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Phillip Ragain

The Human Error Trap

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The agitation of the managers sitting in the meeting room is palpable. The safety director sits stiffly at the conference table. Everyone is overwhelmed by a hurricane of thoughts. "We did everything we could, right?" Conjectures whirl. Voices surge. "We've spent the last three years installing a safety management system to keep this sort of thing from happening. It was textbook!”

These leaders wonder to themselves, “Did I do something that led to this?" But soul-searching eventually gives way to frustration as a voice stands out in the room: "What were they thinking out there?"

People grab hold of these words and their implication – that the incident occurred because a handful of people in the field did something wrong. It seems a simple matter of fact that explains what happened and points to what must be done next. "We will review our policies, retrain everyone, hold people accountable and get rid of those we can't trust." And it works … until the next storm blows in.

This scenario has played out countless times, with an array of casts and in the aftermath of many different kinds of events. Some are small-scale events, like an employee failing to lock out equipment before servicing it. Others are catastrophic events, like an exploding chemical plant.

My colleagues at The RAD Group and I propose that the thought process represented here is a trap, and one that people at all levels of an organization can fall into quite naturally. We call it the “human error trap,” and when organizations become ensnared, they find themselves unwittingly stuck in a status quo of safety.

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Andrew Salvadore, CSP

Safe Work Practices: The End of Fuzzing the Lines

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In today’s utilities, there are two essential things that need to happen to create a safe utility workplace, both of which are referenced in OSHA’s General Duty Clause. First, employers must provide their employees a workplace free of recognized hazards that can cause death or serious physical harm. Second, employees must comply with occupational safety and health standards, regulations and company rules that are applicable to their conduct at work.

With that said, when it comes to recognizing electrical hazards in the workplace, is it better to guess or to know? This isn’t a tough question for most utility workers to answer; it is better to know. And while today we know a great deal about how to keep our workers safe, many members of our industry have learned some hard lessons about how – and how not to – test for and verify the presence of electricity. Even as recently as the 1990s, the act of fuzzing or buzzing a line was not an uncommon testing and verification method. Fuzzing or buzzing occurs when a worker uses a live-line tool to hold a wrench or similar item near a line and then listens for a buzzing sound given off as the tool approaches an energized circuit part.

Looking Back
In 1994, OSHA first published 29 CFR 1910.269, which required workers to test for and verify the hazard of electricity. Remember that, according to the General Duty Clause, the employer must provide a workplace free of recognized hazards. So, if the hazard of electricity is recognized, it must be addressed. And since OSHA still permitted fuzzing or buzzing in 1994, it was sometimes still used for electrical testing and verification purposes.

A 1995 letter from OSHA to Lonnie Bell at Oglethorpe Power Corp. (see www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=21981) clarified the agency’s position. Mr. Bell had originally posed this question to OSHA: “Will an employer be found in compliance with 1910.269(n)(5) when his or her employees use the practices of fuzzing or buzzing, instead of a voltmeter, to test a line conductor to be grounded to be sure it is deenergized (dead) before the protective ground is installed?”

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Lee Marchessault, CUSP

Making Sense of Protection Requirements for Open-Air Arc Flash Hazards

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Electric utility workers face complex, high-risk electrical hazards nearly every day. Information about shock hazards – which may come from impressed voltage, residual energy, induction, objectionable current flow in a grounding system or stored energy – has been taught to many of us for quite some time, as have the methods of assessing them.

On the other hand, arc flash hazard assessments are still relatively new to us. In the past, most of us knew that an arc flash could potentially occur during the course of performing our tasks, but the level of the flash and the PPE requirements – other than wearing 100 percent cotton – were not seriously considered in our day-to-day activities until approximately 15 to 20 years ago. To provide more concrete guidelines, OSHA published new regulations in April 2014, with more recent enforcement dates. Instead of making a best guess about PPE, the industry now has a reasonable approach to providing adequate PPE for utility employees who are tasked with performing open-air work. Once a utility completes the required arc flash analysis, develops a policy based on the analysis results and adequately conducts training for affected field personnel, the job of assessing risk and determining PPE levels can easily be incorporated into the daily job briefing. The goal is to make the assessment data easy to access and understand in order to provide effective protection for all workers.

Causes and Severity Levels of Arc Flash Events
An arc flash is the result of either a short circuit during which two energized parts of different potentials (phases) make contact, or a ground fault where an energized part and a grounded conductive part of a different potential make contact. An arc flash event may be caused by a failure of electrical apparatus, potentially due to lack of maintenance, or by worker error, perhaps due to an employee moving conductive parts near energized parts or leaving conductive tools in an energized work area. It’s important to note that differences in potential must always be effectively isolated by distance (air) or insulated barriers.

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Naira Campbell-Kyureghyan, Ph.D.

Injury Risks Associated with Climbing in the Wind Energy Generation Industry

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The growth of the wind energy generation industry in the U.S. has been phenomenal. According to the American Wind Energy Association, at the end of 2016 there were over 52,000 utility-grade wind turbines operational in more than 40 states, with a total capacity of 83,000 megawatts. The Global Wind Energy Council’s latest report shows that the U.S. has the second-largest wind power capacity, after China, with 16.9 percent of the world total, and employs over 100,000 people directly or indirectly. As the number of wind turbine towers grows, so does the number of people involved in their maintenance and repair. In 2015, the U.S. Bureau of Labor Statistics projected that employment of wind turbine service technicians would grow 108 percent between 2014 and 2024. There were approximately 4,400 wind turbine service technician jobs as of 2014.

Wind turbine tower heights also are increasing, with the tallest tower currently in the U.S. measuring 379 feet hub height, and even taller towers have been installed elsewhere in the world. While some towers are outfitted with service lifts, in the majority of towers personnel must climb fixed ladders to perform both routine and unusual operations. The increasing numbers and heights of towers mean more workers climbing ever greater distances.

Research studies conducted at the University of Wisconsin-Milwaukee (UWM) that have specifically investigated the renewable energy sector, including wind power generation, along with data from OSHA and the Bureau of Labor Statistics, have identified multiple risks to workers as a result of climbing fixed ladders. Strains and sprains, falls, overexertion and even fatalities were reported to be possible direct consequences of climbing and working at heights during both the construction and maintenance of wind turbines. Indirect risks also were identified, including potentially being electrocuted from contact with high-voltage cables and being struck by an object or caught between objects. Although power generation injury statistics are not separated by fuel source, 2015 Bureau of Labor Statistics’ data indicates that there were three fatal falls in the power generation industry, and 550 falls with nonfatal injuries. Data from the United Kingdom shows 163 total accidents in the wind power industry in 2016, including five fatal accidents. This data generally is assumed to vastly underreport the actual numbers, which may be 10 times higher.

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Jim Vaughn, CUSP

Train the Trainer 101: Training and Verification Requirements for the Safety of Electric Utility Workers

A number of years ago I investigated a pole-top flash that took place during a transfer. The flash occurred when an improperly installed blanket left a dead-end flange exposed on the backside of the metal pole-top. During untying, the tie-wire contacted the exposed flange. No one was hurt. The issue was the lineman’s selection and installation of the blanket. The foreman assumed the lineman was experienced and competent to perform the three-phase transfer with minimal instruction. The problem was the lineman had spent the last several years on a service truck, had little transfer experience and had never worked a steel distribution pole. The foreman’s assumption was based on the fact that the lineman came from the IBEW hall. Even though they had never met, he assumed the lineman was sufficiently experienced – and so the root cause for the incident was established.

Training and verification of training for new, already-trained employees is another subject that has caused headaches for those professionals charged with OSHA training compliance and the employer liability that goes with it. OSHA, just like CanOSH, the agency’s Canadian counterpart, knows that training plays a huge role in incident prevention. It should be obvious that training prevents incidents, but the investigation of incidents across the continent proves that is not so. I have long said that the quality of your safety program and all of the component procedures, rules and policies that go with it, no matter how innovative and well-written, are only as good as the training you provide to the workforce. A safety program is supposed to protect the workforce first and the employer second. How can that happen if the workforce doesn’t know what’s in the program? And if the workforce doesn’t know what’s in the program, how does the employer expect the safety program to protect the employer?

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Danny Raines, CUSP

Voice of Experience: Qualified and Task-Specific Electrical Worker Training

The revised OSHA 29 CFR 1910.269 standard has now been in place for three years. In making the revisions, OSHA replaced older, passive language that left much to be understood with more objective language that clarifies the meaning and intent of the regulation. The standard is now easier to understand and sets the expectations for employers and employees.

There were some major changes made to the standard, as we all know. Several more subtle changes also were included and have been discussed much less, but they still have had a significant impact on the regulation. In this installment of “Voice of Experience,” I want to focus on one of these more subtle changes that I believe has a tremendous effect on the training requirements found in 1910.269(a)(2). The 1910.269 standard published in 1994 was straightforward, describing what was required in order for an employer to determine that an employee was a qualified worker. By and large, the industry believed that if an employee had the required training, he or she could be determined to be qualified. Now, per paragraph 1910.269(a)(2) of the revised 2014 standard, all employees performing work covered by the section shall be trained as follows:
• Each employee shall be trained in, and familiar with, the safety-related work practices, safety procedures, and other safety requirements in this section that pertain to his or her job assignments. (1910.269(a)(2)(i)(A))
• Each employee shall also be trained in and familiar with any other safety practices, including applicable emergency procedures (such as pole-top and manhole rescue), that are not specifically addressed by this section but that are related to his or her work and are necessary for his or her safety. (1910.269(a)(2)(i)(B))
• The degree of training shall be determined by the risk to the employee for the hazard involved. (1910.269(a)(2)(i)(C))

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Jim Vaughn, CUSP

June 2017 Q&A

Q: We have a group reviewing our personal protective grounding procedures, and they are asking if we should be grinding the galvanized coating off towers when we install the phase grounding connections. What are your thoughts?

A: In addition to your question, we also recently received another question about connecting to steel for bonding, so we’ll address both questions in this installment of the Q&A. Your question is about the effectiveness of grounding to towers, and the other question is about the effectiveness of EPZs created on steel towers. We’ll discuss the grounding question first and then move on to the EPZ question.

As to grounding effectiveness, we have two thoughts here – one simple and one that likely will raise more questions than we can resolve in these pages.

The simple thought is this: Consider grounding to the circuit static. It’s difficult to reach but doing so makes it easier to create an electrical connection. Using the system static shares current with adjacent structures and reduces current on the structure being worked. Dividing current among adjacent structures also reduces ground potential’s risks to workers at the foot of the tower. See the following Q&A regarding EPZ if you are grounding to the static.

As to connecting to the tower, grinding off the galvanized coating opens the underlying steel to corrosion and would need to be replaced after the operation. We have asked how utilities make connections and found that most use a flat clamp to a brushed plate or insulator bracket, or a C-clamp to a brushed bolt or step. Either method is a good one. Others follow one of the recommendations in IEEE 1048, “IEEE Guide for Protective Grounding of Power Lines,” 9.2.1.1 for lattice using a ground cluster. The cluster serves two purposes: providing a clamping connection and keeping the clamps close together.

Fortunately, the structure connection can be installed by hand, making the cleaning and mechanical security of the connection pretty reliable. There are several considerations to discuss that should be part of the training provided to lineworkers who make these connections.

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David McPeak, CUSP, CET, CHST, CSP, CSSM

Frontline Fundamentals: Responsibility for Safety

You are responsible for your own safety and the safety of others.

Most people would say they agree with that statement, but do their actions reflect their agreement? Let’s consider that question in the context of the following incident investigation.

The Incident
Bob, who works in shipping and receiving, has just cut himself with his pocketknife while attempting to cut a zip-tie off a package. Randy, the shipping and receiving manager, is Bob’s immediate supervisor. Pam is Bob’s co-worker. Ron is the facility’s safety supervisor and is interviewing Bob, Randy and Pam as part of the investigation.

Bob’s Interview
Ron: Can you tell me what happened?

Bob: We have a specially designed box cutter we use for cutting zip-ties. It works really well, but we lost it. I told Randy we lost ours and he said he would get us another one. That was three weeks ago. What am I supposed to do, not work? I have a job to do, and I’m going to make sure it gets done.

Ron: What could we do to prevent this from happening again?

Bob: We need the right tools for our job. Someone needs to make sure we have them.

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Tony Barton

Confined Space Training: It Has to Be Done Right the First Time

Confined Space Training: It Has to Be Done Right the First Time

Entering and working in confined spaces is serious business. In the years I’ve been a safety professional, I’ve been involved with several hundred confined space entries, including overseeing entries into most of the confined space examples listed in the scope of OSHA’s “Confined Spaces in Construction” standard. A number of times I’ve been called to the scene of a confined space entry where the entrants had been evacuated because of alarms from direct-reading portable gas monitors. Some of these alarms were caused by degradation of atmospheric conditions, while others were due to operator error. Thankfully, I’ve never been called to a scene involving a worker who was down and overcome in a confined space, but I must admit that where confined space entries are involved, such a situation is my worst nightmare.

Over the last few decades, part of my work also has included training hundreds of workers in confined space entry. Typically training covers two major components: teaching trainees the regulatory requirements of the standard for confined space entry, and training them about their employer’s specific processes and procedures for conducting confined space entries in compliance with the standard. However, as Jarred O’Dell, CSP, CUSP, noted in his February 2016 Incident Prevention article, “Trenching by the Numbers” (see http://incident-prevention.com/ip-articles/trenching-by-the-numbers), “This is a great approach but perhaps an incomplete one. Truly impactful safety training typically includes a third component: sharing of personal experience.” In this article, I want to share some of my personal experiences and goals as they relate to training workers on the topic of confined space entry, with the hope that I can offer some useful takeaways to other trainers and utility safety professionals.

A Major Motivator
I’ve always been passionate about teaching confined space entry, and my major motivator is this: If workers aren’t properly trained to enter confined spaces, they might not be able to go home at some point. I end every training session I conduct, regardless of the topic or skill level of those I’m training, by explaining to the trainees that the most important thing they will do each and every day is to safely go home to their families, their friends, their plans, their dreams – their lives.

I want my trainees to know that the reason we have confined space procedures, training, permits, direct-reading portable gas monitors and non-entry rescue equipment is because people can die in confined spaces. I also want them to know that many people who have died in confined spaces weren’t even the entrants. Nearly half of those who have died in a confined space situation were would-be rescuers. I want my trainees to care enough about safely going home at the end of the day that they will perform the necessary confined-space tasks correctly the first time, based on the training they have received, because I’ve found a way to make this training important to them on a personal level.

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Connie L. Muncy, CIH, CUSP, MS, REM

Shining a Light on Ventilation Systems and Surveys in the Electric Power Industry

Shining a Light on Ventilation Systems and Surveys in the Electric Power Industry

It takes a wide variety of activities – some obvious and others not so obvious – to keep electric utility operations humming along. With maintenance facilities and power plants in particular, there are sometimes unidentified exposures that grow as the facilities grow. In other scenarios, our understanding of exposures or emerging regulations requires the need for a professional hygienist to assess and remediate exposures. Ventilation surveys, which can detect ventilation system failures, are a critical but often overlooked tool that should be used to maintain safe, healthy operations, whether those are power generation operations, transmission and distribution operations, or peaker operations during which power is produced during periods of peak usage. All of these operations require appropriate ventilation to control atmospheric hazards. Failure to recognize the importance of maintaining and periodically checking ventilation systems may impart substantial hidden risk to personnel, facilities and operations.

However, it is not uncommon to see operations that lack the needed systems; are serviced by jury-rigged systems that do not meet operational needs; or are serviced by well-engineered systems that over time have fallen into disrepair due to a lack of ventilation surveys and preventive maintenance.

How is it that these matters fall between the cracks?

It is easy for occupational health to take a back seat to occupational safety or other priorities. Poor change management can be blamed if a new system is installed and there is either no follow-up or incomplete follow-up for hazard control concerns. A simple lack of subject matter expertise within an organization could be the problem; perhaps there is no knowledgeable industrial hygienist on staff and an overwhelmed safety professional wearing multiple hats gravitates away from his area of lesser expertise. In some cases, chemical exposures take years to become evident and manifest symptoms. As such, they are a lower priority than more high-visibility issues, like falls from height or arc flash. Or, it may be that ancillary activities are out of sight and out of mind, and not recognized as a priority for hazard control.

Regardless of the reason, occupational health and safety cannot be maintained without appropriate attention to ventilation matters. The purpose of this article is to shine a light on these matters and encourage organizations lacking the needed expertise to learn to handle them appropriately.

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Damon Beck

Marking a Safety Milestone at Silicon Valley Power

Marking a Safety Milestone at Silicon Valley Power

Clear minds, focused on the task at hand. Strict attention to details and checklists critical to the job. Precise and continual communication among the field, management and control teams. Ongoing training and safety manual review. Looking out for one another. Trust in the workforce’s skills with no micromanagement and with the boss’ door always open.

Such are the written – and unwritten – rules governing the field forces of Silicon Valley Power, the City of Santa Clara, Calif.’s municipal electric utility that recently marked a company milestone: 1,000 days without a lost day of work due to injury or work-related illness.

SVP serves 54,000 customers, including technology industry giants such as Intel, Owens Corning, NVIDIA, Texas Instruments and Applied Materials, and high-profile customers such as the San Francisco 49ers and Levi’s Stadium. Local generation resources include a 147-megawatt combined cycle natural gas plant, landfill methane gas and 20 megawatts of solar installations. Over 692 megawatts of renewable energy are imported from hydro, wind and geothermal partnerships and power purchase agreements; total renewables represent over 40 percent of the company’s power mix.

Health and Safety Success
SVP’s managers firmly believe that the company’s health and safety success begins with a multitude of safety briefings. These include weekly management conferences, mandatory shift start meetings and tailboarding before every job, regardless of scope.

And once the job begins, urgency is effectively tempered by caution. If safety may be jeopardized, there is never any pressure from the city or SVP management to hurry a job or push to restore power during an outage. Safety is first whether it’s in a project planning stage or when responding to an outage. Customer communications during an outage, including social media postings, stress that SVP will restore power as fast as its field force can safely do so.

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Peter Tyschenko and Michael Meathe

Using Thermography for Underground Worker Safety

Using Thermography for Underground Worker Safety

For more than 100 years, Commonwealth Edison – commonly known as ComEd – has been powering the lives of customers across Northern Illinois, including those in Chicago, a city that has thousands of circuit miles of medium-voltage distribution cables installed in conduit and manhole systems.

Over the decades, ComEd’s underground cable splicers have experienced failures of distribution cable system components, including cables, joints and terminations, while employees were working in manholes and vaults. A large number of cable system failures occurred at cable joints in underground manholes. Some of these failures were due to degradation of the electrical connection inside these joints.

One of the hazards associated with a cable system failure is the risk of employee exposure to an electrical arc flash. This type of event can result in temperatures in excess of 35,000 degrees Fahrenheit, producing a blinding flash and causing aluminum and copper cabling components to instantly expand. If an employee is working adjacent to equipment affected by the blast, the heat generated can cause third-degree burns, and the pressure wave can damage hearing and throw the worker into the surrounding structure.

A Culture of Safety
Past experience at ComEd has demonstrated that thermal issues with joints are centered on mechanical connections, typically those that are crimped. Such mechanical connections are used in pre-manufactured joints.

According to OSHA 29 CFR 1910.269(t)(7)(i), “hot localized surface temperatures of cables or joints” are an abnormality that may be indicative of an impending fault. Unless the employer can demonstrate that the conditions could not lead to a fault, “the employer shall deenergize the cable with the abnormality before any employee may work in the manhole or vault, except when service-load conditions and a lack of feasible alternatives require that the cable remain energized.” However, “employees may enter the manhole or vault provided the employer protects them from the possible effects of a failure using shields or other devices that are capable of containing the adverse effects of a fault.”

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Jim Vaughn, CUSP

Train the Trainer 101: Addressing Common Fall Protection Questions and Concerns

To begin this article, I want to offer a disclaimer. One of the reasons the “Train the Trainer 101” series was created is to examine the practical aspects of compliance as they relate to the utility industry. We do that by reading the statutes, looking at how OSHA interprets and enforces the rules, reviewing what the consensus standards state and then determining practical ways the employer can manage and comply with the rules. Sometimes I raise an eyebrow, but in working with the group of professionals who review every article published in Incident Prevention’s pages, we endeavor to ensure the advice given is not merely good but also compliant. With that said, in the following pages I am going to address some fall protection issues that iP has received many questions about in recent weeks. Several of them are driven by the latest OSHA final rule on walking and working surfaces, which contains some new language and expanded rules on fall protection.

Who is Responsible?
I get a lot of questions about fall protection that stem from a salesperson telling an employer they need to do a certain something in order to comply with OSHA. First, a nod to our partners in the industry: the vendors and manufacturers. They have done a great job meeting the needs of the employer by innovating, creating and often collaborating with the industry to get the tools we need into the field. Work with your vendors and manufacturer representatives, but be clear about your responsibilities in the relationship. Understand that there are no OSHA-approved devices for sale in any marketplace. OSHA does not approve equipment for manufacturers even though they may comment on a method of compliance if a written request is made by an employer. Even then, OSHA’s language to the employer often is something such as, “OSHA does not approve a particular device or piece of equipment, but the method you describe would meet the requirements of the standard.” And never forget that – no matter what the manufacturer’s rep says – you, as the employer, are ultimately responsible for how you comply with OSHA’s expectation. As I said, work with your vendors, but do your homework and educate yourself about the requirements. We aren’t just complying with standards – we’re protecting our employees and co-workers.

Common Misconceptions About Harnesses
I have often heard that you can’t arrest at the waist or chest. That is correct if you are truly arresting, which usually means the act of interrupting a fall from height by a personal fall arrest system attached to an anchorage limited to a distance of 6 feet. If you fall 6 feet, you must limit the fall arrest’s load, and the fall arrest’s load must be distributed across the body. That is why we use a full-body harness.

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Danny Raines, CUSP

Voice of Experience: OSHA Record-Keeping Requirements

OSHA record-keeping has long been an administrative challenge to businesses required to keep OSHA logs. In this installment of “Voice of Experience,” I’ll cover some changes that have occurred over the years as well as some essentials that all employers and employees must understand in order to maintain compliance with OSHA requirements.

When the change from the OSHA 200 log to electronic record-keeping was made in 2002, it was a relief to many. At that time, all issues involving first aid were resolved; a list of first aid treatments was identified and took any doubt out of the requirement to report medical attention beyond first aid.

The addition of a hearing loss column to OSHA’s Form 300, “Log of Work-Related Injuries and Illnesses,” in 2004 helped identify hearing loss for those businesses covered by OSHA 29 CFR 1910.95(c), “Hearing conservation program.” Previously, hearing loss often was considered an illness rather than an injury.

Today, the number of logs a business must maintain is determined by the number of premises operated by the business. A log is required to be maintained for each location with an address unless there are multiple facilities at the same address. Centralized electronic record-keeping is acceptable if the records can be provided within four business hours upon request by an OSHA officer. The request must be made in the location of the corporate office where records are kept, even when it is in a different time zone.

An injury must be reported to a record-keeper for logging within a maximum of seven days from the time of the accident; this requirement has not changed. The supporting forms required to document the log entry also remain the same. OSHA’s Form 301, “Injury and Illness Incident Report,” or an acceptable state workers’ compensation form must accompany any orders written by a licensed health care provider (LHCP). All documentation must be retained and kept available in case of an audit. The number of days away or restricted days must be recorded and may be capped at 180 days. The current year and the last five years of OSHA 300 logs must be available for audit or inspection upon request by approved officials. OSHA’s Form 300A, “Summary of Work-Related Injuries and Illnesses,” must be posted no later than February 1 of the year following the year covered by the form, and it must remain posted in the establishment for 90 days in conspicuous locations that are frequented by employees.

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Jim Vaughn, CUSP

April 2017 Q&A

Q: Our plant safety committee has a longtime rule requiring electrical hazard safety shoes for our electricians. We were recently told by an auditor that we have to pay for those shoes if we require employees to wear them. We found the OSHA rule requiring payment, but now we wonder if we are really required to use the shoes. Can you help us figure it out?

A: Sure, we can help. But first, please note that Incident Prevention and the consultants who have reviewed this Q&A are not criticizing a rule or recommending a rule change for any employer. What we do in these pages is explain background, intent and compliance issues for workers and employers in the workplace.

You mentioned a longtime rule that probably dates back to the early OSHA rules that required electrical hazard boots for electricians. We can’t remember exactly when, but there was a letter to administrators in the early 1990s and subsequent rule-making that changed the language on the use of electrical hazard shoes. Your auditor is right; if you require employees to wear them, you are required to pay for them because unlike regular safety shoes, the electrical hazard criterion makes the safety shoe a specialty shoe. Specialty shoes must be provided at no cost to the employee (see www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=29825).

Now let’s address the question, are the shoes required? Employers are required to perform a workplace hazard assessment and then use engineering or procedural controls to eliminate hazards. If a hazard cannot be eliminated by procedures or engineering, PPE is required. OSHA agrees throughout current literature that electrical hazard shoes are to be employed as part of a system of protection based on the hierarchy of controls. If you read the rule closely, you will see that the language is very particular. OSHA 29 CFR 1910.136(a) – edited here for clarity and space – states that the “employer shall ensure that each affected employee uses protective footwear … when the use of protective footwear will protect the affected employee from an electrical hazard, such as … electric-shock hazard, that remains after the employer takes other necessary protective measures.” Those other measures are the hierarchy first, PPE last.

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David McPeak, CUSP, CET, CHST, CSP, CSSM

Frontline Fundamentals: Risk Tolerance

A fundamental premise of working safely is that hazards must be identified and then controlled. Too many incidents occur because hazards are not identified, or worse, they are identified but ignored or tolerated.

One of my favorite ways to introduce the concept of risk tolerance is to ask a Frontline class this simple question: “What are some things you might hear someone say before something really bad happens?” It always amazes me – and scares me – how open participants are when I ask this question. Typical responses I have heard include:
• “We’ve done this a thousand times and no one has ever gotten hurt.”
• “We’ve always done it this way.”
• “This is going to hurt.”
• “If this works, we’ll be heroes.”
• “I think it will hold.”
• “I can survive anything for two minutes.”
• “What’s the worst that could happen?”
• “Here goes nothing.”

That list could go on for a long time, and it gives us a lot of insight into how we think about hazards and risk. In fact, I want to be sure to mention one incredibly memorable response not listed above that led to some great discussion about risk tolerance: “Hold my beer and watch this.”

Take a moment to remember if you have ever made that statement or heard someone else make it. What followed? I have heard stories involving “testing” an underground dog fence, in which someone held the shock collar in his hand and ran through the fence; jumping off a roof into a swimming pool; attempting to bench-press 400 pounds; boxing a kangaroo; and a myriad of other superhuman feats fueled by alcohol. Oddly enough, sober people do not think it is cool or that it will impress someone if they, for instance, eat a spoonful of cinnamon.

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Mark Steinhofer

The Silent Secret About Successful Safety Communication

The Silent Secret About Successful Safety Communication

It’s a chilly morning, and the crew is eager to make progress on the substation upgrade before tomorrow’s snow. A shiny pickup truck pulls up to the job site, the driver’s door opens and out walks a good-looking guy in neatly pressed khakis, a white button-down shirt and highly polished lace-up shoes. He stops a couple yards away from the crew, looks at everyone, breaks into a cheesy smile and makes a joke about his golf game.

Nobody laughs or even snickers. After an awkward pause, “Joe Office” tells the crew that fall protection is the day’s safety discussion topic. He points to one of the crew members and mentions that he saw him working without a harness yesterday, and that isn’t acceptable. He drones through the rest of the lesson and asks if anyone has any questions. There’s no response from the crew, so Joe Office grins again and tells everyone to stay safe as they shuffle off to the day’s tasks.

Words Mean Little
What Joe Office doesn’t realize is that nobody paid attention to anything he said. Oh, they heard him just fine, but Joe lost most of the crew members before he opened his mouth, and the rest tuned out within the first 30 seconds of hearing him speak. They pretended to listen while they thought about other things.

It’s true that Joe Office knows a lot about safety. Unfortunately, he has no clue what his body language projects and can’t read the body language of the workers with whom he’s communicating. As a result, in this scenario he wasted everyone’s time and had zero effect on the crew’s well-being.

The fact is that humans do far more listening with our eyes than we do with our ears. According to Mehrabian and Wiener, and Mehrabian and Ferris, when a verbal message is delivered, a typical human being only receives about 7 percent of the message via the words that are spoken. Thirty-eight percent of how a person receives a message is due to the way those words are delivered. And a full 55 percent of the message is conveyed through the speaker’s body language.

In other words, when a safety professional speaks to a group of workers, the nonverbal components of his or her message have a far greater impact on listeners than what’s actually being said. The professional’s physical appearance, body language, tone and pace of voice determine how carefully the workers will listen and how much they’ll retain.

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Dwight Miller

Equipotential Grounding: Lessons Learned in the Field

Equipotential Grounding: Lessons Learned in the Field

When the earliest linemen first began to ground lines for worker protection, they attached a small chain – known as a ground chain – to the conductors, with the end dropped to the ground. When I began to work on a line crew, I’m sad to say that my grounding practices weren’t much better than those used in the early days. I wish someone had better explained to me then the situations that could arise, the ways grounding could protect me and the best methods to accomplish it. So, in an effort to help out other lineworkers in the electric utility industry, I want to share in the following pages some of the important aspects of grounding that I’ve learned throughout my career.

Worker Protection
Ever since enforcement of 29 CFR 1910.269 began in 1994, OSHA has required grounding practices that will protect employees in the event that the line or equipment on which they are working becomes re-energized. The equipotential zone, or EPZ, is made to do just that.

If you read paragraph 1910.269(n)(3), the preamble discussion and Appendix C to 1910.269, titled “Protection From Hazardous Differences in Electric Potential,” OSHA’s intent seems clear. To summarize, install temporary grounds and bonds at the worksite in such a manner that keeps the worksite at the same potential and prevents harm to workers even if the line is accidentally re-energized or exposed to induced voltages. You can follow Appendix C as a one-size-fits-all approach or perform your own engineering analysis to create procedures. But keep in mind that if you create your own procedures, you must be able to demonstrate they will protect your workers.

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Dr. Andrew Murro, DC, DABCO

Understanding and Preventing Lower Back Pain in the Electric Utility Industry

Understanding and Preventing Lower Back Pain in the Electric Utility Industry

“I don’t know what I did to cause this injury, Doc. I’ve had lower back pain on and off for the past five years, but it’s never been like this before. All I did was reach under the boom for a roll of cable on the truck when I felt something give in my back and then felt shooting pain down both legs. What the heck happened?”

This is not an unusual story. When I used to practice as a chiropractic orthopedist, I heard similar accounts on a daily basis. Lower back pain affects utility workers in epidemic proportions. In 2004, my company surveyed 224 employees of a public electric utility, and the results revealed that more than one of every five lineworkers reported living with moderate to severe lower back pain on a weekly or daily basis. There are valid reasons why most lineworkers believe that lower back pain is just a consequence of the work they do, but the good news is that it doesn’t have to be that way.

The Mechanics of Back Pain
Most lower back pain is mechanical in nature, meaning it does not come from cancers, other diseases or infections. But it doesn’t necessarily come from performing physical work either. All physical work causes some daily microscopic wear and tear of your body, and the more a job requires you to do physically, the more wear and tear will occur. Before you start looking for another job, however, remember that your body is fully capable of repairing the vast majority of the wear and tear that occurs from demanding physical work. The painful conditions that most lineworkers experience in their careers occur because the balance between the amount of damage done each day and the repair that occurs each day gets thrown out of whack. How you position and move your body as you perform work dramatically affects how much wear and tear you sustain each day. Habitually working with stressful techniques can cause more microscopic damage on a daily basis than your body is capable of repairing. If it is not repaired, this microscopic damage accumulates over time and eventually causes painful conditions. “Cumulative trauma” is the name given to this slow accumulation of microscopic damage. As cumulative trauma increases over the years, the end results commonly are painful conditions, serious injuries and degenerative arthritis.

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Hugh Hoagland and Stacy Klausing, M.S.

Maximizing Your Arc-Rated Gear

Maximizing Your Arc-Rated Gear

When designing your PPE program, how do you know which option will work best for your application? How can you get the most for your money? How can you get no-cheating compliance from your workers? With so many arc-rated (AR) and flame-resistant (FR) PPE products on the market, it can be difficult for a utility or utility contractor to make a sound decision. To start, complete an analysis to determine hazard levels, as well as the workers who will be exposed. Application, comfort and cost should be considered when deciding on the best product to purchase. In this article, we will help you see how to maximize your AR and FR gear. The process begins with making a choice that makes sense for your company and your application, and then you will need to know how to care for the PPE so you can get the most from your money and extend the equipment’s lifespan.

Application and Comfort
While there have long been arguments and marketing claims about the superiority of either treated or inherent fibers used for FR and AR clothing, the truth is that both can work well from a protection standpoint, and both have a place in the market. Determining which one to use depends on the application and properties the end user needs.

For instance, aramids are durable and can work well with exposure to certain acids and bases – as an example, para-aramid is sensitive to chlorine bleach, mineral acids and UV, but these do not affect its flame resistance – yet pure aramids do not work well with regard to molten metal hazards because molten metal sticks to the fabric. However, there are several aramid blends that work well with molten metal. Modacrylics are great for chemical resistance, but the fiber has a high amount of shrinkage in a thermal exposure and doesn’t pass some of the small-scale tests for flash fire unless blended. Cottons and a similar, regenerated cellulose FR fiber known as FR rayon are breathable, soft and relatively inexpensive, yet they do not perform well in acid exposures. They also have fair colorfastness, meaning that their colors can fade with exposure to light and laundering.

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