Incident Prevention Magazine

In our first article in this series (see https://incident-prevention.com/ip-articles/when-osha-electric-power-safety-standards-apply), we discussed how to apply OSHA’s electric power standards. This article will review OSHA 29 CFR 1910.269 and 1926 Subpart V training requirements relating to qualified and unqualified employees.

To determine training requirements, you must first ask the question, are my employees exposed to electric power system hazards? If so, the training portion of the OSHA electric power standards should apply.

OSHA requires all employees to be trained in the safety-related work practices, safety procedures and emergency procedures that pertain to their job assignments. This includes employees performing covered work, as discussed in the first article of this series, and employees who access areas restricted to qualified employees in order to perform nonelectrical work.

Examples of employees who access restricted areas include an employee spraying herbicide around underground enclosures, a warehouseman delivering substation equipment inside an energized substation, and a maintenance employee replacing “Danger” signs inside an energized substation. Each of these nonelectrical employees has potential electrical hazards and risks associated with their job tasks that must be identified. Unfortunately, nonelectrical employees are many times exposed to unknown electrical hazards, such as step and touch potentials they do not know exist, which emphasizes the importance of effective training.

Workplace safety requires each of us to do our part to keep ourselves and our co-workers free from injury and illness. To meet this goal, we must understand the tools we have and know how to use them. Let’s look at a lineman’s life, for example. He can climb poles, float through the air in a bucket, safely touch energized conductors, balance poles and transformers, and construct all of these items into a working system. The skills needed to accurately accomplish these tasks are a result of training and repetitive practice, but these skills are only partially responsible for the lineman’s success because the lineman is part of and works in a team. True success occurs when the team members who perform the dance are connected to each other.

How do team members connect with one another? You may not know it, but human beings have superhero powers that have evolved over thousands of years. And when we understand how to successfully tap into them, we can improve our connections with others and change outcomes. This article will identify three of your superpowers – reading minds, reasoning and looking into the future – and how to tap into them to improve safety on the job.

As we discovered in the first part of this two-part series (see https://incident-prevention.com/ip-articles/leading-change-through-faith-hope-and-tough-love-part-i), people are fallible, sometimes lessons aren’t learned, and improvements aren’t always made. This can leave leaders and team members feeling frustrated or apathetic because they don’t know how to right the ship. The simple truth is that your team should be able to succeed today and learn what they need to improve tomorrow. The simple solution is to speak from vision through faith and hope, and lead with tough love. However, simple rarely equals easy.

In the previous article, we discovered that if we have confident trust in our people, it leads to hope, which allows us to keep our current reality in proper perspective and stay future-focused – not yesterday-paralyzed. And with faith in our people solidified in our minds, we’re now free to focus on hope and tough love.

So, without further ado, let’s jump into the first part of the hope mindset.

All of us have experienced mishaps in our daily lives, both at home and at work. An accident typically is defined as an unwanted incident occurring unexpectedly and unintentionally, usually resulting in damage or injury.

In our work lives, proper training develops our mindset as well as our knowledge. Increasing our knowledge allows us to identify known hazards and to recognize unknown hazards. Training value is understood and incorporated into workplace law. OSHA’s General Duty Clause requires employers to furnish to each of their employees a workplace that is free from recognized hazards that cause or are likely to cause death or serious physical harm. In addition, each employee shall comply with OSHA rules, regulations and orders that are applicable to their own actions and conduct. We assure employees can follow the law by training them with the necessary knowledge and intangible tools to make them more effective.

The job hazard analysis or job briefing is an effective tool for identifying hazards. A job briefing is required by OSHA rules that employers and employees must abide by (see 29 CFR 1910.269(c) for general industry and 1926.952 for construction). The briefing is an intangible tool that uses recognition and reasoning through knowledge and experience. Here is where the human brain is leveraged to be successful. Guidance from OSHA requires that a job briefing discuss hazards associated with the job; the work procedures involved; special precautions; energy-source controls; and personal protective equipment requirements.

I perform audits of both utilities and contractors. When I work with them to do those audits, we include trucks and trailers. The trailers I’m talking about here are not the box vans behind tractors, but the general-duty trailers used to haul trenchers, backhoes, wire reels and padmount transformers. It’s no surprise that the trailer issues we discover are in keeping with the types and frequencies of violations that enforcement officials find on the roadways: those involving lights, load securement and brakes. Auditors also get a lot of questions about trailer safety, or more specifically, trailer rules, which are in place for trailer safety. I almost always receive those questions after an enforcement action has occurred.

Many enforcement actions have come about due to the efforts of states that have noticed trends in trailer-related incidents. The incidents didn’t involve semi-trailers pulled by tractors; they involved smaller trailers used in commercial environments where enforcement had not spent much focus. Without that focus, there was a lack of accountability, and now it’s caught up with us. States are enhancing their observations of commercial trailering, making stops and taking trailers out of service for numerous issues, most often related to brakes.

Over the years, I’ve received numerous questions about which duties lone workers can safely and legally perform, and which ones require more than one qualified worker to complete.

Tasks that require at least two qualified employees are defined in OSHA 29 CFR 1910.269(l)(2)(i), which states the following: “Except as provided in paragraph (l)(2)(ii) of this section, at least two employees shall be present while any employees perform the following types of work: installation, removal, or repair of lines energized at more than 600 volts; installation, removal, or repair of deenergized lines if an employee is exposed to contact with other parts energized at more than 600 volts; installation, removal, or repair of equipment, such as transformers, capacitors, and regulators, if an employee is exposed to contact with parts energized at more than 600 volts; work involving the use of mechanical equipment, other than insulated aerial lifts, near parts energized at more than 600 volts; and other work that exposes an employee to electrical hazards greater than, or equal to, the electrical hazards posed by operations listed specifically in paragraphs (l)(2)(i)(A) through (l)(2)(i)(D) of this section.”

Q: We don’t provide self-rescue equipment for lone workers, but we recently heard that OSHA is requiring self-rescue equipment as part of the General Duty Clause. Are you familiar with this?

A: This is a complex question, part of which might border on legal arguments. Incident Prevention relates legal opinions to our readers from case outcomes that we are familiar with, but in practice avoids rendering advice or opinions that may border on legal terms.

The rescue requirements in the OSHA rules do not address self-rescue. Many employers address self-rescue in part based on their interpretation of the training requirements found in OSHA 29 CFR 1910.269(a)(2)(i)(B) because of the language that states, “… 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.” However, the OSHA rules regarding rescue are crew-based rescue requirements and similar to those found in most provincial Canadian health and safety standards. OSHA has several rules regarding lone workers, but those references lack any requirements for self-rescue. It certainly could be that such language would be hard to address considering the numerous instances and types of work in which workers are alone across all industries.

If you have seen the movie “Kung Fu Panda,” you probably remember the powerful and inspiring moment when Po comes to the realization that there is no secret ingredient – it’s just him. He was all but unbeatable after that. Sometimes I also think about the secret sauce Michael Jordan gave his team at halftime in the movie “Space Jam,” so they could come back and defeat the Monstars.

But while we long for secret ingredients, magic sauces and silver bullets, the reality is that our jobs and lives are complex, with ever-changing roles and no exact road maps. Perhaps, in addition to Po’s wisdom, we should heed the words of Stephen R. Covey, who told us in his book “The 7 Habits of Highly Effective People,” “If I really want to improve my situation, I can work on the one thing over which I have control – myself.”

And that’s exactly what assessments are for, improving ourselves.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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