Passing the CUSP Exam

The Utility Safety & Ops Leadership Network’s Certified Utility Safety Professional exam is like no other in the safety industry. There is strict criteria an individual must meet to sit for the exam, and the exam itself is challenging, but for good reason. From the beginning, members of the USOLN exam development team challenged ourselves to create a valid process to identify the skills a utility safety professional should have, and then to establish a process to validate those skills. The culmination of these processes is the CUSP credential – a reliable means for employers to identify safety professionals with the skills required to be capable safety leaders and reliable workplace safety resources.

In our testing, we certify competency of the individual as a safety professional. Unlike a classroom test, exam questions are not based on a month of academic review during which all test candidates sit through the same learning process. Rather, CUSP candidates come from a variety of backgrounds. Some have academic professional backgrounds and others have the benefit of particular training. Most have come up through the craft ranks and are mentored into safety professionals by a variety of sources. We must test them all in a way that fairly certifies the elements of competency, taking into account that not all of them have been trained the same way. As to the rules, it is well recognized in the industry that a person who can memorize the OSHA manual does not necessarily make a capable safety professional; what makes a good safety professional is the ability to analyze a situation and respond accordingly. The response is based on conventional safety practices driven by, if not detailed by, the relative consensus standards, or in accordance with either horizontal (applying to all employers) or vertical (applying only to certain types of employers) outcome-based standards.

In the workplace, a competent safety person should be able to examine a condition and make an effective judgment as a result of their knowledge and experience. In the CUSP exam, we mimic that same competency. Our testing seeks to determine if a candidate has the relevant experience and requisite knowledge to administer safety in a competent way. We accomplish this by carefully constructing test questions designed to demonstrate that a CUSP candidate, faced with challenges from a variety of safety-related topics, can examine a question and, from their experience and understanding of the issues and knowledge of the principles of safety, correctly determine the best answer.

We routinely analyze the testing outcomes. There are no names associated with the analyzed data, just comparisons of correct and incorrect answers. In doing so, we have discovered that there are commonly missed topical areas. Not surprisingly, the data confirms something we have recognized and that professional accrediting associations know – a static environment can atrophy unexercised parts of a whole.

Another finding common among larger organizations with several CUSPs in their workforce is that they all miss the same questions, and they are frequently questions that the majority of the other 450 candidates correctly answered. Because the security of the exams and the monitoring of the exam procedure ensure there is no collaboration among candidates taking the exam, what this demonstrates is that CUSP candidates who work for the same employer have the same lack of familiarity in the inquiry area.

What Gets Missed
Following are several specific areas that CUSP candidates routinely have difficulty with:

Consensus Standards
Our analysis shows that a large number of candidates don’t spend time reading the consensus standards, which are listed by OSHA in 29 CFR 1910.6. Why are consensus standards important? As OSHA states in 1910.6(a)(1), provisions of the consensus standards containing the word “shall” or other mandatory language of standards incorporated by reference are adopted as standards under the Occupational Safety and Health Act. In other words, some parts of the consensus standards are official rules, while other parts, OSHA explains, are useful for the helping the employer comply with the requirements of the standards. In addition, the consensus standards contain requirements that OSHA uses to determine evidence of hazards and as guides to hazard remediation – the necessary elements of a General Duty Clause violation. There are approximately 35 consensus standards and CPLs every safety professional should own; please see the sidebar below for a complete list.

Reporting Requirements
In an unscientific survey conducted over the years, it’s been found that candidates who directly work for utilities are more likely than contractor candidates to miss questions regarding 29 CFR 1904, “Recording and Reporting Occupational Injuries and Illness.” If we ask a room filled with contractors five questions about recordable criteria, they will almost all get the answers right. If we ask the same questions of a room filled with utility employees, they, for the most part, will get the answers wrong. The likely reason is that contractors with high recordable rates won’t qualify to bid on work. As a result, contractor company management reinforces the importance of post-incident illness and injury management to their supervisory team and employees so they become more familiar with the fundamentals of the 1904 standard. Utility statistics are primarily recorded administratively, with very little push of the statistics to the workforce. Few utilities train their workforce in the management of illness and injuries under the 1904 standard.

29 CFR 1910.269 and 1926 Subpart V
Colloquially known as “.269 and Subpart V,” these two standards are specific to the utility industry and the basis for company safety standards and transmission and distribution rules. Questions on the CUSP exam about the standards mostly focus on the standards themselves or are limited to generalities regarding the most fundamental elements of the standards, yet they are the questions most frequently missed. For instance, many candidates miss questions about the application of Subpart V compared to the application of 1910.269. Other commonly missed areas are criteria for PPE, training requirements, certification by employers, the crane standards, and training and criteria for the use of powered industrial trucks. The questions are not obscure or tricky. Instead, they are very common aspects of everyday hazards confronted in every workplace. This corresponds to the experience of consultants associated with Incident Prevention: During meetings, policy development and training, consultants learn that many safety representatives are familiar with their own safety manuals, but have never read the 64-page 1910.269 or the 14-page 1926 Subpart V standard.

Though extreme, following is an example of a very common error made by many simply because they are unfamiliar with 1910.269: Most readers would agree that grounding a truck will not protect a person touching the truck or even standing next to it if it contacts an energized line. In addition, most readers would not know that OSHA mandates in 1910.269(p)(4)(iii)(C)(1) through (C)(4) the use of equipotential mats and barricades around all grounded trucks. That’s been the rule since 1994, but we consistently run into safety personnel who are not aware that this is so.

As we have reviewed employer safety manuals, we are aware that most manuals evolve and are modified numerous times. Some exceed the requirements of the standard, and some fail to meet the requirements. The CUSP exam tests on the standard. Candidates whose regulatory expertise is bound to their company safety manual will have difficulty with standards on the CUSP exam.

Bonding and Grounding
Temporary grounding creates risks that injure as many lineworkers as any other industry-specific risk, if not more. The purpose of grounding is to cause immediate operation of a circuit protective device, and the purpose of bonding is to electrically connect conductive surfaces to prevent difference in potential that can injure an exposed employee. These are fundamental principles for temporary protective grounding that seem to be an issue for many who take the CUSP exam. The exam questions about temporary grounding are based on grounding/bonding differences and the general rules regarding placement during stringing, clipping and grounding of equipment, and current flow in grounded systems. These are issues the industry has struggled with for 100 years, but now we are finally getting a grip on the practices and principles thanks to the work and training done by safety professionals. On many occasions during review and after the exam, we have learned that longtime company policies or procedures do not meet the expectations of grounding rules or are outdated practices that don’t recognize the above-referenced principles. Again, as with the other frequently troublesome areas, becoming familiar with the regulatory and consensus standards relating to temporary grounding practices will not only improve your workplace procedures, it will help you pass the CUSP exam.

Composition of Questions
The exam is composed mostly of multiple choice questions with two, three or four possible answers. For the purposes of this discussion, we will assume there are three answers to a question. Of the possible answers, one of the three is clearly correct in relation to the question to the exclusion of all other possible answers. Typically, of the other possible answers, one is almost correct in relation to the question, but made invalid by some condition established in the question. The third answer may be entirely incorrect or almost correct, containing an error or being conditionally correct, but invalidated because of the conditions stated in the question. Multiple almost-correct answers, invalidated by conditional clauses in the questions, add rigor to the process. These are not tricks. Candidates should carefully review each question and try not to read anything into it. The questions and answers are precise, and are designed to challenge the candidate so they have to consider both for a moment. This is what safety professionals do every day. When given a problem, the safety professional defines the parameters of the issue and then, using their experience and expertise and based upon the fundamentals of rules of practice, makes a judgment as to the correct solution. For 78 percent of CUSP candidates, taking and passing the exam is as simple as that.

When you take your exam, you may find the percentage of those who have passed has increased. Rest assured that if that is so, it’s not because the test has gotten easier – it’s because the candidates have gotten smarter.

Good luck, and the USOLN looks forward to welcoming you to the ranks of the utility safety elite.

About the Author: After 25 years as a transmission distribution lineman and foreman, Jim Vaughn has devoted the last 15 years to safety and training. A noted author, trainer and lecturer, he is director of safety for Atkinson Power. He can be reached at jim.vaughn@atkn.com.

Consensus Standards and CPLs
Here are just a few of the most useful consensus standards and OSHA CPLs for safety professionals in the utility transmission and distribution industry. Safety professionals with other areas of responsibility, such as in the power plant gas or CCTV/outside plant industry, will find guidance references on many subjects in 29 CFR 1910.6, the general industry standard. When purchasing standards, be sure to buy the latest revision. The revision date generally follows the standard number. Revisions for different standards are not always completed at scheduled intervals; many are revised at different intervals as need requires.
• ANSI/ISEA 107, American National Standard for High-Visibility Safety Apparel and Headwear
• ANSI Z535.2, Environmental and Facility Safety Signs
• ANSI B30.5, Mobile and Locomotive Cranes
• ANSI Z87.1, Occupational and Educational Personal Eye and Face Protection Devices
• ANSI Z89.1, Industrial Head Protection
• ANSI Z359.1, Safety Requirements for Personal Fall Arrest Systems, Subsystems and Components
• ANSI Z359.13, Personal Energy Absorbers and Energy Absorbing Lanyards
• ANSI Z359.14, Self-Retracting Devices for Personal Fall Arrest and Rescue Systems
• ANSI A11.1, Practice for Industrial Lighting
• ANSI A92.2, Vehicle-Mounted Elevating and Rotating Aerial Devices
• ANSI B56.1, Powered Industrial Trucks
• ANSI Z41, Personal Protection – Protective Footwear
• ANSI A90.1, Safety Standard for Belt Manlifts
• ANSI B175.1, Outdoor Power Equipment – Internal Combustion Engine-Powered Hand-Held Chain Saws – Safety and Environmental Requirements
• ANSI J6.4, Rubber Insulating Blankets
• ANSI J6.6, Rubber Insulating Gloves
• ANSI Z4.1, Sanitation – In Places of Employment – Minimum Requirements
• ANSI Z9.2, Fundamentals Governing the Design & Operation of Local Exhaust Ventilation Systems
• IEEE 516, Guide for Maintenance Methods on Energized Power Lines
• IEEE 524, Guide to the Installation of Overhead Transmission Line Conductors
• IEEE 978, Guide for In-Service Maintenance and Electrical Testing of Live-Line Tools
• IEEE 1048, Guide for Protective Grounding of Power Lines
• IEEE C2, National Electrical Safety Code
• NFPA 70E, Standard for Electrical Safety in the Workplace
• NFPA 10, Standard for Portable Fire Extinguishers
• NFPA 101, Life Safety Code
• ASTM F496, Standard Specification for In-Service Care of Insulating Gloves and Sleeves
• ASTM F855, Standard Specifications for Temporary Protective Grounds to Be Used on De-energized Electric Power Lines and Equipment
• ASTM F887, Standard Specifications for Personal Climbing Equipment
• ASTM F1701, Standard Specification for Unused Rope with Special Electrical Properties
• OSHA CPL 02-01-038, Enforcement of the Electric Power Generation, Transmission, and Distribution Standard
• OSHA CPL 02-00-150, Field Operations Manual
• OSHA CPL 02-01-054, Inspection and Citation Guidance for Roadway and Highway Construction Work Zones
• OSHA CPL 02-01-050, Enforcement Guidance for Personal Protective Equipment in General Industry
• OSHA CPL 02-00-100, Application of the Permit-Required Confined Spaces Standards