Incident Prevention Magazine

The operations director stood before his direct reports, boiling over with anger.

“Here we are again!” he said. “Still plagued with the same production, quality and safety issues – problems that we’ve cussed, discussed and created improvement plans for over and over again. I don’t know what’s wrong with you and your people, but we’re going to get to the bottom of this right now. To be brutally honest, I’m not sure that everyone in this room will still have a job next month if you don’t start implementing the changes that will get us different results. So, who wants to kick off this meeting with an idea about how we can become the best division in this company?”

And then there were crickets, only to be interrupted by moments of meaningless, self-protective chatter.

Does this scenario sound familiar? I hope not. The problem is, however, that people are fallible, lessons sometimes aren’t learned, and improvements aren’t always made. This can leave leaders and team members feeling frustrated or apathetic because they don’t know how to right the ship. Regardless of how close this scenario hits to home, what we’re going to discuss in this two-part article will enable you to find greater success today and learn what you need to improve tomorrow.

Leaders play a pivotal role in creating a safe work environment that brings out the best in their people and produces quality results. And this doesn’t just mean leaders at the top but at every level of the organization. Leadership isn’t a difference maker – it is the difference maker.

The pathway to better safety performance in an organization or on a team begins with understanding the physics of performance. Leaders create the culture, the culture drives and supports behavior, and behavior produces results. Nothing impacts safety behavior and performance more powerfully than culture, and nothing impacts culture more powerfully than leadership. Simply put, if you get your culture right, you will win at safety; get it wrong and you will struggle with safety. Now, let’s take a deeper dive into the physics of performance.

Behavior, Culture and Leadership
The ability of people to apply their job-specific knowledge in a safe and productive manner is largely dependent on their behavioral skills, including how they communicate, make decisions, manage their attitudes, deal with stress and interact with others. Task-specific knowledge and technical skill are essential, but behavior-related issues are the biggest drains on safety performance in most organizations. Behavior is the one thing that affects everything, and culture is what drives and supports how people behave. 

Years ago, a rare event happened in the service area of the company I was working for at the time. Sea fog had rolled in and blanketed most of the system along the coastline where the generation was located. It contaminated the insulators and tripped major circuits everywhere. All of the substation and line crews worked hard to clean the insulators and get the system restored. It took a full day to get the system back to normal, during which all of us learned a great deal about insulation. One crew in particular will probably always remember that day. While they were getting ready to switch out a section of 230-kV bus in a substation, electricity tracked down the insulator right above their heads. Fortunately, no one was injured, but there was a lot of high stepping and gravel flying.

Nearly everyone reading this has worked with insulators of various sizes and shapes. For me, it was in substations. You learn to trust the equipment with your life. What prompted this article was a website discussion I read about best practices for maintaining and cleaning insulators and bushings for testing. There were some interesting suggestions. The question is, how do we know where to get the correct information to help us in our work? Safety is our primary guide. Our second guide should be manufacturer guidelines. In the early years of our industry, we were instructed to “go do it” and not given much direction or specifics about how to perform the tasks we were assigned. So, we used a variety of methods and materials to clean and install insulators. Some were good, others not so much. But today we have the world at our fingertips: websites, phone numbers and access to almost any kind of information from a variety of sources. The problem remains, however – we must know how to determine if we have and are using the correct information.

Welcome to the first part of what will be a six-part series focused on OSHA’s electric power standards. We will start this series with a discussion about when the standards apply. Future articles will cover what is in the standards plus provide you with some practical ways to apply them.

If you have tried to read OSHA’s electric power standards, you may find them difficult to interpret and apply. Always keep in mind that each part of the standard was written to address a specific hazard that must be controlled. The standards outline the minimum controls you are required to put in place, so that is why OSHA standards are considered minimum performance standards. If you always begin by identifying the hazard, you may find that the application of the standard becomes somewhat simplified.

Why Does OSHA Have Electric Power Standards?
Employees who work on and around electric power installations face unique electrical system hazards with potentially high risks. OSHA estimates their electric power standards will prevent approximately 20 additional fatalities and 118 additional serious injuries annually. Each portion of OSHA’s electric power standards is designed to address electric power system hazards that workers are exposed to when performing covered work that falls under general industry or construction. 

This is a review of ANSI/SAIA A92.2-2015, “American National Standard for Vehicle-Mounted Elevating and Rotating Aerial Devices.” As a consultant, investigator and auditor, I have been surprised time and again that people who should know this standard do not know it that well. Most fleet managers are familiar with the rules, which is important because the A92.2 standard obligates owners of aerial lifts to be held liable for equipment they sell in certain scenarios. On the employee side, a working knowledge of A92.2 can prevent incidents and loss of life. In fact, a recent live-line barehand training class was what inspired this topic. We found that a bucket truck had the leasing company’s logo sticker adhered down both sides of the insulating boom section. That bucket truck was designed and rated for barehand use at 500 kV, yet a vinyl-plastic printed logo installed by the leasing company, spanning two-thirds of the insulation length, could have had some serious implications for the safety of that boom.

In this article, we are going to review some of the information covered in the A92.2 standard. Readers should recognize that ANSI/SAIA consensus standards are protected by copyright, so we will not directly reproduce the text of the standard itself. The A92.2 standard can be purchased directly from the ANSI website (https://webstore.ansi.org).

The target audiences of this review are the owners and users of aerial lifts (bucket trucks) as well as safety departments, with the goal of familiarizing those parties with both the safety aspects and owner responsibilities regarding aerial lifts. Unlike many consensus standards, A92.2 has been incorporated by reference into the OSHA standard, meaning that certain parts of the A92.2 standard are enforceable by compliance officers. In addition, the incorporated parts of the standard essentially are “living” – they have been published in the Federal Register and made available to the public so that updates to the A92.2 standard are automatically part of the legally enforceable federal OSHA standard. Now that we have the applicability of the standard covered, let’s take a look at what the standard requires.

It happens every so often – and more often than it should. A lineworker climbs a wood pole and the pole falls. With the advent of 100% fall protection, the climber is assured serious injury and often death if a pole falls while they are tied to it.

Several of these types of incidents have occurred in recent months. The first question is, why didn’t those poles get checked before anyone climbed them? The next question is, what can we do to prevent future falls?

Correct Depth is Key
First and foremost, correct depth is what keeps a pole in the air. Most companies have a specification that determines a pole’s installed depth based on its length. Another resource you can refer to is ANSI O5.1, “Wood Poles – Specifications and Dimensions.” Essentially, the taller a pole is, the deeper it needs to be buried in the ground to ensure it is stable. Across the industry, it is not uncommon for utilities to teach this rule of thumb: 10% of the pole height plus 2 feet.

Q: We have a crew performing pole change-outs with the line energized. They are suspending phases with a link stick and digger derrick to provide more clearance between phases to install new poles and hardware. The question is, can the operator leave the controls with the phase lifted? We thought they could, but it seems there has been a change to OSHA 29 CFR 1926.1417(e).

A: The good news is that you cited the wrong rule. Pole change-outs fall under the 1910.269 operation and maintenance rules. You cited the rule for construction (OSHA 1926). The operation and maintenance rule – found at 1910.269(p)(1)(iv) – states the following: “The operator of an electric line truck may not leave his or her position at the controls while a load is suspended, unless the employer can demonstrate that no employee (including the operator) is endangered.”

Of course, it’s not as simple as that. The likely intent of both the operation and maintenance rule and the construction rule is to give an operator a break from the seat for inclement weather exposure or water or bathroom breaks. The issue with the construction rule is that the lift must meet “all of the following,” which are these requirements: no other duties for the operator, the operator stays next to the lift equipment, the equipment is stabilized and locked down, and barricades block the fall zone. Those requirements reflect the Cranes and Derricks in Construction standard (1926.1417(e)). The only requirement with the operation and maintenance rule is assuring no one is at risk.

“Anyone can become angry. That is easy. But to be angry with the right person, to the right degree, at the right time, for the right purpose and in the right way – that is not easy.” -Aristotle

From an early age, many of us were taught that there are bad words we shouldn’t use. I won’t provide any examples here, but I suspect most readers know which words I’m referring to. In our industry, there are other “bad” words that we have learned we should avoid at all costs – because they are perceived to show signs of weakness. These words include “feelings,” “relationships,” “emotions” and “caring.”

My personal observation is that many organizations and individuals have become more accepting of these words due to increased understanding of leadership and human performance. Still, quite a few of us want nothing to do with emotions and feelings, and that is such a shame. We are missing out on a great number of opportunities for personal and professional growth and success.

Creating a safety mindset and a culture of caring can be facilitated using the process of socio-biomimicry. Simply put, biomimicry is a way to solve engineering and other problems by looking to nature. The term was popularized in 1997 by Janine M. Benyus in her book, “Biomimicry: Innovation Inspired by Nature.”

Nature can also be used to inspire a fresh look at social systems and how other life groups manage safety. I developed the Safe-ari process of socio-biomimicry to solve a client’s problem of fading situational awareness. Fourteen learning points on situational awareness were distilled from safari photos – some of which we’ll take a look at in this article – and woven into employee meetings. In one representative session with a group of 48 people, using pre- and post-surveys with the Likert scale (1-7 rating) plus comments, the following results were delivered:

• 30% improvement in understanding what situational awareness means
• 90% improvement in listing three situational awareness concepts
• 40% improvement in helping other people think about their own awareness
• 50% improvement in comfort of leading a toolbox talk on situational awareness
• 90% improvement in generating a year’s worth of situational awareness topics
• 50% improvement in listing three ways people are not situationally aware
• 50% improvement in knowing how to incorporate situational awareness into daily actions

Results such as these suggest that socio-biomimicry is a successful methodology for raising safety consciousness and creating touch points for easy recall of safety messages.

On March 27, 1977, two 747 passenger jets crashed on a runway on the Spanish island of Tenerife, killing 583 people. It remains one of the worst disasters in aviation history.

Human performance has evolved as a valuable incident prevention strategy in the utility and contractor industry. If you have studied human performance and safety management, you will see how the right training could have prevented the Tenerife incident. The purpose of this article is to explain the details of the Tenerife airport disaster and then draw lessons that can help crews in the utility industry work even more safely.

Perhaps the first thing you should know is that Jacob Veldhuyzen van Zanten – who piloted the Dutch KLM 747 that was involved in the crash – had served as a role model for other airline pilots. He was considered the best of the best. Having moved up to top management at KLM Royal Dutch Airlines, he was even the head of safety for the company. However, van Zanten had a problem: His revered skill and knowledge made him think he knew better, which ultimately was a major factor in the Tenerife crash.

“Back in the day, we put leaking pots in a trash bag, and we were good to go!”

For hundreds of Incident Prevention readers, that remark isn’t totally unheard of. And in reality, it’s not far off from what some do when leaking transformers are transported or stored prior to reclamation or disposal. However, that will not save a utility from the fines and reclamation actions it could face if transportation or environmental regulatory authorities get involved.

Utilities fall under numerous environmental regulations, including the Toxic Substances Control Act of 1976. Since the 1970s, public demand for environmental safety also has led to numerous additional requirements. The problem is that the various agencies, with their overlapping environmental requirements, don’t specifically or clearly detail the issues that utilities face with aerial and padmount transformers and other line equipment that are insulated with a variety of fluids or oils. Individual states also may have regulations that exceed federal standards, potentially increasing utility exposures. What is clear is that if you dump oil, no matter what kind it is, you will face fines and reclamation costs far beyond what the cost of compliance would have been.

Ultimately, utilities must be concerned about the greatest exposure to environmental enforcement, and that is field-employed transformers and switchgear that contain chemicals. Transportation and storage of fluid-insulated apparatus are covered by numerous U.S. Environmental Protection Agency standards, including the Resource Conservation and Recovery Act, as well as standards from the U.S. Department of Transportation and the Pipeline and Hazardous Materials Safety Administration. But even more important than regulations may be your customers’ impressions of your environmental stewardship. These days, the public has become more sensitive to environmental risk exposures. Oil dripping from trucks or apparatus impacts the public perception of a utility.

Salt River Project, or SRP, is a power utility located and operated in the greater Phoenix area. Created as part of the federal Reclamation Act of 1902, it was originally established to help secure a reliable water source to the desert valley. Today, SRP not only provides reliable water – it also supplies reliable power to over 1 million customers, operating and maintaining all of its own assets, including generation, transmission and distribution.

The utility has a successful 500-kV barehand/live-line program that dates back to the late 1970s. In the fall of 2018, SRP experienced a boom flashover event during preparation for 500-kV barehand work. The procedures the utility had developed over the history of its barehanding program, and the crew’s careful execution of those procedures, saw everyone return home unharmed on the day of the incident.

Safety procedures sometimes are developed following an injury or incident that may have occurred a long time ago. In our industry, we often adhere to procedures without having personally witnessed why they exist. The 2018 event is one case where we got to see up close and personal why SRP’s safety procedures are so valuable. We have a very tight-knit group where you don’t just know the crew members; you know their families, too. Our safety culture exists in service to a broader community.

In the June-July 2020 issue of Incident Prevention magazine, I made a mistake in the Q&A. I stated that there is no consensus on a particular procedure when, in fact, there is. It is new in the most recent edition of the National Electrical Safety Code, but I missed it when it was published in 2017. In light of my error, I decided I should take a closer look at the most recent revision of the standard and present my findings here for the benefit of iP’s readers.

The NESC is one of the consensus standards that I regularly recommend as an important resource – every safety professional should have a copy of it in their library. Here’s some important information about the use of consensus standards: First, the standards are more procedural than the OSHA performance language. “Performance language” means that a rule is written in a format that tells the reader what must be accomplished. Procedural language, on the other hand, tells the reader how to accomplish something. Second, OSHA classifies consensus standards into two categories, adopted and referenced. Consensus standards that are adopted are incorporated into the OSHA standards by references listed in 29 CFR 1926.6 for construction and 1910.6 for general industry. Referenced standards are adopted into the OSHA rules with the force of law and can be cited in compliance actions against employers. Consensus standards that are referenced are helpful to the employer, as OSHA puts it in the introduction to Appendix G of 1910.269. OSHA defines “recognized” consensus standards as “helpful in understanding and complying with the requirements contained in § 1910.269. The national consensus standards referenced in this appendix contain detailed specifications that employers may follow in complying with the more performance-based requirements of § 1910.269.” You will find the same referenced standards in Appendix G to the 1926 Subpart V construction standards.

Is it maintenance or construction? That’s a question that was asked regularly by industry workers for many years. These days, we can thank David Wallis and the committee members who diligently worked on the OSHA 29 CFR 1910.269 and 1926 Subpart V final rule published in 2014 for clearing things up.

To better understand the value of the final rule, let’s review some brief history of the two standards. In 1972, the construction standard for building transmission and distribution systems was completed. Did you notice there was no mention of generation in that standard? We will address that shortly. Nearly 20 years later, around 1992, the 1910.269 electric power generation, transmission and distribution standard was completed and published in the Code of Federal Regulations. That was a significant event since it had taken two decades of research by OSHA construction committees and an unknown number of stakeholder meetings in which utility end users, contractors, cooperatives, municipals and investor-owned utilities expressed their concerns.

Q: I read what was written about an air gap for worker protection in the June-July 2020 issue of Incident Prevention magazine, but one of our engineers who sits on a National Electrical Safety Code advisory committee brought something to my attention. NESC C2-2017 444.2 states,  “Air gaps created (e.g., cut or open jumpers) for de-energizing equipment or lines for the purpose of protecting employees shall be tagged and meet minimum clearances as specified in Table 444-1 or separated by a properly rated insulator.” What are your thoughts on this matter?

A: Thanks for your question. Our thought is that your colleague is right regarding the table and we missed it.

To remind iP’s readers, in the June-July 2020 Q&A, we addressed what constitutes an air gap and stated that some utilities build their gap rules around minimum approach distance. We pointed out that MAD is a combination of minimum air insulation distance (MAID) and unexpected movement, which is 24 inches for distribution. We gave the example of a dropout switch that has an 8- or 10-inch-plus gap being acceptable where the MAID in a 15-kV distribution exposure is fewer than 2 inches for phase to ground. We could have worded it better, so we hope we didn’t give anyone the idea that MAID is all that’s necessary. In any case, we don’t want anyone to be misled by what we publish. 

Do good decisions exist? Think about that question for a moment and allow me to explain the intent and purpose of this article. In these pages, I will take the position that good decisions do exist, but people define “good” differently, and that definition changes based on circumstances. That has huge implications for leadership and safety.

Take a look at the following questions. What decisions would you make? I can guarantee that some of you have disagreed with family members or friends about these very same topics. When it comes to certain decisions, we have strong opinions; with others, we simply don’t care.

• Should you rinse off the dishes before you put them in the dishwasher?
• You are traveling to a destination that is a seven-hour drive from your house. Do you make the drive or fly there instead? If you decide to fly, do you check bags or carry everything with you onto the plane? How early should you get to the airport?
• It’s time for vacation. Beach or mountains? Do you want to relax or head for the thrill rides? Should you rent a hotel room or a house?
• You are ready to eat dinner. Should it be a hamburger or a salad? Healthy or not? Delivery or carryout?

When it comes to lifting transformers, aerial devices equipped with jibs are one of the handiest tools available to lineworkers. Compared to old methods for transformer replacement – which required workers to climb the pole and use a pulley to manually lift the transformer – using a jib is safer, easier and more productive.

Most aerial devices sold to companies in the utility industry are equipped with jibs. However, not all jibs are the same, and the user should evaluate the type of work to be done when choosing the equipment for the job. Consider whether the tasks are construction or maintenance work on distribution or transmission lines. Before dispatching to the job, workers should know how the lines are situated relative to where the vehicle can be located. In addition, the weight of the load will determine the capacity of the aerial device and jib needed.

In the remainder of this article, we will provide an overview of the four key areas that inform good practice for using jibs: knowing your equipment, inspecting your equipment, knowing the load and understanding proper setup.

Know Your Equipment
There are many different styles of jibs with varying capacities available on different boom and platform configurations, including side mount, underslung, end mount and jibs that rotate with the platform. There also are fixed-length jibs, jibs that can be manually re-pinned to provide various extensions, and jibs with one or more sections that are hydraulically extendable. Some units are designed with the load line above the jib boom and some are below. Other jibs are equipped with sheaves that allow only non-overcenter lifting, while some can do either overcenter or non-overcenter lifting.

The contractor’s executive team sat across the table from the client’s construction leadership. It was the client’s director who spoke first.

“Let’s ensure everyone is on the same page,” he said. “Over the past six months, you’ve had numerous quality, production and schedule issues, an environmental noncompliance, two injuries and a utility contact that caused a 3,500-customer outage for over six hours. All of this has almost crippled three projects that we trusted you with, and we need to know how all this happened and what you are going to do about it.”

The contractor’s president looked up and humbly replied, “First, I want to apologize for breaking your trust. As for the ‘how’ question, there was no single cause. We missed a lot of good catches and close calls because we weren’t using those indicators on our operational and safety scoreboards, but things are different now. We have a new way of measuring success. What we’ve learned over the past few months is that our workers’ thoughts, attitudes and mindsets affect how much they respect the conditions and situations they face, and that level of respect becomes apparent in their behavior. We’ve been learning about and addressing these issues for the past month, and we’re beginning to see greater operational and safety success. However, we also have to change 52 years of culture, and that’s taking more time and effort than we would like. While I accept the fact that this change will be an ongoing, forever endeavor, I can confidently tell you that if we had begun this earlier, we wouldn’t be sitting here right now.”

The company I work for receives a lot of questions about flame-resistant (FR) and arc-rated (AR) clothing, including inquiries about what should be worn on extremely hot summer days and very cold winter days. We’re always happy to answer those questions because it’s our business and – in the electric utility industry – donning FR/AR apparel often is necessary for workers’ personal safety.

The fact is, extreme weather doesn’t appear to be stabilizing anytime soon. Both NASA and the American Meteorological Society have predicted that we can expect both more intense and more frequent heat and cold events across the country in the coming decades, with implications for both indoor and outdoor workers.

Given that information, it’s important that workers know what heat stress and cold stress are and what those types of stress can do to their bodies. So, let’s discuss some definitions of heat and cold stress, what can contribute to them, and what employers and workers can do to address them – including participating in a strong FR/AR clothing program. 

Recently I have received numerous emails and phone calls regarding respiratory air-filtering masks rated for arc flash. I’m sure everyone reading this, no matter what country you’re in, is aware why that’s the case: the COVID-19 pandemic.

If you are a regular reader, you know it is my methodology to address topics by first citing the related safety standards in effect and then discussing the issue from a practical perspective typically related to the utility industry. This time is no different – for the most part.

Initially, the use of masks during the pandemic was limited as effective respiratory protection and still is for the public per the Centers for Disease Control and Prevention. As far as OSHA was concerned regarding workplaces, the only approved mask was the NIOSH-approved N95 filtering facepiece respirator (FFR). The N95 rating means that the mask meets the criteria for effective filtering of airborne particulates and moisture at 95%. The rating system also was established by NIOSH. It is important to understand that the N95 rating is based on the assumption that the masks are utilized by trained users meeting the OSHA respiratory protection worker training and fit-testing standard, which also can require a medical evaluation of the user.