Safety By Design: Implementation and Operation

The first four articles in this six-part series outlined the significance of an organizational safety management system (SMS) that involves all employees. They emphasized effective risk mitigation through a well-developed plan for continuous improvement, with a focus on human and organizational performance.

This article highlights critical operational processes that must be thoroughly assessed and refined to support organizational safety. Every operational unit must take proactive ownership of its safety protocols and practices, actively integrating safety measures into all aspects of its operational processes. By integrating safety into daily routines, each unit fosters a culture of responsibility and prioritizes employee safety.

This article also highlights key aspects from my experience in the electric power industry. We will follow the framework provided by ANSI/ASSP Z10-2019, “Occupational Health and Safety Management Systems,” which addresses the following areas relative to implementation and operation:

• Operational planning and control
• Identification of operational issues
• Operational risk assessment
• Change management
• Operational process verification
• Procurement
• Contractors
• Emergency preparedness

I encourage readers to consider topics not covered in this article – including operational process verification and emergency preparedness – to obtain a more comprehensive understanding of the principles associated with the Z10 standard.

Operational Planning and Control
This section of the standard emphasizes a crucial aspect of how organizations equip their employees for success.

Rules and procedures. Let’s begin by discussing the implementation of rules and procedures in the workplace. As a consultant, I have consistently encountered missing or ineffective procedures and/or rules during organizational safety assessments. Safety rules that reference OSHA regulations hold little value if there are no clear procedures defining what is expected to comply with those rules. One example is stating in the safety manual that equipotential zone grounding is required without clearly explaining how to achieve it within all aspects of work. Rules and procedures must provide clear directions so that employees know what is expected of them and can successfully comply.

Competency. Ensuring the competency of employees plays an extremely important role in an effective SMS. An employee isn’t necessarily competent just because they attended school or received specific training. Competency is based on the employee’s ability to demonstrate a specific skill on a regular basis, using all required safety procedures in response to identified hazards. I purposely included “regular basis” in the previous sentence because some employees can pass written and practical tests immediately after training but struggle when performing those tasks later in the field.

Additionally, competency should never be solely based on field experience and time on the job. Although both are important factors, they must be paired with a structured method to ensure employee competency through the demonstration of proficiency. It is crucial to remember that this principle also applies when organizations promote employees to leadership positions. Seniority should never be the only reason to promote someone who will be responsible for safely leading others.

Maintenance and inspection programs. These programs are essential SMS components that should encompass electrical and mechanical equipment as well as other critical systems that require regular maintenance to ensure safety. National codes, such as the National Electrical Safety Code and the National Electrical Code, emphasize the importance of electrical equipment maintenance for both employee safety and system reliability. Many organizations adhere to manufacturer recommendations for maintenance; however, some have neglected inspections and maintenance for years. When equipment and systems are not adequately cared for, the risk of hazards significantly increases, potentially impacting employees’ ability to work safely. I believe that strong maintenance and inspection programs are imperative for an organization to achieve safety success.

Identification of Operational Issues
The main directive of this section of the Z10 standard is to evaluate whether the organization has (1) conducted a thorough assessment of its work processes and (2) adopted improved methods, tools, equipment, installations, designs and technologies suitable for today’s workforce. As an industry consultant, I believe electric power organizations must stay informed about and adaptable to innovations that can enhance workplace safety and efficiency.

An example I recently encountered involved employees working in a remote area with no access to radio or cellphone service. This is a serious operational issue, even if some workers view it as normal. Should an electrical contact or other serious injury occur, the affected employees would have little chance of receiving life-sustaining support. I consider this unacceptable. Known communication challenges require immediate operational evaluation and improvement based on available tools, equipment, rescue supplies and technology.

Numerous organizations fall into the trap of accepting the status quo without questioning it, adopting a mentality of “this is the way it is.” This mindset fails to recognize the critical nature of regularly evaluating and improving the methods and practices that support employees, thus risking serious operational upsets. Organizational leaders should actively seek to identify areas for improvement, implement innovative strategies and foster an environment in which employees know their feedback is valued.

Operational Risk Assessment
Here is something else that leaders must consider: Have each of the organization’s operational units taken the necessary steps to identify high-risk jobs by asking, “What are the worst things that could happen on our worksites?” Let’s be honest: While many operational leaders acknowledge this concept, their discussions sometimes overlook employee safety. Earlier in this series, I explored the distinction between planned work and actual work. These two activities represent distinct realities in the workplace. Frequently, operational processes and discussions focus on how work is theoretically done, neglecting the actual execution by field employees.

According to the Z10 standard, an operational risk assessment should consider organizational factors that can increase risk, such as production pressures, poor communication and lack of resources. Here is a possible scenario: A contractor has been hired to build a new substation for a utility. While on-site, the contractor receives a request for emergent work: replacing equipment in an energized substation located within 5 miles of the existing work. Should the contractor dispatch additional personnel with the necessary expertise to work in an energized substation, or should they assign the project to existing staff with limited experience in that environment?

If this were a real scenario, many decisions would influence the answer. They are frequently made based on the project’s financial aspects for both the utility and the contractor, rather than the risks involved. Such situations often stem from a widespread culture of risk acceptance that overlooks the potential negative consequences of these decisions.

Change Management
Has your organization recently implemented a new work method or safety rule that has created confusion among employees, causing them to revert to previous practices? This is common in organizations that lack a structured strategy to effectively communicate and manage change.

Operational units often communicate change during safety or operational meetings. Consider, for example, an organization that purchases a new distribution line recloser. The recloser is introduced during a safety meeting, where its basic functions and safety requirements are explained. Several days later, employees are tasked with troubleshooting an area where the new recloser is located, despite having little knowledge about its design, installation or operation. While changes are commonly introduced at safety meetings, my professional experience suggests that they are only effective when paired with employee skills training and proficiency demonstrations based on specific task requirements.

After identifying significant opportunities to enhance their change-management processes, many large organizations have appointed personnel explicitly tasked with addressing them. Regardless of whether your organization has such specialized personnel, it is essential to clearly understand how change is identified, assessed and managed. This includes recognizing the potential impact of change on various operational units and ensuring that all team members are prepared to adapt. Effective management reduces resistance to change while also fostering safety culture growth within the organization. By actively involving all stakeholders and clearly communicating the reasons for change, organizations can more smoothly integrate new practices and policies.

Procurement
Does your organization effectively incorporate procurement into its safety and risk management planning? To illustrate procurement’s critical role, let’s continue examining the line recloser example provided above. In that scenario, the procurement department identifies a new line recloser that has been successfully adopted by several other utilities, as communicated by the sales team. The purchasing team decides to acquire 25 units for evaluation, aiming to determine whether the reclosers will perform as promised and enhance operational efficiency.

However, a significant oversight occurs: no risk assessment is conducted prior to the acquisition, and there is no clear strategy to integrate the new devices into the organization’s existing operational framework. This could lead to implementation challenges, particularly if the new technology does not align with current processes or safety protocols.

Scenarios like this one are common in organizations that fail to involve their procurement department in operational risk assessments and safety planning. This lack of collaboration can result in the purchase of new equipment that does not meet safety standards or operational needs, ultimately leading to unnecessary risks and complications in the field. To ensure a safer, more efficient operational environment, it is vital to implement a comprehensive approach that includes procurement in these discussions.

Contractors
It is also essential for utility organizations and contractors to establish a comprehensive safety management standard that effectively addresses the unique safety requirements of contractors, tailored to their respective risks. The Z10 standard emphasizes the necessity of developing a systematic approach to identify, assess and mitigate potential safety and health risks associated with contract work. This process enhances safety performance and fosters a proactive organizational safety culture.

When engaging contractors, electric power organizations have historically adopted a somewhat hands-off approach. This traditional method typically involves evaluating incident rates, confirming insurance limits and mandating adherence to OSHA standards. However, my experience indicates that these measures alone are insufficient to effectively mitigate the risks a host organization may face, particularly in the event of a catastrophe.

To address this, it is imperative to move beyond basic compliance. Organizations should conduct thorough prequalification processes, including assessing a contractor’s safety management system, past safety performance and safety training practices. Additionally, implementing regular safety audits and ongoing performance evaluations can help organizations ensure that contractors maintain high safety standards throughout the contract’s duration. Engaging in open communication and collaboration with contractors regarding safety expectations can lead to a deeper understanding of risks and the shared responsibility for safety outcomes. By adopting a more integrated and rigorous approach to contractor safety management, utility organizations can significantly enhance their ability to safeguard their employees and the public from potential hazards.

Summary
This article emphasizes the importance of thoroughly assessing and refining critical operational processes to embed and support safety within utility organizations. It highlights the ANSI/ASSP Z10-2019 standard as a framework for implementing an effective SMS, focusing on areas such as operational planning, operational risk assessment, change management, procurement and contractor oversight. By fully integrating safety into all aspects of operations and fostering a culture of accountability, organizations can better protect their workforce and improve system reliability.

About the Author: Pam Tompkins, CUSP, CSP, is president and CEO of SET Solutions LLC. She is a 40-year veteran of the electric utility industry, a founding member of the Utility Safety & Ops Leadership Network and past chair of the USOLN executive board. Tompkins worked in the utility industry for over 20 years and has provided electric power safety consulting for the last 25 years. An OSHA-authorized instructor, she has supported utilities, contractors and other organizations operating electric power systems in designing and maintaining safety improvement methods and strategies for organizational excellence.