Incident Prevention Magazine

All of us who work with electricity know how hazardous it can be. During a stint with my previous employer, a co-worker and good friend was electrocuted and killed when he made contact with energized switchgear components. Another co-worker at the company also was seriously injured. Safety is always a part of our job; it’s something we talk about and practice every day, but given what happened to my two former co-workers, I felt that more needed to be done to establish a zero-accident workplace – more than just job briefings, using human performance tools and “living safely.” When it came to working with switchgear, it was necessary to develop a tangible safety device that could be paired with work practice improvements.

Several years later, after starting my current employment at Con Edison – a regulated utility that provides electric, gas and steam service to customers in New York City and suburban Westchester County – a simple request to pursue a solution prompted an effort to reform switchgear work practices. The result has made those practices both safer and more efficient – not just at Con Edison, but potentially for the industry.

You just want to do the job right and go home unharmed today, but things don’t always go as planned, incidents happen, and the lessons your team learns don’t always change the way you’ll do the job tomorrow. This can leave you feeling frustrated and helpless to improve the things that keep your team from reaching its full potential.

You deserve a framework that allows you to continuously improve your operations and team morale. In this two-part article, we’ll use the hierarchy of incidents and learning to identify and rank the different parts of an incident. As we work through all six levels of the hierarchy – the first three in this article and the next three in the follow-up article – we’ll discuss things you and your team members can do to support a continuous growth mindset. The ultimate goal of all this is to learn and improve so that we can identify and mitigate the potential for error as soon as possible and reduce the impact of incidents on our people, projects, company and customers. 

From 1980 through 2010, safety performance emphasis was on accident prevention through the application of controls. We learned about the hierarchy of controls (elimination, substitution, engineering controls, administrative controls and personal protective equipment) and the multiple barrier principle (use several controls in case one or two fail so there will always be something to protect you). The Institute of Nuclear Power Operations has defined “defense in depth” as “the overlapping capacity of various defenses to protect personnel and equipment from human error. If a failure occurs with one defense, another will compensate for that failure, thereby preventing harm. The four lines of defense – engineered, administrative, cultural, and oversight controls – should work together to anticipate, prevent, or catch active errors before suffering a significant event.” This thinking took us a long way in improving safety, and most companies experienced significant reductions in incident rates, severe accidents and fatalities.

During that period of time, and due to that success, most utility companies started to target zero injuries as part of their safety performance improvement programs. This led to an almost exclusive focus on a single number: the all injury rate or the total recordable injury rate. The result was that companies were able to achieve rates of less than 1.0 (one injury per 200,000 hours worked), which, in turn, led to the belief that they were ultra-safe organizations where nothing really bad could happen. But history has demonstrated that, even in those high-performing organizations, disasters and fatalities can and do still occur. As James Reason taught us in the 1990s through his Swiss cheese model, even multiple barriers can fail under the wrong circumstances, leading to accidents and loss.

The last time we met Bob the foreman and his crew, they saved the day when a vehicle hit a utility pole on a busy roadway in Safety County, New York (see https://incident-prevention.com/ip-articles/safety-concerns-when-setting-wooden-utility-poles).

These days, Bob and his crew are still in action, working for Sunshine Electric Co. At Sunshine, following company safety rules and industry best practices is as normal as breathing air. On this particular day, we find Bob prioritizing the unending string of planned field work assigned to his crew. His first priority for Sunshine’s customers is the list of new services and reliability jobs. As a supervisor, he also has priorities for the safety of his crew. But that’s not all. Because of his training, he knows that safety compliance to protect his employer is another one of his responsibilities as a supervisor. That is a lot of responsibility, but Bob and his crew were safely trained by Sunshine, and Bob has communicated his expectations to the crew for their safety.

Bob selects a job from the list that involves installing a new transformer on a replacement pole. The existing pole is too short to accommodate the additional facilities that must be attached, including the new transformer to feed a customer’s premises. A new, taller pole must be installed. Bob gathers his crew and explains what the job is all about. He then releases the paperwork so that the linemen can gather the new pole and all the other materials necessary for the job. He will meet them on-site in a little bit.

Across our industry, I have found all kinds of policies for grounding trucks. I also have found that in many cases, employers’ rules for grounding trucks are not based on OSHA requirements and – even more concerning – are not based on sound principles of protection. I believe the grounding policies are well intentioned, but they fail to achieve two important goals: (1) meeting the OSHA standard and (2) protecting workers where electrical contact hazards exist. So, let’s take an ABCs approach to the issue because even though some detailed explanation is required, it really is that simple.

A Defensible Plan
You must be able to defend your plan or policy. This is the case for every plan or policy. Defense is built around establishing and accomplishing a goal, understanding the hazard, understanding the mitigation of the hazard, training at-risk employees, and conducting periodic audits to ensure the plan or policy is properly employed.

Providing accurate, effective training to workers is one of the electric utility industry’s most pressing challenges. From my perspective, there are not enough appropriately qualified trainers to fill the open jobs available. As our industry’s attrition rate continues to increase, will we be able to provide the right training to new and existing employees? Each day, there are lineworkers being given work to do for which they are not adequately trained, endangering them and their co-workers. We need trainers to help correct this problem so that fewer lineworkers are hurt on the job.

I mentioned that our industry has a shortage of “appropriately qualified” trainers. There certainly are a number of individuals working for utilities and contractors who hold positions that have the word “training” or “trainer” in the title. But some of those individuals are newer lineworkers with limited experience working with crews. That can be a problem for their trainees, who need and rely on the guidance of trainers with real-life experience about how to plan and execute specific job tasks. Too many of these trainers lack a basic understanding of system grounding, distribution cover-up, and switching and tagging for employee protection. OSHA’s 29 CFR 1910.269 standard was updated in 2014, and our industry’s trainers must know and train students in accordance with those regulations.  

Q: Recently we had an employee reference OSHA 29 CFR 1926.960(f) and 1910.269(l)(7), “Conductive articles.” The question is, can an employee work in an energized area while wearing jewelry, and earrings in particular? The rules discuss conductive articles such as watches, bands, rings and chains, but I do not see where it mentions earrings. 

A: When it comes to interpretation, it is good to confine a rule to the language used, but sometimes you also have to address the intent. The concern that drove the creation of this rule was whether jewelry, which is conductive, increases electrical contact risk. Those risks are twofold: (1) Does the jewelry make an electrical shock more likely, and (2) does the jewelry increase the damage or level of injury from an electrical contact? This rule does not fit well in the utility industry because its origin is the indoor electrical industry. Electricians rarely employ rubber gloves and were sticking their bare hands in energized panels in close quarters. Still, we can’t ignore the rule, but we can easily address it. As far as electric utilities are concerned, hands in close quarters to uncover bus or wire could cause a flash where jewelry goes to ground. You would get shocked anyway, but the jewelry could cause an arc flash, which increases injury levels with burned skin. That doesn’t really apply where we work unless your uncovered hands are in a meter can. The answer for either 1926 Subpart V or 1910.269 is in the wording of the rule, so look closely: “When an employee performs work within reaching distance of exposed energized parts of equipment, the employer shall ensure that the employee removes or renders nonconductive all exposed conductive articles, such as keychains or watch chains, rings, or wrist watches or bands, unless such articles do not increase the hazards associated with contact with the energized parts.”

Over the years, I have taught or sat through training sessions with thousands of people. Based on my experiences, I can unequivocally state that personality and leadership styles are the training topics that generate the most excitement and discussion among trainees, and the ones that inspire the most aha moments. Relatedly, the DISC profile is the single tool that I get the most positive feedback about – and the one that has had the most positive impact on people’s lives and careers.

This article, which is based on the DISC assessment that is offered through the Incident Prevention Institute (https://ip-institute.com), will explain the value of the assessment, what is involved in undergoing the assessment, what you will receive after completing the assessment, and how to use the assessment as a personal and professional development tool. It is worth noting that there are many useful leadership, personality and behavioral assessments available that are similar to our DISC assessment. I highly encourage you to research them and take at least one.

Planning is a critical part of our work in the electric utility industry. Inevitably there will be unknowns in each plan we put together; the more variables there are, the less control you have over your intended outcomes. So, it’s worth spending the time to identify and address those unknowns. In the remainder of this article, we will cover how to identify the critical elements and variables in your projects as well as how to weigh the consequences of those variables to help ensure the best possible outcomes for your plans.

A friend of mine who is a psychologist once shared a story from her childhood with me. She said that whenever she had a plan for something that appeared overly complicated, her father would say, “Be careful – you are taxing the variables!”

What did my friend’s father mean by that? To put it simply, taxing the variables occurs when there are too many variables that depend upon the success of other parts of your plan. Let’s say you have to check in for a flight at the airport. The flight leaves at 7:30 a.m. Boarding begins at 6:30 a.m. You live two hours from the airport and want to arrive two hours before departure. Leaving your house at 3:30 a.m. should get you there at 5:30 a.m., so you set the alarm on your cellphone for 2:30 a.m. That plan sounds simple enough, right? But what are some of the unknowns in the situation, those variables that may arise and interfere with your plan? For starters, the battery in your car has been a bit weak lately and it’s going to get very cold later today. Will your car start when you need to leave for the airport? You set the alarm on your cellphone for 2:30 a.m., but did you remember to put the phone on the charger, too, so that the battery doesn’t die? Oh, you just remembered it’s also a holiday weekend. Is two hours still sufficient to make it to the airport, or should you factor in extra driving time because of traffic concerns?

One of the most vital responsibilities a utility fleet has to its customers – which typically include operators, field management and corporate management – is to provide vehicles and equipment that meet operational and corporate objectives. Those objectives also must be met without compromising the safety of the operators, other workers or the general public.

So, how does fleet uphold safety as a core value while managing all of the other objectives that the department and its customers have – particularly when those other objectives appear to, at times, directly conflict with the safety objective?

The fact is that if only fleet itself attempts that task, it will not only be daunting but nearly impossible to execute. However, success in the area of fleet safety is not only possible but attainable when fleet works with its customers and business partners to understand their needs and challenges. So, let’s review three areas – communication, data analytics and customer buy-in – in which fleet and other work groups can collaborate to help assure safety on the job.

This article concludes a two-part discussion of protection strategies against arc flash and shock hazards. Here you will read about two topics: (1) arc flash and shock hazard labeling for industrial, commercial and generation facility electrical exposures, and (2) methods used to determine the level of PPE required.

The previous article (see https://incident-prevention.com/ip-articles/arc-flash-considerations-for-utility-and-construction-activities) mentioned that utilities follow OSHA 29 CFR 1910.269 and construction companies follow either 1926 Subpart K or 1926 Subpart V, depending on the job site. It discussed arc flash and shock hazards as a basis for selecting appropriate PPE to protect against each hazard. It also reviewed the consideration and provision of daily workwear and flash suits as well as voltage-rated gloves for low- and high-voltage work. Part II will explain the methods used to determine the level of PPE required through an arc flash incident energy analysis or engineering study. Equipment-specific labeling is the most widely used method to communicate the level of protection to workers. Arc flash and shock labeling will be presented using examples and serve as a backdrop to the introduction of key terminology used in electrical safety.

Aerial devices have improved exponentially over the last 20 years. Many purchasers and users of the devices, however, are not fully aware of the options now available to them. Technology and innovation – driven by ANSI standards and user collaboration with manufacturers – have resulted in aerial equipment that provides greater functionality and improved safety mechanisms for utilities and operators.

In the U.S. and Canadian utility industries, aerial equipment must meet the requirements found in ANSI/SAIA A92.2, “American National Standard for Vehicle-Mounted Elevating and Rotating Aerial Devices.” The most recent version of the standard was published in 2015. For their part, manufacturers work hard to design and produce aerial equipment that meets utilities’ needs and adheres to or exceeds the A92.2 requirements.

In this article, we will review some of the aerial equipment technology and innovations now available in the market. We’ll also discuss pertinent ANSI safety standards for aerial equipment used in the utility industry.

When analysts look at utilities, and to some extent utility contractors, they often see what’s referred to as “mission creep.” That occurs when the expertise of the utility should be focused on quality and continuity of service but begins to be compromised by focus on too many other areas. The opposite of mission creep is when business elements that are critical to successful progress toward the goal get overlooked because of focus on the goal. One business element that gets less attention than it deserves are big trucks and the Federal Motor Carrier Safety Regulations (FMCSR). Granted, 75% or more of the FMCSR do not apply to utilities, and many parts that do apply are difficult to implement. Implementation is tough because, even as employers with drivers and big trucks, we are not carriers, which is the target audience of the rules, but we still are regulated by those carrier-related standards. The key areas of compliance for utilities are driver qualification, record of duty status (RODS), safety equipment and load securement. There also are a couple of new initiatives that we should keep an eye on.

I find human performance a fascinating topic to teach during my supervisor training classes. Many readers of Incident Prevention are familiar with the topic. For those who aren’t, human performance is an analytical tool that examines how people accomplish tasks and why they perform those tasks in a particular way. Employees in the electric utility industry execute many of the same tasks each day. We do them according to the local culture’s work practices, primarily learned through on-the-job training. As older workers retire and new employees join the ranks, those work practices are passed down to the next generation. Sometimes the practices are not the safest approach and can lead to incidents and accidents.

At one point in our industry’s history, it was common to blame employees when incidents and accidents occurred, but we have learned over time that human error rarely is the root cause. That’s where human performance tools help employers identify and correct latent organizational weaknesses and errors. A company that invests in human performance analysis can minimize active errors on their job sites. Human performance training helps employees understand risk adversity, particularly how the coincidental experience of an injury-free work history can cause increased risk and exposure to an employee simply because nothing bad has happened to them so far. Workers can become so used to risky practices that they often will assume they’ll be alright today and in the future.

Q: Where does OSHA’s switching and lockout/tagout policy draw the distinction between generating plants and the plants’ substations, particularly with metal-clad substations?

A: It depends more on the equipment used than a distinct line, and it has to do with OSHA’s intent, equipment design and practicality. Let’s look at this from the perspective of intent. OSHA intends that employers have an energy control plan that protects workers. LOTO was developed for that and has worked very well over the years. The data shows that LOTO has been directly responsible for a dramatic decline in severe and fatal incidents related to hazardous energy releases. The utility industry was ahead of OSHA with switching policies and procedures, and OSHA recognizes the effectiveness of that history.

When we talk about leadership and human performance, something we stress is that people are equal but never the same. That’s true for how we behave, what motivates us, how we interact with others and what we will do in specific situations. A tenet of leadership is that your leadership style should be based on the people and circumstances you are dealing with – not on what you personally prefer and are comfortable with.

This is also true for how we learn, or what’s referred to as our “learning style.” One person may love to read a book while another might prefer to see the movie. Some people need a group setting with discussions and debates to learn while others want to study individually. I might be interested in a topic that is of no interest to you. Certain people like to take detailed notes while others might be satisfied with slide images or no notes at all. You may have heard terms like “visual learner,” “auditory learner” and “tactile learner.” You should also know that every person has different levels of literacy and information retention skills.

Les Prudent was sitting at his desk on a Monday morning, savoring a cup of coffee and reflecting on his solar farm transformer company’s crazy year of growth. From four people three years ago, the company now employs 112. A friend from a local business group recently suggested Les hire a full-time safety coordinator, but he’s been comfortable handling those matters on his own. He just put some of those “Safety First” posters on the fabricating area’s walls. That should do it.

His wife, Linda, who is also the company’s office and accounting manager, just stuck her head in the door and said, “Les, there’s a man here from OSHA. He says there’s been a complaint and he wants to conduct an investigation.”

Shocked, Les wonders who could have complained. He remembers what his buddy Frank told him about OSHA’s visit to his plant. Frank hadn’t done anything wrong, but they still fined him thousands of dollars because one of his employees slipped and fell from a truck bed. Isn’t that why he carries workers’ compensation insurance? Anyway, Frank said he’d never let OSHA back into his plant without a warrant.

Electrical utilities are among the most hazardous industries in which to work. And since the early days of power distribution, utilities have investigated and analyzed fatalities and other incidents in an effort to prevent recurrences.

One proven way to help verify and measure the effectiveness of an organization’s safety efforts is to conduct field personnel observations – or, in OSHA terminology, “inspections” – on a consistent basis. Conducting these observations enables the organization to take a firsthand look at what is going on in the field, as well as document employees’ demonstration of their knowledge and ability to work safely. The practice also sends a message to employees that the company cares about their safety.

Five Goals of Field Observations
There are five goals we hope to achieve when we observe workers in the field.

1. To assure compliance with the requirements of OSHA 29 CFR 1910.269(a)(2)(iv).
Paragraph 1910.269(a)(2)(iv) states the following: “The employer shall determine, through regular supervision and through inspections conducted on at least an annual basis, that each employee is complying with the safety-related work practices required by this section.”

Safety managers know that when an employee has done a particular task many times, that individual can become so familiar with the action that they no longer have to pay close attention while performing the work. As they become complacent in their ability to successfully complete the task, the risk of accident increases. But familiarity is not an emotional state. It’s a physical condition. Familiarity is the byproduct of habit, and a habit is a neural pathway created in the brain through repetition.

How Habits are Formed
When the brain does something for the first time, the prefrontal cortex (PFC) is activated and communicates in a loop with the striatum.

The PFC is the part of the brain that sits above the eyeballs. It’s essential in making decisions, planning ahead, focusing thoughts, paying attention, learning and considering several different yet related lines of thinking. It’s used for evaluating the future consequences of current activities, working toward a defined goal, predicting outcomes, interpreting social cues, moderating social behavior, and determining good and bad, better and best. The PFC helps retain information while performing a task, determine what information is relevant to the task in progress and keep the objective of the task in mind, all at the same time.

Recently I was on a conference call during which a client and I discussed aggression aimed at the client’s line crews and service technicians. As I hung up, I came to the realization that hostility toward utility workers isn’t a passing storm – it’s a bellwether of change in the public attitude. Aggression directed at utility workers is a critical issue that we must deal with effectively before more people are hurt.  

The truth is, a growing number of people no longer see investor-owned, municipal and cooperative utilities as benevolent service providers. Instead, they see adversaries who are blocking access to service entitlements and ruining the environment. Much of this growing animosity is aimed at utility office staff and field crews. In fact, the client that I was speaking with on the conference call I mentioned had seen a significant jump in the number of threats to their field employees, and they were looking for ways to mitigate the hostility and keep the workers from harm. As we talked, the need for sharper skills in identifying and responding to threats became evident. The client and I decided to move toward that goal, starting with awareness and baseline training.

What is Situational Awareness?
Awareness – or more precisely, situational awareness – is the foundation of effective security. Today, there are as many approaches to situational awareness training as there are security trainers. The problem for utilities is determining which training technique and which trainer to use, but we’ll get to that issue a little later. First, we’re going to talk about what situational awareness is and why we need a baseline of what’s normal in our specific working environment.