Incident Prevention Magazine

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.

There are two reasons why it’s problematic not to know OSHA. The first reason gets the employer in trouble. The other reason gets everyone in the utility sector in trouble. Let’s begin this installment of “Train the Trainer 101” with a discussion about the first reason and why it’s important to know OSHA from the perspective of rules and regulations.

There are some realities we need to acknowledge to understand the difficulties different employers face. These are generalities based on my experience; I do not seek to classify all sectors of the utility industry as the same. It is a reality that municipalities – and the contractors who work exclusively for municipalities – are more or less late to the OSHA table because OSHA has excepted government and subdivisions of government from complying with OSHA regulations. In the past, only municipalities in state plan states were under OSHA jurisdiction. As word and experience got out, more municipalities voluntarily expanded their safety programs, and municipal associations took a role in raising the awareness and safety consciousness of municipalities that were not accountable to OSHA. However, small contractors have a resource issue. Few small contractors with under 100 employees have full-time safety personnel, and many contractors with even larger workforces have no full-time safety personnel on their larger job sites. But lack of safety on job sites is not just reserved for smaller contractors. I see large utilities with roving safety personnel who are stretched so thin that their time is mostly spent getting ready for safety meetings and newly hired employees rather than auditing crews on work sites where threat meets flesh. For a safety program to work, there must be staff who are qualified to audit the workplace, know OSHA’s expectations for employers, develop compliance strategies and the related training and written procedures, and conduct safety training. There also must be site visits to audit performance and compliance, mentor crew leaders and members, assist in job planning, and review job site documentation like tailboards and work plans. If your safety department also keeps required Department of Transportation and safety training documentation, performs investigations, and keeps injury and incident documentation, that is another full-time layer of work.

Each time I present an OSHA training class to electric utility workers, the topic of utility locates arises. That’s because, other than utility locates being a legal requirement in most states, it is critical for line crews to have up-to-date locates for their own safety. When locates are not in place, it’s more than just a possibility that an employer will face OSHA citations and other legal liabilities in the event of an employee’s injury or death.  

In most areas throughout the U.S., calling 811 will connect you with someone who can help you get applicable locates to ensure the safety and legality of your digging operation. Whether the job is to trench, backhoe or set a pole, locates must be made for the dates you will be working so that workers are safe and the employer can avoid potential legal action against them.

In the remainder of this article, I’m going to share two examples I’m aware of in which locates weren’t properly marked, resulting in property damage and one fatality. None of the errors was made intentionally, and each time the crews were simply trying to be productive for their respective companies. Nonetheless, the incidents and injuries occurred. 

Q: As a contractor doing transmission maintenance, we see many different constructions of statics at the tops of transmission poles and structures. They’re grounded, and we always thought they were safe to handle with leather gloves. Now we’re hearing that statics should be grounded temporarily for worker protection. What’s the explanation for that?

A: It’s called a “static,” but don’t forget that the voltage and current flowing on it is induction-coupled alternating current that will kill you. As an industry, there are a lot of utilities that have worked statics in leather gloves and have had no issues. There are others that had no issues for decades – right up until the day someone on their crew was injured by current on a static.

It’s not actually grounding that protects the worker; it’s bonding of the grounded static. Because of the hazard level associated with this discussion, we need to post a disclaimer here: Incident Prevention magazine publishes what it believes to be the best, most accurate advice available from industry experts, but the publication is not a training venue nor is it in the consulting business. It is the employer who is solely responsible for work methods employed in the field.

This article wraps up our “Lead to Win” leadership series. In this series, and during the associated webinars, we have discussed characteristics of effective leaders – both who they are and what they do, challenges leaders commonly face, and how to improve your leadership skills and maximize your effectiveness as a leader. The remainder of this article will outline highlights and key points from each article in the series and reinforce that leadership is a skill that can be practiced and improved. As you read, think about how each topic builds on the others and how interrelated and interdependent they are.

An outrigger pad is a safety tool that can be used with any equipment that has outriggers, down jacks or stabilizers. It is a must for stability when a piece of equipment – such as a crane – lifts loads or personnel aloft. This article will provide an overview of outrigger pads, including how to use them safely and what kinds of pads are available on the market today.

The Basics
Outrigger pads are placed on the ground under the equipment’s outrigger, shoe, float or foot. The size and thickness of the outrigger pads to be used should be selected based upon the type of equipment, soil conditions of the work site and type of lift being performed.

When working with outrigger systems, it’s important to understand that the point of contact between an outrigger and the ground is quite small. Because of the pressure of the outrigger, the ground underneath may shift, be displaced or collapse if an outrigger pad is not used. If any of those things happen, there is the potential for the equipment to shift or tip the load, which could lead to the equipment toppling over. In fact, approximately half of crane lifting accidents are caused by improper use of outriggers.

If you have studied human performance or read Incident Prevention magazine regularly in recent years, you know that human beings are affected by a variety of cognitive biases. And if you’ve been in the electric utility industry for even a short while, you know that the job brief is hailed as a key to a safe workday. Given the variability in the delivery of job briefs around the country, however, it sometimes is difficult to determine how effective they really are. This article will explore issues presented by some current job brief practices as well as identify behaviors to consider that will help make job briefs more effective on your work sites.

In the Beginning
When I was a young lineman, we did not have written job briefs, but there was almost always a plan written out for complicated work. The job usually went well when we had a crew leader with good communication and organizational skills. Assumptions and poor communication typically resulted in poor workflow. Then came the mandatory job brief, which today has become an integral part of our work practice.

Electrical safety-related work practices are governed by different OSHA regulations for utilities and construction companies. Utilities follow 29 CFR 1910.269 and construction companies follow either 1926 Subpart K or 1926 Subpart V, depending on the job site. It wasn’t until the 1910.269 revisions in 2014 that OSHA used direct wording mandating arc-rated clothing. And while it may seem that five years is enough time to install an organization-wide PPE program, it is not uncommon to find such programs lacking. Recently, a utility’s operational team confirmed that they normally operate a piece of equipment while wearing street clothing. While this practice may not be a problem in certain limited cases, in this instance the garment labels prohibited any energized work based on the high arc flash energy. The problem was, these workers failed to realize that switching off is considered energized work. Serving as independent safety consultants to various construction companies and utilities has offered us a great deal of insight into similar hazardous operating conditions, but at the same time has allowed for testing and implementing what works in these environments. This article, the first in a two-part series, introduces the concepts of arc flash and shock hazards, followed by a discussion about personal protective equipment (PPE) that guards against those hazards. The second article in this series will provide guidance on how to effectively communicate the adequate level of protection to workers.

In my 40 years of electric utility experience, I have investigated and documented dozens of work-site incidents that required immediate emergency medical response from a crew. One pattern has become clear after debriefing workers who have rendered assistance at a scene: Workers who responded well to rescuing their co-workers used effective communication and competent delivery of job-site first aid, including CPR. Time and again, nearly all workers involved in successful emergency responses said, “I was just doing what I was trained to do.”

Looking back on the history of the electric utility industry, competent emergency responses have not always occurred. In the late 1970s through the early 1990s, the utility I worked for suffered a series of fatal and serious accidents. Most were electrical contacts, but the list also included arc thermal exposures, falls from poles and traffic accidents. With each incident, we learned about the value of providing appropriate emergency training for the work performed as well as the value of refining our annual emergency response training drills.