Safety and Compliance on Low Voltage Projects

Cal/OSHA IIPP and site-specific safety plans#

Every California employer is required to maintain a written Injury and Illness Prevention Program under Title 8, section 3203 of the California Code of Regulations. Ours names the person responsible for the program and describes how hazards are identified and corrected, how employees are trained, how incidents are investigated, and how safety communication runs between the office and the field. A copy is furnished in the prequalification packet.

A low voltage crew works inside the GC’s site under the GC’s safety program, and our plan says so. For each project we prepare a short site-specific plan that lists the scopes we will perform, the hazards those scopes create in that building, the controls and PPE required, the emergency contacts, and the competent person named for any scope that requires one. It is reviewed at the GC’s orientation, updated when the phase or the conditions change, and it sets the toolbox talk topics for the crew on that project. On public agency and campus projects the plan is adapted to the owner’s badging, escort and after-hours rules.

Ladders, lifts and working in occupied buildings#

Falls from ladders are the main fall hazard in our scope, and most of our work is above the ceiling. Crews use the right ladder for the height, inspect it before use, and do not work from the top two rungs. Scissor and boom lifts are used where the height or duration calls for them, and that work is performed to the Cal/OSHA requirements for operator training and evaluation, fall protection where the equipment calls for it, and inspection before the shift. Overhead work in an occupied space is barricaded, and ceiling tiles go back at the end of the shift.

Many of our projects are in buildings with people in them: state agency floors, campuses, senior housing, clinics. Work areas are cordoned with signage, cable is never run across a corridor at floor level, tools and material do not sit in an egress path, and dust and noise producing work is scheduled in the windows the owner allows. In senior housing and healthcare, residents and patients are notified before work in their unit, and a member of the owner’s staff is involved when we enter. The occupied building phasing guide describes the sequencing side.

Lockout, tagout, firestopping and plenum-rated materials#

Line voltage work and energized electrical equipment belong to the electrical contractor. Where our work needs power shut down, for example to land equipment in a telecom room, the shutdown is scheduled with the GC and performed by that contractor under its own lockout and tagout procedure. Our technicians apply their own locks and tags to the same isolation point where the procedure requires it, and no lock comes off until our people are clear. The handoff between our scope and the electrician’s is drawn on the submittals.

Every penetration we make through a fire-rated wall, floor or shaft is firestopped with a listed system matched to the penetration, the rating and the cable type, and the system used is recorded. Sleeves are sized to leave room for the firestop to be redone when cable is added later. Where a ceiling space is a return air plenum, the cable is plenum rated, CMP, and non-plenum cable does not go into a plenum regardless of who furnished it. Riser cable, CMR, is used in vertical shafts. These are California Electrical Code requirements and are checked on inspection.

Prevailing wage, NDAA equipment, background checks and badging#

On public works projects:

• We pay the prevailing wage for the classification and the county under Labor Code 1720 and following.
• Certified payroll records are submitted electronically to the Department of Industrial Relations.
• Apprenticeship requirements under Labor Code 1777.5 are met.
• Public works bids are handled under Labor Code 1725.5, and DIR registration and current certificates go into the prequalification packet.

The final certified payroll is closed out with retention.

On any project with federal funding, including HUD-assisted housing, NDAA Section 889 and 2 CFR 200.216 prohibit cameras and telecommunications equipment from Huawei, ZTE, Hytera, Hikvision, Dahua and their subsidiaries and affiliates. Our submittals state the actual manufacturer of every camera, switch and access point, because many white-label camera brands are relabeled Hikvision or Dahua. On a covered project, equipment is specified and documented against that list before it is submitted, so the GC and the owner can check each manufacturer against it. The NDAA camera guide covers how to specify it.

School districts, state agencies, courts and some housing owners require background checks, fingerprinting or badging before a technician enters the building. We hire technicians who can pass those checks and build the processing time into the schedule at kickoff. On state office floors, the building manager’s badging and escort rules are followed on every visit.

Records we keep and furnish on request#

Every item above produces a record: the IIPP, the site-specific plan and toolbox talk logs, lift inspections, firestop system records, certified payroll, submittals stating manufacturer, and badging records. They are kept for the project and furnished to the GC or owner on request. Experience modification rate and incident statistics are read from carrier documents rather than from a web page. Tell us what your prequalification form asks for and we will have the carrier issue it.

Next step#

Send the site safety requirements with the bid documents, through the request a bid page or to carson@telelinkca.com, and the site-specific plan that comes back with the bid will be written to fit your program rather than handed over as a generic template. Tell us at the same time whether the building will be occupied, whether badging, fingerprinting or escorts are required, and whether the project carries federal funding, because all three change the schedule and the equipment we can submit.

General contractors can ask for the prequalification packet by email. The for general contractors page lists what a complete packet contains.