Train the Trainer 101 Archive

Employers in our industry must have policies and procedures in place that align with OSHA’s qualified worker requirements. Each employer also must be able to defend its interpretation of those requirements. Many can’t do it. This is something I come across in almost every OSHA and civil litigation case I work on. Whether it’s General Industry (29 CFR 1910.269) or Construction (1926 Subpart V), the requirements are the same. If an employer assumes a journeyman’s ticket is proof of qualification, they have made a mistake. The employer’s duty is not met by third-party certification alone under the employee qualifications standard. In 2018, OSHA issued a final rule – “Cranes and Derricks in Construction: Operator Qualification” – that includ…

I perform audits of both utilities and contractors. When I work with them to do those audits, we include trucks and trailers. The trailers I’m talking about here are not the box vans behind tractors, but the general-duty trailers used to haul trenchers, backhoes, wire reels and padmount transformers. It’s no surprise that the trailer issues we discover are in keeping with the types and frequencies of violations that enforcement officials find on the roadways: those involving lights, load securement and brakes. Auditors also get a lot of questions about trailer safety, or more specifically, trailer rules, which are in place for trailer safety. I almost always receive those questions after an enforcement action has occurred. Many enforceme…

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…

This isn’t the first time – and I suspect it won’t be the last time – that I have addressed the question of what work can be done under the digger derrick exemption found in OSHA’s Cranes and Derricks in Construction standard (29 CFR 1926 Subpart CC). The issue has come up constantly since the matter of the digger derrick exemption was resolved, and just recently I once again received considerable pushback to an answer I provided on the topic for Incident Prevention magazine’s Q&A section. Before we go any further, I want to define some terms I will use in this article for brevity’s sake. “Subpart CC” or “CC” refers to OSHA’s Cranes and Derricks in Construction standard. “CDAC” refers to the rulemaking committee that established the …

Discipline is one of the many things that have served our industry well. Decades before OSHA was established by the Williams-Steiger Occupational Safety and Health Act of 1970, our industry already had disciplined procedures for switching, controlling and tagging circuits. When OSHA began to establish rules for the power-line industry, they recognized the superior discipline that utilities had employed in the control of hazardous energy and wrote into the standards those procedures that were being generally applied across the industry. Readers can find OSHA’s hazardous energy control (i.e., lockout/tagout) procedures for generation facilities in 29 CFR 1910.269(d). In 1910.269(d)(1), OSHA explains that the standard is for the control of …

Author’s note to readers: Be careful not to judge this article before you finish reading it. Even some members of Incident Prevention’s editorial advisory board were concerned the wrong message might be sent. I don’t think so. We have a great history of training and a lot of good trainers in the college-operated programs, the for-profit training centers, the apprentice yards and on the job. But there are issues with some of our training as evidenced by what we see on social media. We must start the conversation to honestly confront these issues, and maybe that begins here. You are invited to let me know what you think. I have recently been critical of what I have labeled “TikTok linemen.” The criticism was based on what I was seeing on s…

When I think about safety signs, the first thing I hear in my head is the hit 1970s song “Signs” by Five Man Electrical Band, particularly the part that goes, “Sign, sign, everywhere a sign, blockin’ out the scenery, breakin’ my mind.” In our industry, we have a lot of signs, and the truth is that few of them are useful. What is it about signs that helps us, and what is it about signs that hurts us? Part of my full-time job involves providing expert witness litigation support, so I frequently discuss and relate aspects of the courtroom experience here in these pages. That’s because the purpose of this column is to inform readers in practical language about the realities of safety compliance. And signs have a big role in safety that is ve…

At NASCAR’s Talladega, Pocono and Daytona superspeedways, there is always talk of the “Big One.” The Big One is a wreck that frequently characterizes those three-hour, 200-mph, 42-car races on a three-lane-wide oval. Of course, there have been superspeedway races where the Big One didn’t happen. Numerous racing organizations go years without getting caught up in a superspeedway Big One. Sometimes it’s attributed to luck. Other times it’s chalked up to preparation, planning and skill. When the Big One does happen, it’s usually because somebody messed up. Sometimes the person who messed up takes out lots of other people who weren’t messing up. They were just out there doing their jobs. Whether you are a racing fan or not, you probably alre…

I have been warning my clients to prepare for an expensive high-reach, non-insulating platform compliance issue, and that time is very near, if not already here. The issue is the use of pin-on man baskets for cranes. For quite a few years, it has been illegal to use a crane to hoist personnel with a few exceptions. The most recent OSHA prohibition is found at 29 CFR 1926.1431(a), which begins by stating, “The use of equipment to hoist employees is prohibited …” As I mentioned, there are exceptions. Specifically, 1926.1431(a) goes on to state, “… except where the employer demonstrates that the erection, use, and dismantling of conventional means of reaching the work area, such as a personnel hoist, ladder, stairway, aerial lift, elevatin…

Last year, Incident Prevention published an article by Altec’s Phil Doud regarding changes to the ANSI A92.2 standard regarding vehicle-mounted elevating and rotating aerial devices (see https://incident-prevention.com/blog/ansi-a92-2-2022-changes-and-training-requirements/). It is a good and timely article. In it, Mr. Doud points out that many of the training requirements in the revised 2021 edition of the standard were already expected, but the standard now captures in detail the type and content of training for aerial lift operators and supervisors of those operators. It is time for such detailed language to be published because we have a real problem with unqualified users operating aerial lifts, especially in energized distribution …

Throughout all of industry, all-terrain vehicles (ATVs) and utility task vehicles (UTVs) are involved in the majority of off-highway vehicle (OHV) incidents that result in injury. It’s not much different in the utility industry. While there is no official mechanism for counting or comparing vehicle class versus incidents, surveys and experience seem to indicate that of the vehicle classes used in our industry, ATVs and UTVs used in construction account for a high incident and injury rate. I have run safety at three large utility-related entities, and this awareness of the high incidence of ATV/UTV accidents among OHVs – which include pickup trucks, crew trucks, digger derricks and bucket trucks – struck me some 15 years ago.

When you say you are opening a can of worms, you are warning people that you are about to discuss something that could be very controversial or lead to more problems. And that’s exactly what I’m about to do.

There are rules in our industry. We, as utility or utility contractor employers, must follow the rules for two reasons. The first reason is that, if we don’t follow the rules, we get into trouble with the regulatory authorities. The second and more important reason is that the rules are in place to protect employees from injury or death. So it is with confined spaces. Confined spaces can and have killed workers. Confined space is a confusing issue among many of our colleagues and one I get questions about all the time. In fact, a recent inquiry about confined spaces in wind generation spurred this article. We will first look at the classification of the spaces we work in so that you start from the right perspective as you try to comply w…

Question: How many traffic cones does it take to stop a speeding car? Yes, the barriers we use are flimsy, and a traffic cone will not stop an errant vehicle from driving into a work zone. But there are some tweaks we can make to the equipment we use that will improve the level of protection workers on the street can get out of the resources available. Yet even with all our preparations, there is always a worst-case event dramatized by a recent news photo of an errant car, upside down on a bucket truck that was on a right-of-way well off the highway. It is the reason that OSHA and other regulating authorities expect employers to train all employees, specially train supervisory employees and provide the equipment necessary to protect work…

The topic of step and touch potentials is controversial, which is precisely why we need to discuss it. In my role as a work methods auditor and consultant, I see more variations in how employers address step potential than in any other aspect of equipotential bonding. I know the reasons for this and will address them here. But first, I need to clearly state the following: The theoretical argument for hazardous step potential in electric utility work environments clearly exists. Every employer must assess the hazards of step potential in their work environments and adopt a plan to protect exposed workers. Every employer must train their employees to recognize step potential hazards and employ the procedures necessary to protect workers f…

You might be surprised how a little thing like a safety sign can turn out to be one of your company’s biggest financial losses of the year. Over the last decade, I’m aware of three clients who lost big because a sign they put up was the wrong color, the print was imprecise, or the employer didn’t have a sign policy or effective safety sign training. Let’s start with having a sign policy. When helping to develop any policy, I always tell clients that the policy you write is only as good as the training you provide when you roll it out. For instance, if I were to research signs in preparation for a sign policy, I would likely start with the ANSI Z535 safety sign standard. That is where you find the results of the research and testing perfo…

Pandemic preparation is nothing new. In fact, I have been telling employers since the 1980s that a pandemic plan is one of the business/safety mechanisms they should have in place. It’s just good practice to address and interrupt a contagion that could potentially immobilize the employer’s workforce. The United States has been researching pandemic responses since a swine flu outbreak in 1976, but few if any publications back then addressed workforce contagions. The earliest literature on organized pandemic responses appeared around 1976 when the U.S. government established formal research panels to develop a nationwide response to a pandemic threat. The panels performed research and modeling activities and revised and expanded both resea…

There is an adage applied to seemingly insurmountable jobs: “How do you eat an elephant? One bite at a time.” Of course, being quite literal, my first thought after hearing the adage for the first time was, “Won’t it spoil before you finish?” And that’s the problem with safety management. There’s too much to do and too few people to do it. One way you are assured to fail is to try to do everything at once. Even a plethora of half-measures do not create sustainable change. Change comes from using a methodical approach to solving problems. If you are one of those overworked safety professionals, stop! You can’t do it all. You must figure out how to apply available resources to the challenge you have, and you start that process with an audi…

But first, this public service announcement. Summer is here, and if your organization doesn’t already have a policy on energy drinks, you should do the research and develop one. I had long been skeptical of energy drinks because I know that anything that artificially enhances body function always comes with consequences, especially if it’s overused. It’s no different than any prescription drug that supplants the body’s failed functions. There are always side effects. With heat stress or any other kind of stress, the body gets tired, which is how it tells you that it’s exhausted and needs rest to repair itself. If we artificially stimulate the body to ignore those signals, the outcome is not just bad – it can and has become deadly. In the…