices, marking requirements, testing procedures to certification. Basically, this type of packaging is designed for bulk flour, grains, gravel, soil and alike. It’s not designed or tested for articles, like a transformer or for any type of contained inner packaging. In fact, ISO 21898 performance tests and certifications for this type of packaging is only for solid flowable materials. This includes any and all claimed weight ratings and capacities.
The United States Code of Federal Regulations (CFR) Title 49 Transportation (UN/DOT) recognizes woven fabric FIBCs as a type of bulk packaging classified between 13H1 to 13H4 and restricts FIBCs from having any intermediate form of containment or inner packaging. Pipeline and Hazardous Materials Safety Administration (PHMSA) reinforces this restriction on inner packaging or articles inside an FIBC with their own Letter of Interpretation #16-0173
How do you safely lift a transformer? So now that we know what an FIBC is and what it is designed for i.e., its intended use, was this the right tool for the job? Were safe lifting procedures and lineman training followed?
Rigging the load is a critical step when lifting a transformer or any piece of electrical equipment. According to the Lineman’s handbook used by lineman training schools, in utility safety departments and by lineman instructors, they all teach the safe and proper way of rigging and lifting a utility transformer. Specifically, by using the lifting lugs built into the transformer at the time of manufacture. This safety protocol is required by ANSI Standard C57.12.20 by which every transformer manufacturer incorporates engineered, permanently attached, lifting lug points on their transformers. These required lifting lugs provide for safe lifting sling attachment for a balanced lift in a vertical direction for the completely assembled transformer and shall be designed to provide a safety factor of five.
The Occupational Health and safety Administration (OSHA) has many regulations regarding rigging and safe lifting when using a motorized hoist or crane. Most utility safety departments reference compliance with 29 CFR 1910 regulations. But consideration should be given to the additional requirements when using mobile cranes and hoists covered by 29 CFR 1926, even if there is an exemption for some of their equipment.
The rigger’s starting point would be found in OSHA regulation 29 CFR 1910 that requires that the load be attached to the hook. Was the load attached to the hook? In the scenario detailed above, the transformer was in a bag. The bag was attached to the hook ergo, the load (transformer) was not attached to the hook. It was free floating in the bag. Further, the rigger is required to follow 29 CFR 1910 which states The load is well secured and properly balanced in the sling or lifting device before it is lifted more than a few inches.
Was the load balanced and secure? If the load (transformer) is free floating in a bag, how can it be balanced and secure?
Although the use of FIBCs to lift transformers or other electrical equipment is somewhat isolated, it is happening in the industry. These unscrupulous companies are claiming FIBCs can be used to lift transformers as described above and claim OSHA & UN/ DOT compliance with tremendous weight capacities. Weight capacities that are calculated using ISO 21898 standards that are for filled FIBCs filled with flowable materials, with even distribution of stresses across all surfaces of the FIBC. Not point loading caused by placing an article, like a transformer, inside an FIBC. These claims are all designed to convince you that their product is regulatory compliant, easier to use and saves you time. These companies are only telling you half the truth. FIBCs are OSHA and UN/DOT compliant packaging solutions when used for their intended use and with the proper materials – grains, flour, sand, gravel i.e., for flowable materials that fill the packaging as it was intended to be used. However, these deliberate omissions as documented above, make it appear that the certification and regulatory compliance apply to the use of FIBCs for electric utility transformers or other equipment.
Nothing could be further from the truth. In a regulatory agency investigation, making the claim “…but the salesman said it was approved and would work” is not going to be a viable defense. Safety managers have to do their research. Just because a product is marked as OSHA or UN/DOT com-
pliant does not mean that it is so for every possible use. One must ask, what is the intended use? Does this use follow our proven safety training? And if it sounds too good to be true…it usually is. Ben’s story would have taken a very different path had one of the crew members been hurt. It will be difficult for a utility to justify the use of an FIBC to lift a transformer when even a first-year law student can do an internet search for the definition and intended use of an FIBC.
The Right Tool for the Job
So how should a utility line crew safely contain and lift leaking or non-leaking transformers? Simply lift it by the lugs and use the Andax Transformer Containment Bag. The containment bag that provides line crews access to the manufactures lifting lugs, while containing the transformer at the same time. Never lift a transformer by a bag. OSHA requires that the load must be attached to the hook and that it must be balanced and secure. The Lineman’s Handbook, Lineman Training schools and transformer manufactures stipulate safe lifting of transformers by the manufactures engineered lifting lugs, in compliance with ANSI Standard C57-12-20. UN/DOT regulations specifically do not allow articles inside FIBCs, and ISO 21898, the standard to which FIBC are made, states that they are for made for flowable bulk materials.
When it comes to safely lifting and moving transformers or other equipment, be safe and compliant …lift it by the lugs.
