Incident Prevention Magazine

Cleanup of potentially hazardous materials and flammable contaminants can sometimes be a part of an electrical job. When workers arrive on a scene, they cannot always be sure of the exposures or contaminants they will face. In electrical work, it could be oil that contains a small number of PCBs. This oil, and other contaminants, is flammable and can affect the flame-resistant properties of garments until it is washed from the garments. Working around flammable contaminants, as well as flame and thermal hazards like arc flash potentials and flash fire potentials, often requires a PPE safety system that can be difficult to balance. Some workers may need chemical protection, flame protection or both. Secondary protection used in such circumstances, like disposable garments, can create a fast and effective way to decontaminate and clean a scene – by removal and disposal – without soiling or degrading the primary protection underneath. Because of this, disposables often are useful over daily wear. Many workers and managers assume that a chem suit is a chem suit and use the common polyester/polyethylene suits to cover their arc-rated/flame-resistant (AR/FR) gear. This can be a disaster if one of the suits ignites, melts and continues to burn, or if part of the suit becomes molten and melts onto a worker’s hands or face.

In the AR/FR PPE industry, however, disposable garments are few and far between, and the standards aren’t quite in place to help make the distinction between garments that are truly flame resistant in specific hazards versus marketing. The lightweight, thin materials typically can’t pass some of the harsh requirements set forth for garments to be used as primary materials. And even though most are not intended for primary protection, there are limited standards to guide manufacturers on appropriate tests and claims for these types of products. This is especially true for those needing multihazard protection in the outermost disposable garment. There are disposable garments on the market that boast protection from a variety of hazards, like blood-borne pathogens, dry particulates and chemicals. When flame resistance comes into play, there are even fewer options on the market.

How Far Have We Come?
Disposables have come a long way in the past few years, but we are still lacking in standards on the AR/FR side. Initially, polyester spunlace disposable garments were used for chemical protection, and they revolutionized the industry in providing secondary, fast protection that could be doffed and disposed of without concern of contamination of primary clothing; these products add extra protection to the worker at a low cost. Later, coated and sealed-seam garments on the chemical protection side were made to withstand even higher-level exposures, including chemical warfare, an unlikely scenario in the workplace. Disposables for chemical protection worked well for chemical hazards, but they were not adequate or intended for the risks from flash fires or electric arcs. Flame resistance of disposable garments still hadn’t been adequately addressed from a standards perspective, and there were misunderstandings in the market regarding FR PPE, including PPE intended to be disposable.

Outdoor workers – including lineworkers and communications technicians – routinely work in hazardous environments. Most of these hazards are well-recognized and understood by the workers and their management, but that is not always the case with cold-weather injuries, such as hypothermia and frostbite. Until workers receive specific and relevant training from medical professionals with cold-weather experience, they may lack the basic understanding of just how suddenly cold weather can kill.

Although there are numerous types of cold-weather injuries, this article will address the most common one: hypothermia, or the human body’s attempt to manage a drop in its core temperature. The core includes the brain, heart, lungs and neck. When managing body core temperatures, keep in mind that more blood flows closer to the skin in the neck than anywhere else in the human body.

Any drop in the temperature of the core blood will trigger a response from the hypothalamus in the brain, which is responsible for all body thermoregulation. The hypothalamus has three separate and unique methods that it will use, in sequence, to respond to a lowered core temperature, referred to as stage 1, stage 2 and stage 3. Failure to recognize the differences between the stages can immediately be fatal to a hypothermia victim.

The Three Stages
Stage 1 hypothermia occurs when the body’s core blood temperature first drops. The hypothalamus initiates two major responses to this temperature drop, only one of which the victim is aware. The first response is the hypothalamus triggering the major muscle groups – those in the arms, legs and face – to shiver. This is mild at first but then progresses to severe and uncontrollable shivering. The second response, which the victim is unaware of, is the brain triggering the release of larger quantities of sugars and insulin into the bloodstream. This is necessary to support the hard muscular work involved in shivering.

The utility industry has high expectations for employing safe work practices and readily invests in equipment and training. Maintaining a workforce with the right skills is a herculean task. Crane operation and rigging skills development presents greater challenges than some other areas because these skill sets typically are not part of the routine work schedule. Individuals with crane operator certification may have fewer than 100 hours of actual operating time in a year, or go more than a year with no seat time or hands-on practice time.

OSHA requires employers to ensure that crane operators are trained and competent without exclusion for any industry. Even while safe crane operation and rigging are critical to utilities, the lack of seat time and skills maintenance is a growing concern among utility safety departments. A strategic approach to developing those skills across business units is essential to maintaining the industry’s above-average safety record.

However, utilities, like most large, complex organizations, battle the 5 C’s: complex corporate culture causing complications. Different groups within the utility may, out of necessity or for other reasons, operate as silos, with little shared knowledge or resources. Construction groups, T&D and emergency response crews have different needs when it comes to crane operation skill levels. The differences between operating boom trucks or digger derricks and large telescopic or lattice boom cranes must be recognized when training individuals for typical or emergency response work environments. Yet the reality of maintaining skill levels may require staff and budget that conflict on the surface with corporate cultures that thrive on efficiencies.

To maintain qualifications in the various areas of responsibilities, utilities need to plan for and schedule practice time with cranes and rigging to reinforce and verify skill ability. Relying on a weeklong refresher training course once every five years is not sufficient for retaining competent crane operation skills.

Some utilities – including electric, cable and communications providers – have had both underground and overhead applications for many years. However, more and more of these utilities now are either primarily installing their services underground or relocating overhead services underground, for a variety of reasons. These include reliability and protection from weather conditions, as well as minimizing exposure to equipment, vehicular traffic and farming operations. In addition to these safety concerns, utilities are installing services underground due to customer requests to improve the general appearance of the communities served by the utilities.

There are many beneficial reasons to install services underground, but there also are some downsides. Among them is the risk of personnel exposure to hazards when improper excavation practices are used. It is critical to adhere to OSHA 29 CFR 1926 Subpart P excavation practices as well as 811 and Dig Safe procedures. Another risk associated with underground facilities is that they often incorporate vaults or manholes that may be classified either as confined spaces or permit-required confined spaces. In either case, there are a number of safety concerns for which OSHA has implemented specific regulations that must be enforced to keep employees safe while working in these areas.

Safety should always be No. 1 on any job site. OSHA 1910.269(a)(2) states that all employees shall be trained in and familiar with the safety-related work practices, safety procedures and other safety requirements that pertain to their respective job duties. The agency goes on to say that employees who work in and around manholes must be trained on manhole rescue each year in order to demonstrate task proficiency. Proper documentation should be completed for the manhole training, as with any other training. The standard also states that the employee in charge shall conduct a job briefing or tailgate with all employees involved before the start of each job. At a minimum, the briefing should address the five areas required by the OSHA standard: hazards associated with the job, special precautions, energy-source controls, work procedures involved and personal protective equipment requirements.

It was a little over 40 years ago that a Vietnam veteran helicopter pilot in Florida made the first live-line contact with a live transmission circuit, bringing a quantum leap for power-line applications using helicopter methods. The FAA regulates what they call “rotorcraft” work with specific qualifications for pilots, flight crews and the airships and auxiliary equipment used.

Many utilities and contractors think helicopters – or HCs, in flyers’ lingo – are for use on difficult projects because of the expense. But I have been working with contractors for the last 15 years who recognize the value of HCs in construction and use them as often as possible. An hour of HC time may cost the same as the monthly rental of a bucket truck, but when you can clip, space, dame and ball 20 times the structures in a day over bucket access, the expense really makes sense. I also am aware that some contractors and utilities think HC use raises risk. I know that some utility clients prohibit HCs on their properties while others actively assist their contractors by prequalifying HC companies.

The primary use of HCs has been to string rope or, in some cases, hard-line for pulling wire in transmission construction using HC blocks. These blocks are equipped with a spring-loaded gate at the top of the frame. The gate has extensions that guide the rope into the sheave, provided the pilot is good enough. It looks easier than it is. Since Mike Kurtgis of USA Airmobile put his ship on a hot line in Florida, skid and rope-suspended work, inspection and insulator washing have continued to advance as accepted work practices. The FAA refers to working from a skid or rope (short haul) as “human external load,” or HEL. By some it is called the most dangerous work method in the line industry. In fact, even the FAA has a sense of humor about it, as noted in their wording of a safety requirement in the HEL rules. In guidance document FSIMS 8900.1, Vol. 3, Ch. 51, the FAA provides examples of the types of persons that can be carried on an HC skid – they include movie camera operators and clowns as two of those examples. We always assumed that the lineman with the nerve to work from the skid was not the camera operator.

Over the next few installments of “Voice of Experience,” I’ll be reviewing some accidents that have taken place in the electric utility industry. I’ve had many requests for information about incident investigations and would like to share some details in hopes of preventing similar accidents in the future. Distribution cover-up will be the focus for this issue’s column.

Approximately half – or even more – of accidents that result in flashes and electrical contacts are the result of poor cover-up or total lack of rated protective cover. Why would a lineworker not take the time to install protective cover that would assure a safe work area? According to statistics and accident reports, the industry suffers an average of one contact or flash every week. That needs to stop.

Investigations into many accidents, some of which involved fatal contact with system or source voltages, have revealed that failure to cover up all differences of potential in the immediate work area was the common denominator in most flashes and contacts. If you are or your company is following the minimum requirements found in OSHA 29 CFR 1910.269(l), “Working on or near exposed energized parts,” it is simply not enough to ensure an employee is totally protected from differences of potential in the work area.

The human body essentially is a 1,000-ohm resistor in an electrical circuit. When a lineworker fails to cover energized parts as well as differences of potential in the immediate work area, as little as a 50-volt AC electrical source may enter the body. If the current path crosses the heart, as few as 40 to 50 milliamps can induce atrial fibrillation, cause the heart to stop sinus rhythm and electrocute the worker. The industry is quite familiar with medium-voltage contacts but many times lacks respect for low-voltage contacts that can be just as fatal.

Q: We have gotten mixed advice from our colleagues at other utilities and can’t decide whether or not civil workers digging a foundation by hand in a hot substation should be required to wear arc protective clothing. They are inside the fence but in a new area approximately 20 feet from the nearest distribution structure. Where do we find the requirements or OSHA guidance?

A: That depends. Sometimes it depends on the criteria in the statutes, and sometimes it depends on compliance with company policy. Normally, following the guidelines of OSHA 29 CFR 1910.269(l)(8) – which establish the criteria for arc flash protection – excavation in a substation would not produce the type of work exposure you described that could create an arc flash. The location of the work and the type of work would not bring a worker within any distance of an energized bus or apparatus that would be a threat. If that’s the case, there would not be a requirement for arc-rated clothing for civil workers in a substation.

We are aware that there are utilities that require all workers, no matter what their craft or task is, to wear arc flash protective shirts while in a substation because it’s a company policy. But in regard to your question, it’s all about exposure. No exposure, no requirement for shirts. It is obvious that it’s not quite that simple for policymakers and risk analysts, who often are the people who make these decisions. Utilities must decide how to protect employees, protect the company and comply with the standards. That goal sometimes results in a blanket requirement as opposed to writing detailed criteria for when workers must suit up. The rules held by some utilities raise this question: If workers must wear arc-rated shirts, why don’t they have to wear arc-rated face protection? In fact, most of the inquiries we’ve made would seem to indicate the decision to require arc protective clothing in substations is more about gut response to the spirit of arc flash protection for contractors and employees than the result of arc flash analysis. Processes and knowledge are still expanding in the industry. As most would say, it doesn’t hurt for civil workers to wear arc protective shirts unless there is an unacceptable heat stress factor involved. In fact, there are some pretty lightweight pullover tees in Cat 2 that may help relieve both arc flash and heat stress.

Imagine this scenario: A worker seriously cuts his nose on the job. The laceration causes part of his nose, at the base of the nostril, to partially separate from his face. The worker glues his nose back together with super glue to prevent going to the doctor and having an OSHA-recordable injury. He then receives two rewards through the company’s safety incentive program. The first is an immediate reward when his supervisor recommends him for safety excellence because he prevented a recordable injury. This is followed by a financial incentive at the end of the year, when his work group is given a bonus for not having a recordable injury during the calendar year.

Here’s another scenario to consider: An employee is stopped at an intersection and gets rear-ended by another vehicle hard enough that he is taken to the emergency room and receives medical treatment. Pursuant to 29 CFR 1904, “Recording and Reporting Occupational Injuries and Illness,” this is determined to be a new, work-related case that meets the general recording criteria and therefore is a recordable injury. Because he had a recordable injury, this employee is not invited to attend the company’s annual safety awards dinner, where prizes such as televisions and all-expenses-paid vacations are raffled and given away. Note: OSHA prohibits employer retaliation for reporting an injury (see 1904.35 and 1904.36) and will not allow employers that offer financial incentive programs to participate in their Voluntary Protection Programs.

Incentivize Desired Performance
Both scenarios are unfortunate and too common in the workplace. Organizations need to be aware that the absence of injury does not necessarily indicate the presence of safety. With that in mind, they must stop programs that incentivize results and instead focus on performance, which is the combination of behaviors and results. The guiding principle behind any incentive program, coaching or feedback should be to never reward results or punish someone without understanding the behavior driving the results. Get the desired behaviors and the results will take care of themselves.

Once upon a time, there was a construction company that did great work. The employees delivered their projects on time without change orders, and they completed them without harming people or the environment. All their happy clients gave them more and more work, which the company gladly accepted, believing that surely the fairy tale would continue. But then the company discovered that this rapid growth had spread them so thin that their production, safety and environmental quality had faded away. This moved them from best to worst in the eyes of their clients, and the company almost went bankrupt due to injuries, lawsuits and loss of contracts. The end.  

Not all stories have a happy ending. And many of you well know that the current project-load reality in the utility construction industry certainly isn’t a fairy tale. However, there still can be a positive outcome for your company – even in extreme growth cycles – if you and your leaders master the skills of operational assessment and communication.

Earlier this year I ran Supreme Industries’ numbers and found that our work hours were up 56 percent over the same period last year (January-May). I was shocked – not because of the rapid growth, but because I didn’t receive any warning signals from our safety scoreboard. Don’t get me wrong, I knew things were busy, but other than the fact that I was ordering a lot more health, safety and environmental (HSE) supplies than last year, I didn’t see the magnitude of our growth in my daily life. But why didn’t I?

Flashback three years: I’m sitting with Nate Boucher, Supreme Industries’ vice president of civil and drilling, and Gavin Boucher, vice president of clearing and operations, and Nate says, “Jesse, our field leadership wants more professional development. We’ve done ‘StrengthsFinder 2.0’ and ‘Emotional Intelligence,’ but what’s next? We believe our divisions are going to be growing for the foreseeable future. Gavin and I are taking care of equipment and infrastructure planning, but we want you to prepare our field leaders professionally for what’s coming.” After that conversation, I took some time to outline what we needed to do in terms of future professional development.

Getting back to the present day, I believe the conversation I had with Nate and Gavin three years ago plus the actions we took after the conversation was over are the reasons why I didn’t notice a rapid growth cycle on our safety scoreboard earlier this year.

In the electric utility business, we have highly trained employees who are proud that they have learned the skills to be able to safely work around high voltage. However, a phrase we hear too often is “Hey, it’s only secondary,” which implies that secondary is not as hazardous as primary, lightning or fault current. We’re not going to debate that in this article, but we are going to discuss – and bust – some common myths about working with 120-volt circuitry and equipment, as well as myths regarding lightning and fault current exposure.

Myth 1: Circuit breakers are better than fuses.
If you utter this statement and are merely talking about convenience, you may have a cogent argument, but convenience does not outweigh safety. If you are merely talking about cost, you may again have a cogent argument, but the cost argument doesn’t win when it comes to safety because how do you put a price on a human life?

So, why might a fuse be better than a circuit breaker? All fuse manufacturer representatives will assure you that fuses in general operate faster than breakers. They may operate in less than a quarter of a cycle compared to three to four cycles for many circuit breakers. If you are in series or parallel with fault current flow, you literally are being cooked from the inside out. Reducing the amount of time the circuit is allowed to operate is a better protection strategy than allowing current flow to go on longer. Additionally, fuses typically are better at interrupting an avalanche of fault current from an incoming service. Breakers and fuses have maximum amp interruption capacity ratings, meaning if a breaker or fuse is installed on a circuit with a higher fault current capability than the breaker, the breaker or fuse can simply melt or arc across and fail to operate. The least-protective fuse interrupts 10,000 amperes of incoming energy, while a typical branch circuit breaker interrupts 5,000 amperes.

Myth 2: If you turn on a light switch with wet hands, you will get electrocuted.
While there is a possibility you might get electrocuted, you probably will not. That’s not to say you won’t get shocked; you must understand the difference between shock and electrocution. A shock occurs anytime current flows through your body, via any path, for any duration and at any magnitude. Electrocution is a shock that kills you by interfering with bodily processes. It only takes as little as 50 milliamps to send an adult heart into ventricular fibrillation; death is imminent within four to six minutes of ventricular fibrillation.

Another definition also is useful here: Fault current is current flowing anywhere you don’t want it to flow, especially through you. Fault current can flow in parallel or in series with normal current flow, or with the load. You don’t want to be in the path of fault current. Fortunately, the likelihood of being in a fault current path while operating a modern plastic switch, even with wet hands, is very low. Even lower is the likelihood of electrocution from the event.

Ergonomic safety has had a profound impact on the utility industry over the last decade, without many workers even knowing it. Yet as professional tool ergonomists, we have seen many erroneous “ergonomic” product claims over the years, so in this article we want to highlight the importance of knowing how ergonomic products are measured and if the tools you’re using are truly advancing ergonomics at your company.

Before we dive into the technical aspects of ergonomic measurements, let’s review some background information. OSHA continues to define line work as a high-risk occupation in terms of the risks of electrocution, falls and human error, but also in terms of risks for musculoskeletal disorders and ergonomic injuries. The agency has gone so far as to say that one in three injuries is an ergonomic injury. Examples of these injuries include carpal tunnel syndrome, rotator cuff tendinitis, elbow epicondylitis (tennis elbow) and trigger finger tendinitis.

These injuries translate into an incredible number of dollars spent by employers. According to the 2017 Liberty Mutual Workplace Safety Index, U.S. businesses spend more than a billion dollars a week on serious, nonfatal workplace injuries. Of the billion dollars a week, over 20 percent of the injuries – which account for nearly $14 billion a year – are directly attributed to overexertion involving outside sources.

Objectively Measuring Ergonomics
Based on the information presented above, it’s clear that quality workplace ergonomics are good for both employee health and an employer’s bottom line. But while almost every tool manufacturer talks about ergonomics, are their claims about ergonomics true or just a marketing stunt? It’s important to understand how a company tests their products prior to purchasing them. The truth is that some tool manufacturers have not measured ergonomics at all, some outsource the measurement process and some do partial measurements but don’t perform the complete process. At Milwaukee Tool, not only do we conduct measurements in-house, but we also have teams of subject matter experts who implement ergonomic designs into the tools utilities use every day.

Objectively measuring ergonomics is a very precise task. Some ergonomic risk factors to look for in your tools are high levels of noise, vibration and required force. While some exposure to these risk factors isn’t necessarily hazardous, exposure to high thresholds of these categories puts workers at serious risk for eardrum damage, vibration-induced white fingers, trigger finger tendinitis and carpal tunnel syndrome, among others. 

Rope has always been at the core of many operations and is the principal means of removing an injured person from a structure or manhole. In recent years, labor laws have revised and expanded expectations, particularly for worker fall protection on towers. The quest for methods to accommodate these rules has created opportunities for new applications of rope techniques, introducing wider use of rope access and rope descent technologies into the line industry.

Rope access describes rope-use techniques that have evolved from centuries-old rope applications incorporating maritime, construction and, in particular, mountain climbing or controlled descent methods. In the firefighting world, rescue using rope is referred to as “high-angle” or “technical” rescue. Rope access has been used for centuries in construction, and most readers today are familiar with scenes of lumberjacks, wind energy blade inspections, and dam and bridge inspectors suspended over the sides of structures.

In the line trade, we traditionally think of rope in terms of its use as a handline, which, in the event of an emergency, doubles as a rescue line. This rescue technique is still as relevant now as it was in the late 19th century, as the idea to plan your rescues is not a new one. Any differences between rope rescue today and rope rescue in the early days of power lines are primarily due to technological advances. One example of these advances is Buckingham Manufacturing Co.’s OX BLOCK, which is used for hurt-man rescue and self-rescue, as well as lowering, raising and snubbing loads.

To the employer researching rope access and controlled descent techniques for workers, it is important that line personnel be involved in the research process so that the techniques, tools and training that are adopted effectively match the needs of the workplace. Keep in mind that rope access is not a substitute for all work tasks – it is simply another tool. Both training and research are critical for employers and employees considering rope access techniques; this includes the review and assessment of tools and other items currently available on the market, including rescue-rated blocks and property-rated handlines.

Lately there has been a rash of incidents involving flashes and contacts with primary voltage. The incidents occurred due to improperly written switching orders or missed switching steps, none of which were recognized by the workers involved with the tasks. These types of errors have long been a problem and continue to result in numerous injuries and fatalities.  

In April 2014, OSHA’s revised 29 CFR 1910.269 standard was published. This was the first revision to the standard in 20 years, and one paragraph in particular that was clarified was paragraph (m), “Deenergizing lines and equipment for employee protection,” which addresses system operations. As of the OSHA update, the employer is now obligated to appoint an employee to be in charge of the clearance issued by the system operator; this employee will have control over and oversight of all switching that affects the performance of the system.  

Specifically, OSHA has promulgated the following rules.  

1910.269(m)(2)(i)
If a system operator is in charge of the lines or equipment and their means of disconnection, the employer shall designate one employee in the crew to be in charge of the clearance and shall comply with all of the requirements of paragraph (m)(3) of this section in the order specified. 

1910.269(m)(3)(ii)
The employer shall ensure that all switches, disconnectors, jumpers, taps, and other means through which known sources of electric energy may be supplied to the particular lines and equipment to be deenergized are open. The employer shall render such means inoperable, unless its design does not so permit, and then ensure that such means are tagged to indicate that employees are at work. 

Electric utilities must establish a clearance – also referred to as an “open air gap” – on all known sources of the system and source voltages. A clearance also should be used to disable all automatic switchgear to ensure that all system voltage has been isolated from the work area. This procedure is regulatory language and required to protect employees. Tags shall be applied to all open points to indicate that employees are at work and nothing shall be re-energized.

Q: We are a contractor and were recently working in a manhole with live primary cables running through it. We were cited in an audit by a client’s safety team for not having our people in the manhole tied off to rescue lines. We had a tripod up and a winch ready for the three workers inside. What did we miss?

A: This question has come up occasionally, and it’s usually a matter of misunderstanding the OSHA regulations. The latest revision of the rule has modified the language, but following is the relevant regulation. Look for the phrases “safe work practices,” “safe rescue” and “enclosed space.”

1910.269(e)(1)
Safe work practices. The employer shall ensure the use of safe work practices for entry into, and work in, enclosed spaces and for rescue of employees from such spaces.

1910.269(e)(2)
Training. Each employee who enters an enclosed space or who serves as an attendant shall be trained in the hazards of enclosed-space entry, in enclosed-space entry procedures, and in enclosed-space rescue procedures.

1910.269(e)(3)
Rescue equipment. Employers shall provide equipment to ensure the prompt and safe rescue of employees from the enclosed space.

This rule deals with enclosed spaces, not other spaces referenced in 29 CFR 1910.269(t), “Underground electrical installations.” Enclosed spaces are not, as many think, spaces with energized cables inside. In fact, the definition of an enclosed space has no mention of energized cables. What it does have is the single criterion for an enclosed space: Under normal conditions, it does not contain a hazardous atmosphere, but it may contain a hazardous atmosphere under abnormal conditions.

If you were in a cave and someone yelled “Watch out for that stalagmite!” would you look up or down? If you said down, you are correct. Both stalagmites and stalactites are formed in caves by mineral deposits from trickling water. Stalactites result from water dripping from the ceiling. They hang down, typically are hollow, have smaller bases and form faster than their counterparts. Stalagmites are built from the ground up when water drips on the cave floor. They have a more solid structure with a larger base that takes more time to form.

This imagery is useful when contemplating and discussing organizational culture. Does your company have a top-down (stalactite) or bottom-up (stalagmite) culture? As you think about your answer, consider how your organization handles the following occurrences.

Occurrence 1: Change
Stalactite: The company is reactive and changes only because they have to due to incidents or regulatory reasons. Management creates or revises programs and policies that are implemented during lecture-style training sessions conducted per organizational hierarchy. Employees have no or very limited opportunities to ask questions or provide feedback about the change.

Stalagmite: The company is proactive and changes because they want to. Leaders anticipate the need for change. Frontline workers are involved in creating or revising programs and policies that are implemented during training sessions, and they encourage questions and feedback from safety leaders, safety advocates and change agents.

The agitation of the managers sitting in the meeting room is palpable. The safety director sits stiffly at the conference table. Everyone is overwhelmed by a hurricane of thoughts. "We did everything we could, right?" Conjectures whirl. Voices surge. "We've spent the last three years installing a safety management system to keep this sort of thing from happening. It was textbook!”

These leaders wonder to themselves, “Did I do something that led to this?" But soul-searching eventually gives way to frustration as a voice stands out in the room: "What were they thinking out there?"

People grab hold of these words and their implication – that the incident occurred because a handful of people in the field did something wrong. It seems a simple matter of fact that explains what happened and points to what must be done next. "We will review our policies, retrain everyone, hold people accountable and get rid of those we can't trust." And it works … until the next storm blows in.

This scenario has played out countless times, with an array of casts and in the aftermath of many different kinds of events. Some are small-scale events, like an employee failing to lock out equipment before servicing it. Others are catastrophic events, like an exploding chemical plant.

My colleagues at The RAD Group and I propose that the thought process represented here is a trap, and one that people at all levels of an organization can fall into quite naturally. We call it the “human error trap,” and when organizations become ensnared, they find themselves unwittingly stuck in a status quo of safety.

Electric utility workers face complex, high-risk electrical hazards nearly every day. Information about shock hazards – which may come from impressed voltage, residual energy, induction, objectionable current flow in a grounding system or stored energy – has been taught to many of us for quite some time, as have the methods of assessing them.

On the other hand, arc flash hazard assessments are still relatively new to us. In the past, most of us knew that an arc flash could potentially occur during the course of performing our tasks, but the level of the flash and the PPE requirements – other than wearing 100 percent cotton – were not seriously considered in our day-to-day activities until approximately 15 to 20 years ago. To provide more concrete guidelines, OSHA published new regulations in April 2014, with more recent enforcement dates. Instead of making a best guess about PPE, the industry now has a reasonable approach to providing adequate PPE for utility employees who are tasked with performing open-air work. Once a utility completes the required arc flash analysis, develops a policy based on the analysis results and adequately conducts training for affected field personnel, the job of assessing risk and determining PPE levels can easily be incorporated into the daily job briefing. The goal is to make the assessment data easy to access and understand in order to provide effective protection for all workers.

Causes and Severity Levels of Arc Flash Events
An arc flash is the result of either a short circuit during which two energized parts of different potentials (phases) make contact, or a ground fault where an energized part and a grounded conductive part of a different potential make contact. An arc flash event may be caused by a failure of electrical apparatus, potentially due to lack of maintenance, or by worker error, perhaps due to an employee moving conductive parts near energized parts or leaving conductive tools in an energized work area. It’s important to note that differences in potential must always be effectively isolated by distance (air) or insulated barriers.

The growth of the wind energy generation industry in the U.S. has been phenomenal. According to the American Wind Energy Association, at the end of 2016 there were over 52,000 utility-grade wind turbines operational in more than 40 states, with a total capacity of 83,000 megawatts. The Global Wind Energy Council’s latest report shows that the U.S. has the second-largest wind power capacity, after China, with 16.9 percent of the world total, and employs over 100,000 people directly or indirectly. As the number of wind turbine towers grows, so does the number of people involved in their maintenance and repair. In 2015, the U.S. Bureau of Labor Statistics projected that employment of wind turbine service technicians would grow 108 percent between 2014 and 2024. There were approximately 4,400 wind turbine service technician jobs as of 2014.

Wind turbine tower heights also are increasing, with the tallest tower currently in the U.S. measuring 379 feet hub height, and even taller towers have been installed elsewhere in the world. While some towers are outfitted with service lifts, in the majority of towers personnel must climb fixed ladders to perform both routine and unusual operations. The increasing numbers and heights of towers mean more workers climbing ever greater distances.

Research studies conducted at the University of Wisconsin-Milwaukee (UWM) that have specifically investigated the renewable energy sector, including wind power generation, along with data from OSHA and the Bureau of Labor Statistics, have identified multiple risks to workers as a result of climbing fixed ladders. Strains and sprains, falls, overexertion and even fatalities were reported to be possible direct consequences of climbing and working at heights during both the construction and maintenance of wind turbines. Indirect risks also were identified, including potentially being electrocuted from contact with high-voltage cables and being struck by an object or caught between objects. Although power generation injury statistics are not separated by fuel source, 2015 Bureau of Labor Statistics’ data indicates that there were three fatal falls in the power generation industry, and 550 falls with nonfatal injuries. Data from the United Kingdom shows 163 total accidents in the wind power industry in 2016, including five fatal accidents. This data generally is assumed to vastly underreport the actual numbers, which may be 10 times higher.

A number of years ago I investigated a pole-top flash that took place during a transfer. The flash occurred when an improperly installed blanket left a dead-end flange exposed on the backside of the metal pole-top. During untying, the tie-wire contacted the exposed flange. No one was hurt. The issue was the lineman’s selection and installation of the blanket. The foreman assumed the lineman was experienced and competent to perform the three-phase transfer with minimal instruction. The problem was the lineman had spent the last several years on a service truck, had little transfer experience and had never worked a steel distribution pole. The foreman’s assumption was based on the fact that the lineman came from the IBEW hall. Even though they had never met, he assumed the lineman was sufficiently experienced – and so the root cause for the incident was established.

Training and verification of training for new, already-trained employees is another subject that has caused headaches for those professionals charged with OSHA training compliance and the employer liability that goes with it. OSHA, just like CanOSH, the agency’s Canadian counterpart, knows that training plays a huge role in incident prevention. It should be obvious that training prevents incidents, but the investigation of incidents across the continent proves that is not so. I have long said that the quality of your safety program and all of the component procedures, rules and policies that go with it, no matter how innovative and well-written, are only as good as the training you provide to the workforce. A safety program is supposed to protect the workforce first and the employer second. How can that happen if the workforce doesn’t know what’s in the program? And if the workforce doesn’t know what’s in the program, how does the employer expect the safety program to protect the employer?

The revised OSHA 29 CFR 1910.269 standard has now been in place for three years. In making the revisions, OSHA replaced older, passive language that left much to be understood with more objective language that clarifies the meaning and intent of the regulation. The standard is now easier to understand and sets the expectations for employers and employees.

There were some major changes made to the standard, as we all know. Several more subtle changes also were included and have been discussed much less, but they still have had a significant impact on the regulation. In this installment of “Voice of Experience,” I want to focus on one of these more subtle changes that I believe has a tremendous effect on the training requirements found in 1910.269(a)(2). The 1910.269 standard published in 1994 was straightforward, describing what was required in order for an employer to determine that an employee was a qualified worker. By and large, the industry believed that if an employee had the required training, he or she could be determined to be qualified. Now, per paragraph 1910.269(a)(2) of the revised 2014 standard, all employees performing work covered by the section shall be trained as follows:
• Each employee shall be trained in, and familiar with, the safety-related work practices, safety procedures, and other safety requirements in this section that pertain to his or her job assignments. (1910.269(a)(2)(i)(A))
• Each employee shall also be trained in and familiar with any other safety practices, including applicable emergency procedures (such as pole-top and manhole rescue), that are not specifically addressed by this section but that are related to his or her work and are necessary for his or her safety. (1910.269(a)(2)(i)(B))
• The degree of training shall be determined by the risk to the employee for the hazard involved. (1910.269(a)(2)(i)(C))