Incident Prevention Magazine

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.

The date was January 28, 1986. The event was the tenth and final flight of the Space Shuttle Challenger. Seventy-three seconds into flight, the booster rocket that was lifting Challenger into space exploded, killing all seven astronauts aboard.

When events like the Challenger explosion happen, you never forget where you were at the time. You remember the iconic photos and the national days of mourning for those lost. After the Challenger explosion, President Reagan appointed the Rogers Commission to investigate the disaster, and some of you may remember the news commentary on the Rogers Commission Report. If you didn’t study the reports from the incident, you likely aren’t aware of the stunning findings, the changes that were called for and, even more importantly, the effect the changes at NASA have had on industry – including the utility industry. It’s worth taking a look. You can read about lessons learned from the incident at https://ocw.mit.edu/courses/aeronautics-and-astronautics/16-891j-space-policy-seminar-spring-2003/readings/challengerlessons.pdf.

Many industries use bucket trucks to help workers accomplish tasks. In the electric utility industry, we use bucket trucks – often referred to as insulated aerial devices – to help maintain and improve productivity and safety. The trucks are the most reliable when all of the manufacturer’s recommendations are followed and routine maintenance is performed. Manufacturing performance standards for insulated aerial devices can be found at ANSI A92.2 and OSHA 29 CFR 1910.67.

I have performed fields audits for many companies over the years, and I want to share some facts about operational safety and proper use of insulated aerial devices. It’s critical for every company to have documentation that sets expectations for all employees about the safe and proper use of bucket trucks.

Q: Are utilities required to have a written fall protection program that follows a written hazard analysis?

A: It’s not a bad idea because the process assures a fairly complete assessment of fall risks that makes training and protection of workers more effective. We know the source of your confusion because it’s a question we get often, and we’ve looked into it. It takes some deciphering, but here is how the confusion starts. We often hear of power and telcom companies reading OSHA 29 CFR 1910 Subpart D, “Walking-Working Surfaces”; seeing 1910.28, “Duty to have fall protection and falling object protection”; and begin writing complex compliance programs following the Walking-Working Surfaces rule. There is nothing wrong with a robust hazard analysis program that drives training, but if you are doing it to comply with a standard, you may not need to. If you read closely, you will find an exception for both telcom (see 1910.28(a)(2)(vi)) and electric power transmission and distribution (see 1910.28(a)(2)(vii)). The T&D exception relies on compliance with 1910.269(g)(2)(i).

This series of articles began with “Developing a Complete Definition of Leadership” (see https://incident-prevention.com/ip-articles/frontline-fundamentals-developing-a-complete-definition), in which I defined leadership as influence and discussed how the measure of a leader is the performance of their team. We also talked about the fact that many leaders in our industry came up through the ranks in a culture of autocratic leadership and that many people in leadership positions never received any leadership training. That has led to leadership being incompletely defined as telling people what to do and threatening them with consequences if they don’t comply.

That bears repeating: It is an incomplete definition of leadership – not an incorrect definition.

Utility fleets today have access to a wide variety of valuable data from sources including telematics systems, motor vehicle records and crash statistics, all of which track drivers’ actions behind the wheel. With the vast amount of information available and the efficiency technology offers, it can be tempting to believe instilling safe driving behaviors in your organization’s drivers can be turned into an automated process.

The truth is that you can robotize behavioral change to a certain extent, but if you are using only automated processes, don’t expect them to make any true, long-lasting change. At best you will achieve the most basic level of driver compliance because in this scenario, the driver is not integral to the process but rather just the object of it. And as soon as you pull the plug on any technological monitoring of drivers, expect that evidence of risky driving habits will likely resurface in your next round of risk management reports.

The growing lure to rely almost exclusively on data inputs for managing safety – without including personal and direct involvement from the very drivers you expect to influence – creates a barrier to meaningful progress. It’s one that essentially positions drivers on one side as a problem to be controlled and management on the other side commanding that the drivers comply with the rules. This impersonal approach could lead to more severe incidents and higher crash rates in the future, which could mean increased injuries, fatalities, and revenue loss resulting from payouts and repair costs.

“Safety” is a word many of use daily in our line of work. Within our organizations, we have safety manuals, safety procedures, safety meetings and even entire safety departments. But I often wonder how many times workers have truly considered the question, “What does safety mean to me?”

Safety is “the condition of being safe from undergoing or causing hurt, injury or loss,” as defined by Merriam-Webster. If you were to come up with your own definition of safety, what would it be? Some common responses I’ve heard include having the ability to go home at the end of each day, not getting injured and following all of the rules.

Whatever their definition of safety happens to be, most people don’t head to work each day planning to get hurt – but it does happen. And the reasons why often reflect the safety culture of the workplace. Relatedly, how an organization’s leadership team defines safety has an enormous impact on the company safety culture.

People are affected by gravity at every moment of their existence. There is an ongoing struggle between this planet, which never stops trying to pull things to its center, and humans who are trying not to be overcome by the pull. In the battle against gravity, humans rely on balance, coordination, traction and decision-making. In work environments, employers are responsible for managing hazards; reducing or eliminating hazards that could cause slips, trips and falls; training employees; and investigating incidents to prevent recurrence. The remainder of this article will focus on the investigation and documentation of slips, trips and falls in the utility work environment.

Terminology and Goal
Clear definitions help guide us to clear outcomes, improved safety and reduced risk. People may refer to “slipstripsandfalls” as a single thing, but they are each distinctly different. Slips, trips and falls can occur alone or in combination.

The employer’s goal is to reduce risk of injuries and incidents by maintaining clean, dry, well-lit workplace walking surfaces with appropriate traction that matches the user’s expectations; managing footwear; eliminating trip hazards; avoiding slippery contamination; and training workers. 

At some point, you most likely have heard a co-worker say, “Alright, it’s time for the safety meeting.” Immediately after that, you typically have heard grumbling from other co-workers who were not looking forward to a meeting they believed would be slow and painful. If you’re a safety trainer, you’re probably somewhat familiar with this response and routinely wonder, “What can I do to make my safety training sessions both informative and enjoyable?”

While there is no magical solution or formula, there are a few strategies that trainers can use that will allow trainings to become valuable events that engage trainees and deliver meaningful content.