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Don’t Leave Employees to Fill in the Blanks

Early in my marriage, my wife asked me to pick up some groceries on my way home. This task seemed easy enough; after all, I had been feeding myself for years. How hard could it be? We needed food and the grocery store had food for sale. The path to success appeared to be pretty well laid out. All I needed was a method of payment and a shopping cart with four functioning wheels.

As I negotiated my way up and down the aisles of the grocery store, I put great thought into what I added to my cart. I made sure to get the basics, including bread, milk and eggs, and I rounded out the cart with some other reasonable dining options. Mission accomplished – or so I thought. When I returned home and we began to unload bags full of bachelor staples, such as chicken wings and Cap’n Crunch, my wife came to realize that my future trips to the grocery store would require more specific guidance. It was clear that my idea of “mission accomplished” was vastly different from hers.

How did a task that seemed so simple go so wrong? Why was it that my wife’s job-specific expectations did not align with my understanding of how I should successfully complete the task? Was this misalignment a failure on my part or was poor communication to blame? When I was given every option in the grocery store to choose from, could my wife truly be upset when I filled in the blanks and chose the options that looked right to me?

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Soil Mechanics in the Excavation Environment

The February 2016 issue of Incident Prevention featured “Trenching by the Numbers” (see http://incident-prevention.com/ip-articles/trenching-by-the-numbers), the first installment in this series on advanced trenching and shoring principles. In that article, I reviewed the OSHA excavations standard found at 29 CFR 1926 Subpart P. The purpose of reviewing the rules was to give readers a starting point upon which to build more advanced concepts. In this article, I will continue the series with an in-depth discussion about the principles of soil mechanics.

Throughout the years I have worked in the utility industry, I have observed a systemic deficiency when it comes to training and educating the workforce about soil mechanics. This deficiency impacts nearly everyone, from employees in the field to civil engineers who design the work to be done. In practice, what I tend to see is training that begins with teaching enforceable standards and concludes with an overview of some methods for classifying soils. This is problematic because employers may end up with employees who merely understand how to classify soil in order to comply with a standard, instead of having comprehensive knowledge about how to harness the naturally occurring characteristics of soil to keep workers safe and make jobs run more smoothly.

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Field-Level Hazard Recognition Training That Works

As a safety professional or operations leader in your organization, one of your primary responsibilities is to ensure your employees can and do complete their work safely. People don’t want to get hurt and you don’t want them to. With that as a given, the question then becomes, how do you accomplish this? You can’t be everywhere watching everything all the time. You can’t point out every hazard on every job site for every worker. So, how do you rest easy in the belief that your employees are recognizing and mitigating hazards and working as safely as possible when you are not around?

I’m going to assume – not always a wise choice, but I’m comfortable with it in this case – that if you are reading this article, you have a system in place for conducting pre-job briefings to discuss the known and expected hazards on your jobs. That is standard procedure in the utility industry. And since many of the jobs utility workers perform each day are very similar, these job briefings can become mundane and lifeless. A briefing becomes a rote process that is almost copy-and-paste from work site to work site. The danger in this is the complacency it can breed. The examination of the job site and the communication and mutual discussion of the hazards present are meant to be the primary preparation for safely completing the assigned tasks. If the process becomes mundane, what are the chances that some of the hazards – especially ones that aren’t typical of the work – will go undiscovered until it’s too late?

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The Future of Ergonomics

Over the last decade, our industry has done a great job of reducing work-related injuries as a whole, but musculoskeletal disorders (MSDs) – also known as ergonomic injuries – are on the rise.

From 2008 to 2012, work-related injuries decreased steadily each year. During that same period, however, ergonomic injuries increased by approximately 15 percent, according to the U.S. Bureau of Labor Statistics.

As we know, OSHA sets standards and precise thresholds, such as those for vibration and noise exposure, in an effort to improve work site safety and prevent injuries. But there are no specific federal guidelines for ergonomics, and thus very few repercussions for employers if employees sustain ergonomic injuries, some of which can cause irreversible damage. According to a September 2015 article written by Jeff Sanford (see www.humantech.com/our-incidence-rate-is-down-so-why-are-our-msds-lingering), director and ergonomics engineer for Humantech, “OSHA can only fine your company for an ergonomics violation through the General Duty Clause (which is not specific to ergonomics).”

Sanford then goes on to say that “[m]any companies have a very good handle on lowering the risks associated with fatalities, amputations, and other life-altering injuries, but have not yet focused on eliminating MSD risk factors. The incidents associated with poor ergonomic design have always been on the OSHA log, they are just now rising to the top of your priority list with the decrease in safety-related incidents.”

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A few years ago I came upon a crew using 6-inch chocks to hold back a 38-ton crane truck. I told the crew I was happy that they were making an effort at compliance, but I had to ask them, “Why do we place chocks under a truck’s wheels? Is it to comply with our safety rules or to keep the crane from running away?” It was obvious to me that the short chocks would not hold the crane. The driver proved my assumption true a few minutes later. From the cab, with the transmission in neutral, he released the parking brake. The crane easily bounced over the chocks and, unfortunately, hit my pickup truck.

Sometimes I ask similar questions about grounds installed during stringing. That’s because it seems we do not pay as much attention to the value of grounding as we do to the perceived value of an act of compliance. Grounding during stringing plays a very important role in protecting workers; however, that’s only the case if we know why we are grounding and then install grounding so it does what we want it to do.

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OSHA fines will increase for the first time in 25 years under a provision in the recently signed U.S. congressional budget deal.

The Federal Civil Penalties Inflation Adjustment Act of 1990 exempted OSHA from increasing its penalties to keep pace with inflation. But a section of the new budget signed in November by President Barack Obama – referred to as the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 – strikes the 1990 exemption.

Now, OSHA is directed to issue an interim final rule adjusting its penalties to account for current inflation levels, which would raise proposed fines by about 80 percent. This means the maximum penalty for a willful violation would rise from the current $70,000 to about $127,000. Additionally, OSHA fines for serious and other-than-serious violations could increase from $7,000 per violation to approximately $13,000 per violation. The penalty adjustment must take effect before August 1 of this year. In subsequent years, employers should expect to see OSHA fines increase by January 15 of each year as the agency makes adjustments based on the annual percentage increase in the consumer price index.

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Q: What is an employer’s affirmative defense relative to an OSHA charge and how does it work?

A: In simplified legal terms, an affirmative defense is the act of an accused party putting forth a set of alternative claims or facts. The purpose of the accused party doing this is to mitigate the claim against him, or at least the consequences of the claim, even if the facts of the claim are true. Following is an example of a fairly common scenario in which an affirmative defense is claimed by an employer. OSHA investigates an incident that resulted in an injury to an employee and finds the employer responsible. The agency subsequently issues a citation for violation of a certain rule. Most successful affirmative defenses have shown that the employer’s safety manual rule would have protected the employee if the rule had been followed; that the rule was communicated to the workforce via training; that supervisors and employees were trained to comply with the rule; that supervisors enforced the rule; and that a disciplinary program effectively remediated noncompliance. If the employer successfully puts forth that defense, he can claim the employee violated the rule outside of the control of the employer. The employer showed due diligence and cannot be held responsible for a condition over which he had no control, such as employee misconduct.

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April 2016 Management Toolbox

Overcome Your Fear of Failure
Nearly everyone has been afraid of messing up on the job at some point in their career. Nervousness, anxiety and fear are common emotions, especially when so much may be at stake, including your professional reputation and livelihood. But while it’s normal to feel unsure from time to time, it becomes unhealthy when fear of failure paralyzes you, preventing you from moving forward and performing at your best.

Fortunately, there are ways to combat your fears. The first step is to identify exactly what it is that’s making you most afraid. Are you uncomfortable with how a particular project is going? Have you taken on a new role and don’t feel you have the skills to be successful? Figure out what’s truly bothering you and write it down, including the worst-case scenario. This might seem like a torturous exercise, but for many people, the simple written acknowledgement of their fears creates a sense of relief and helps to open up a path toward conquering what’s bothering them.

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Every person who reads this Tailgate Topic might have a slightly different idea of what drives a strong safety culture. But there is one thing every reader can likely agree upon: that all of a company’s employees have value and make valuable contributions to the organization, helping to create and maintain its safety culture.

Valuable contributions come in an infinite number of forms. In the utility industry, they go well beyond employees simply getting the work done accurately and on time. One example of a valuable contribution is a new written work procedure that helps to keep crews safer, is easily understood by employees and isn’t overly cumbersome to adopt. This contribution also is tangible; it can be disseminated via email, printed, used in training sessions and brought to work sites for easy reference.

Other contributions are less concrete. For instance, a caring attitude is highly valuable. If employees do not have a caring attitude that’s authentic, safety and good health can falter or even cease to exist in some cases.

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Utility workers are required to receive electrical safety training on a variety of topics, including grounding, switching and tagging, de-energizing, live-line work, pole-top rescue and job briefings. Unfortunately, there are some training topics – like how to properly secure loads on vehicles – that are not always given the attention they deserve. For instance, when I first passed my commercial driver’s license test 25 years ago, I had to undergo training on proper inspection of commercial vehicles, physical limitations, record keeping and proper driving techniques. Part of the training discussion was about securing the load on a commercial vehicle, but not much emphasis was placed on its importance. As you and I well know today, properly securing cargo is serious business, and a failure to follow the rules may result in injuries, death and jail time.

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Have you ever reflected on the moment when an accident or injury occurred? During that period of reflection, did you think about the decisions you made that may have played a part in the incident? A common thread I have discovered among many incidents is that we sometimes make the choice to proceed with a certain step in a process or activity despite the fact that we are unsure of exactly how to safely and correctly do so.

In retrospect, we know the step is one that we obviously should not have taken. It’s that simple. Instead of moving forward, we should have stopped and asked, am I really sure about what I am about to do? Do I fully understand what is going to happen when I perform this step?

Far too often, we find ourselves in a place of uncertainty and talk ourselves into going ahead with an action. Based on various root cause evaluations I have reviewed over the past several years, it has become more evident that we are creatures of habit who want to accomplish our tasks without failure. It has also become clear that many organizations have not provided enough resources to thwart this and related issues. The root cause of an incident is found to be human error and we leave it at that. But what about organizational weaknesses, such as failing to identify the need for more specific guidance or to provide stop-work criteria?

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Trenching by the Numbers

By and large, organizations directly provide the training and other resources needed for the development of their foremen and crew chiefs. Such training tends to be built around two components: following the standards set forth by OSHA and other regulatory agencies, and adhering to organizational policies and procedures.

This is a great approach but perhaps an incomplete one. Truly impactful safety training typically includes a third component: sharing of personal experience. For instance, I once observed a training session in which the instructor drew from his experiences during a discussion about how to troubleshoot problems that can likely be anticipated in the field. Often, this type of training is held in higher regard by trainees than that which simply outlines a standard. Furthermore, workers are more likely to become active participants in training sessions that highlight proven, real-world work practices that they can use to more safely and efficiently execute their tasks.

With this in mind, I began crafting a series of four articles that focus on trenching and excavation techniques and practices. My goal is to present advanced material – injected with my own on-the-job experiences as a safety director and instructor – to the seasoned foremen and crew chiefs who already have some practice working in and around trenching environments.

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The CUSP Program Expands to Canada

We are pleased to announce that the Utility Safety & Ops Leadership Network has developed a version of the Certified Utility Safety Professional program that directly serves utility workers employed in Canada. Starting this summer, individuals will have the opportunity to enroll in the two-day utility safety leadership review course and sit for either the CUSP Blue or CUSP Green exam.

The USOLN was founded in 2009 to advocate for a safe, productive utility work environment. In 2010 the organization offered the first CUSP program session in Denver. The program continues to be the only one of its kind that offers a utility safety-specific credential to professionals employed by utilities, contractors and communication providers. By earning the CUSP credential, employees help to assure their employers that they have the requisite knowledge, skills and abilities to safely and correctly execute their roles in the utility work environment. Not only that, those who earn and maintain the CUSP credential have access to a network of nearly 800 other safety professionals who have earned the designation.

As the CUSP program has evolved over the past seven years, there has been increased need and interest in bringing the program to Canada. Given the variation in occupational health, safety and utility regulations among the Canadian provinces, the focus of the new Canadian CUSP program is the development of industry best practices with due consideration given to the provincial internal responsibility systems. In the electric utility industry, safety is one of the greatest benefits derived from the use of best practices. Another benefit is that – unlike OSHA and other regulations – best practices offer a level of flexibility; they are continually changing as new information and technologies are brought to the table.

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Understanding Your Safety DNA

Last summer my extended family planned and hosted a long-overdue family reunion. This one was particularly special because my Uncle Roy, who is now in his 80s, was there, and it was the first time in many years that I had the opportunity to see and spend time with him. Prior to his retirement, Uncle Roy was a railroad engineer in charge of and responsible for driving a freight train engine. From a safety perspective, I should explain a few details about trains before I continue. First, a typical freight train can be 120 to 140 cars or approximately one-and-one-half miles in length. Second, if a train is traveling at a moderate speed of 55 mph, it will take more than one mile – or 18 football fields – before that train comes to a stop. And finally, a train can’t swerve to avoid an object in its path. The aforementioned facts should give you a clue as to where we are heading with this article.

After getting reacquainted with Uncle Roy at the reunion, I asked him to tell me about his days as a train engineer. His face lit up at the question, and he proceeded to tell me about his love for the railroad. Uncle Roy probably could have gone on for hours, but at a certain point – and I’m not entirely sure why I did this, except that I have spent quite a bit of time focused on safety efforts in diverse organizations – I asked him if he’d ever hit anything while driving a train. Uncle Roy’s demeanor changed as he described the multitude of times his train had hit objects on the tracks, including animals, chairs, coolers, camping equipment and even cars. In one instance, the driver of a car was clearly trying to get across the tracks as the train approached, even though the gates were down and the lights were flashing. Unfortunately, the driver was not successful in his attempt and another unnecessary fatality occurred that night.

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Best Practices for Arc-Rated Clothing Programs

Many things have changed since 1994, when the first hint of arc-rated (AR) materials hit the utilities. Back then, the best practice was to wear cotton jeans, heavy cotton shirts and heavy cotton-shell winter wear. Other personal protective equipment (PPE) like rainwear illustrated an industry problem: There were not many good flame-resistant (FR) clothing options available. At the time, the only markets for FR garments were military, aviation and refineries. Non-melting rainwear was not really on the market since most “FR” rainwear at that time was made of nylon or polyester, which means it melted and thus didn’t meet OSHA requirements.

In the years immediately following the promulgation of the 1994 version of OSHA’s 29 CFR 1910.269 standard, a few utilities began using AR shirts. However, in a 2001 IBEW survey, only 68 percent of utilities reported using AR shirts and rainwear. There was a false belief that cotton was somehow FR, but this was a misinterpretation of ASTM data provided to OSHA about heavy, 11-oz/yd² cotton. Any utility that had done calculations using ARCPRO – software that computes the thermal parameters of electrical arcs – knew it was basically impossible to justify not moving to AR garments given the available data. In the same IBEW survey, 70 percent of respondents reported using FR clothing – which was commonly used interchangeably with “AR clothing” at the time of the survey – as part of a uniform required by the company for which they worked. The tides were turning even then toward company-provided AR garments for line technicians.

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Auditing for Safety Improvement

The mere thought of participating in an audit can be unnerving. Consider IRS audits for a moment – they can never mean good news, right? So why would an organization want to spend time, money and other resources to conduct an audit when it could be painful? The answer is that, regardless of the feelings they evoke, audits – when done right – can be a powerful organizational improvement tool rather than just a way to monitor compliance.

To better understand the importance of auditing for improvement, let’s review an example of a traditional compliance audit. In this example, the audit identified a distribution underground crew whose members did not use insulating cover-up while working inside a single-phase underground transformer. The apparent cause of the violation seemed straightforward – the crew members had simply failed to use appropriate insulating cover-up, so management reviewed the violation and mandated the crew to follow the rules in the future.

The action taken by management in this example seems acceptable, but was it truly enough? Will the apparent cause of this violation be completely remedied through talk and discipline? Although rule compliance is extremely important, audits that focus solely on this type of compliance may neglect to identify major gaps that contribute to an ineffective safety system. What happens if a utility doesn’t have the right people in place to support safety? For instance, it’s possible that workers have not been properly trained and frontline leaders don’t know how to apply the rules on a job site. In the previous example, the crew may not have understood how to use insulating cover-up on underground applications as they were only trained for application of cover-up on overhead lines.

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Words have power. We confirm that every day when we examine why people do what they do. Communication is often the root cause of accidents, particularly how the receiver interprets what he or she hears. That communication is not always something said in the moments before an incident; it can occur days, weeks or months in advance. I have discussed this issue with behaviorists on a number of occasions, and I am convinced that some of the words I – and many others – have repeatedly heard over the years have served to limit our success in the quest for a strong, positive safety culture.

The real problem is that what we say to soften our approach and encourage safe work has the exact opposite effect of our intention. Many of us – and yes, I have done it, too – don't want to be criticized or worse when we ask crews to do something differently. Sometimes we think our request is going to sound accusatory or like an insult to their professional skill level. Other times we know from past experience that the issue that needs to be addressed is contentious. Maybe we worry that our message is going to be challenged, or perhaps we are not confident in our delivery. There are any number of reasons, but it boils down to this: Safety professionals are human, and humans don't want to be challenged or rejected. Therein, as they say, lies the problem.

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With the recent changes to the OSHA standard, many employers are working on what rules apply – the arc flash standard or the PPE standard – and how to comply with them. Part of the issue is determining how many types of protection are needed and what types of protection are appropriate.

To begin, OSHA’s requirements for all personal protective equipment can be found in 29 CFR 1910 Subpart I. Rules specific to hand protection can be found in 1910.138. They read as follows:

1910.138(a)
“General requirements. Employers shall select and require employees to use appropriate hand protection when employees' hands are exposed to hazards such as those from skin absorption of harmful substances; severe cuts or lacerations; severe abrasions; punctures; chemical burns; thermal burns; and harmful temperature extremes.”

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Q: I work for a small utility and am new to my safety role. Recently I have been wading through the Federal Motor Carrier Safety Regulations (FMCSR) in an attempt to understand my responsibilities with regard to testing CDL drivers. Can you briefly explain these responsibilities?

A: FMCSR 391.31 requires the employer to ensure a driver is competent by means of road testing. The FMCSR allows a valid commercial driver’s license as evidence of competency (see FMCSR 391.33). If the employer accepts the evidence of the driver’s competency, the employer does not have to road test the driver. Rule 391.33(c) allows the employer to conduct a road test if they so choose even if the driver has a current license and certificate of competency. If the employer intends for the driver to haul double or triple trailers, they are required to conduct a road test. The road test criteria are listed in FMCSR 391.31(c).

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February 2016 Management Toolbox

Help Your Employees Manage Stress
Stress is incredibly common in the workplace. During your years of employment, you’ve probably found yourself in a great number of stressful situations and thus discovered effective ways to manage your response to them. Now that you’re part of the management team, one of your responsibilities to your employees is to help them find healthy ways to cope with their own job-related stress and anxieties.

The first step to helping someone deal with a high level of stress is to recognize there’s an issue. Some on-the-job stress is normal, but if you’re in tune with your employees, you can usually tell when they’re not acting like themselves. They may be irritable or panicky, or their productivity rate may decrease. Essentially, if you notice that something just isn’t right, that’s the time to intervene.

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