Voice of Experience: Training for the Qualified Employee
Training is required by OSHA and all employees should follow proper training, but the unfortunate truth is that doesn’t always happen, resulting in accidents, contacts and fatalities. OSHA is very specific about defining what qualifies employees to work on and near energized conductors and equipment energized at greater than 50 volts. To be qualified to work on systems considered primary voltages greater than 600 volts, the mandated training is markedly more intense because of the requirements for such things as knowledge of component specialization, procedures such as insulate or isolate, and the personal protective measures and personal equipment used, among others. The ideal trainer is OSHA-authorized and intimately familiar with federal standards and expectations, and has industry experience as well as a broad knowledge of consensus standards and contemporary practices related to the topics being covered. Electric utility employees are a tough group, and they will be tough on an instructor who has no utility experience. Instructors should not deliver training material simply via PowerPoint presentations or similar delivery methods. Examples and accident histories should be incorporated into the training. Additionally, OSHA requires field observations in order for employees to prove their proficiency in the training subject. After training is complete and an employee has proven proficiency, the employer can state the employee is qualified for the task.
The Employer’s Responsibility
There is a difference between an initial safety orientation and training an employee in skills required for their job. The orientation is far less detailed and can be delivered to all utility employees for general safety. Regarding job-specific training, 29 CFR 1910.269(a)(2)(i) states, “Employees shall be trained in and familiar with the safety-related work practices, safety procedures, and other safety requirements in this section that pertain to their respective job assignments. Employees 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 their work and are necessary for their safety.” This may seem vague; what many people don’t understand is that OSHA will not state exactly what training is needed and required. The employer is tasked with deciding what training is necessary based on the tasks the company expects its employees to perform. Necessary training may include CPR, first aid, pole and bucket rescue, enclosed confined space rescue, arc hazard awareness and electrical safety.
Much of the training is defined by the classification of the worker, and the employer is responsible and accountable for ensuring all skills training and regulatory compliance training are provided to protect the employee. Utility workers are required to be able to recognize energized and exposed live parts. That may sound simple, but it’s not as easy as you think. Some people now being hired as utility workers don’t completely understand the training they’re receiving, and employers shouldn’t assume all employees understand all the training materials. For instance, “nominal system voltage” is a term not all lineworkers are accustomed to hearing. They are used to hearing the more common industry phrase “phase-to-phase voltage.” Employees may also struggle with learning about and fully understanding the minimum approach distance (MAD). Additionally, they must be taught to understand that any handheld conductive item, regardless of length, that may enter a MAD shall be considered energized. Employees must protect themselves from the hazards of their jobs.
Qualified Person Training
In 1910.269(a)(2)(ii)(D), it states that qualified employees shall be trained and competent in the “proper use of the special precautionary techniques, personal protective equipment, insulating and shielding materials, and insulated tools for working on or near exposed energized parts of electric equipment. Note: For the purposes of this section, a person must have this training in order to be considered a qualified person.”
The note included in 1910.269(a)(2)(ii)(D) indicates the need for a great deal of training and is sometimes ignored by employers when choosing the employee curriculum. Without completion of this training, proficiency demonstration and certification by the employer, the employee can’t be considered qualified. If the employee isn’t qualified, they don’t have the ability to be the second qualified employee when work on 600 volts or more is being performed, or when non-dielectric equipment such as a line truck or digger derrick may enter the MAD when work is taking place. A second qualified employee is required in both scenarios.
Another topic of consideration for employers is that training on all consensus standards – including ASTM, ANSI, MUTCD and NESC – associated with all performance standards requirements should be provided to employees to assure their understanding.
A Huge Investment
As you can see, training is a huge investment made by employers for each employee. I see many companies waiting too long before providing basic safety information to newly hired employees. They put the new employees in the field and risk both injury to the employee and regulatory violations by not providing prompt training. The question comes up often: How much time do I have to provide training to the new employee? I asked this question to a senior assistant compliance officer in my region who answered, “Before the employee gets hurt or the company exposes the employee to an unrecognized hazard.” I instruct everyone to use common sense thinking, but not everyone does. I know of a recent situation in which a new hire who had been on the job fewer than two months was killed by induced voltage. It’s crucial that electrical safety training – including information about electromagnetic and electrostatic charging on de-energized lines – is given early in a utility employee’s career. And while understanding and recognizing hazards is up to the employee and crew, training is not the complete answer to keeping employees safe.
OSHA’s General Duty Clause, Section 5(a)(1), requires employers to identify all hazards that may cause injury, illness or death in the work environment and to protect the employee via training and PPE. What many employers and employees fail to understand is that Section 5(b) of the clause states, “Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.” Failure to follow this rule has led to many injuries and fatalities.
Electric utility lineworkers have the ninth-most dangerous occupation in the world. An EPRI study recently stated that utility lineworkers are some of the most skilled craft workers, requiring many hours of classroom and on-the-job training to reach the journeyman/line technician classification. Unfortunately, the occupation has one of the highest fatality rates per 1,000 lineworkers. Investigations revealed that a majority of the fatalities occurred on 15-kV systems and below, and were the result of a failure to follow training, improper use of dielectric gloves, and improper application and use of distribution cover equipment.
In the August issue of iP I will discuss how incidents can be prevented through proper job planning and task control as well as maintaining focus and awareness throughout the duration of a job. This article and future articles can be used in safety meetings to illustrate how accidents can happen and how to prevent similar events in the future.
About the Author: Danny Raines, CUSP, safety consultant, distribution and transmission, retired from Georgia Power after 40 years of service and opened Raines Utility Safety Solutions LLC, providing compliance training, risk assessments and safety observation programs. He is also an affiliate instructor at Georgia Tech Research Center OSHA Outreach in Atlanta. For more information, visit www.electricutilitysafety.com.