Incident Prevention Magazine

Recently my teammates and I were given the opportunity to evaluate the safety programs of a cross-section of contractors conducting potentially hazardous work for a large utility. It was our goal to help those contractors identify the vulnerabilities of their safety strategies and to help them become even more reliable partners to the utilities they serve.

In my line of work, I am often asked what commonalities I see among the most effective safety programs. The temptation is to think that bigger is better, or that world-class safety requires an enormous investment of resources. I wrote this article to dispel some of those notions, and to let smaller contractors know that they, too, can have highly reliable safety programs without huge investments.

Following are five principles my teammates and I have observed in every effective safety program we have evaluated. Please note that none of the following ideas are originally mine. I am indebted to my team and the contractors with whom I have worked. The ideas are theirs, and so the credit must be as well.

Do you have a safety culture that focuses solely on safety compliance and the use of personal protective equipment? If so, you probably also have the dreaded Compliance Grungs, which can secrete poisons throughout your organizational safety culture.

What exactly are Compliance Grungs, and how do deadly creatures relate to anything associated with safety? Deadly creatures kill, destroy, and cause suffering and pain. They wreak havoc and generate a great deal of harm. Individuals who work for organizations that promote safety only as a rule or compliance issue may experience similar phenomena without understanding why their safety culture is suffering.

To put it simply, Compliance Grungs are rules, policies or procedures that are considered more important than their application. They destroy a culture by promoting safety as a rule instead of a personal value, thereby strongly devaluing the importance of safety. Statements like “They don’t care about me,” “Management only wants to cover their own behinds” and “That rule is so dumb – they don’t know anything about our work” are sure indicators that you are suffering from an invasion of Compliance Grungs.

The Missouri Valley Line Constructors Apprenticeship and Training Program has supplied a steady stream of qualified workers to the electrical industry of the American Midwest since the mid-1960s.

Operating out of seven locations in Iowa, Minnesota, Missouri, Nebraska, North Dakota, South Dakota and Wisconsin, Missouri Valley Line Constructors has approximately 600 apprentices enrolled in the lineman, traffic signal technician and substation technician programs at any given time.

“We offer a four-year, 7,000-hour apprenticeship program for the power-line industry,” said Robbie Foxen, executive director for the Missouri Valley Line Constructors Apprenticeship and Training Program. “We start from scratch, teaching apprentices how to climb poles, work on transformers, build high-voltage power lines and maintain electrical grids.”

The training center owns two digger derrick trucks, a bucket truck, a skid-steer loader and a boom truck. In the past, with dozens of apprentices vying for time on the machines, scheduling was difficult. “We just hoped they got some hours on the equipment,” Foxen said.

So, to standardize equipment operator training, as well as expand seat time for apprentices, Missouri Valley Line Constructors decided to turn to simulation-based training.

A news helicopter circled overhead as the two ambulances left the job site. The deputy sheriff looked at the superintendent and said, “Tell me again, how did this happen?” The superintendent removed his safety glasses with a sigh as he surveyed the devastation left behind by the 345-kV contact. “Well, we had to set up for work directly under these lines because some local environmentalists wanted the wildflowers protected,” he said. “So, we did what we were asked. If you notice over there, those flowers are still looking beautiful, but it seems that the now-deceased landowner still didn’t like us being here, so he ran onto the right-of-way and tried to climb up onto the boom truck to stop our work. This must have caught our groundhand off guard, because instead of just stopping the work and notifying his supervisor, he attempted to intercept the man. All this commotion distracted the operator, causing him to contact the line. Once that happened, 345 kilovolts of electricity killed the landowner instantly, and our ground worker was severely shocked by what we call step potential.”

Although the preceding paragraph is an extreme worst-case example of how right-of-way (ROW) distractions and conflicts can impact our job sites, it’s not unrealistic. In this article, we will look at how members of the public and our own workers can create distractions and conflicts that jeopardize our ability to do our jobs well, and we will also consider safe ways to handle these types of distractions and conflict.

I’m not sure how I became an analyst. I don’t think it’s a career goal you necessarily plan for. My understanding of the analyst role is that it’s an individual who studies the elements of an event or occurrence. Analysts break down the elements of an event to learn how those elements are related. The purpose of analysis is to understand the nature of the event being studied. Through effective analysis, we ultimately create or assure desired outcomes and prevent or minimize the likelihood of undesired outcomes.

Over the past 10 years I have analyzed a half-dozen training accidents that occurred in apprentice training yards. Recently I also have seen a couple of videos of incidents involving apprentices in which no one was hurt; they were actually kind of funny to watch. But to an analyst, those videos have a lot more to offer than the lighthearted “been there” sympathy. Lineworkers often learn the hard way how not to do things. It’s that hard way that I want to eliminate because sometimes the hard way becomes the final act to what might have been a great life.

I was once engaged to write an opinion on a root cause analysis (RCA) that OSHA and a utility performed based on an incident that hospitalized three apprentices in a single event. OSHA only performs RCAs to identify where the employer may be at fault, but in this situation, the RCA listed all kinds of physical conditions and procedural mistakes that caused the incident. All of those items were causally related, but none were the real root cause. Before we move ahead in this edition of “Train the Trainer 101,” readers need to understand RCAs and how they fit into the lessons learned from training accidents.

Those of us in the industry tasked with record-keeping sometimes struggle with all of the different reporting scenarios. OSHA 29 CFR 1904, “Recording and Reporting Occupational Injuries and Illness,” gives us guidelines, but even the most thorough research of compliance requirements can still lead to questions and confusion.

For example, workers’ compensation cases may not be recordable as OSHA cases due to exceptions in the agency’s record-keeping rules. Workers’ compensation is mandated by each state, while OSHA 1904 is a federal record-keeping standard.

Further, OSHA’s record-keeping standard was updated in 2002, at which time many changes were made, including some that made the standard easier to understand but others that made it more difficult. Additional changes were made effective January 1, 2015. While basic reporting has essentially remained the same over the years, it’s important to be aware of the 2015 change found at 1904.39(a)(2), which states, “Within twenty-four (24) hours after the in-patient hospitalization of one or more employees or an employee's amputation or an employee's loss of an eye, as a result of a work-related incident, you must report the in-patient hospitalization, amputation, or loss of an eye to OSHA.” These requirements were added to provide OSHA insight on less serious injuries in certain industries that typically have a higher incident/DART rate.

Q: OSHA’s digger derrick exception – found at 29 CFR 1926.1400(c)(4) – includes digger derricks when they are used for augering holes for poles carrying electric or telecommunication lines, for placing and removing the poles, and for handling associated materials for installation on, or removal from, the poles, or when used for any other work subject to 1926 Subpart V. Substations are included in Subpart V, so why do some people say setting steel or regulators is not covered by the exception?

A: You might try to justify substations as being in Subpart V – except for what the substation rules cover in Subpart V. OSHA 1926.966, “Substations,” is not about construction of substations. It is about working in substations. The rule covers minimum approach distances, guarding of live parts, switching and electrical safety. Steel erection, just like concrete work, falls under horizontal standards. 

The logical thinking of very reasonable people regarding this issue often is challenged for sensibility, mostly because of their perspective. For instance, if I can hang a capacitor on a wood pole with a digger derrick, why can’t I hang a beam and capacitor in a substation with a digger derrick? It’s the same thing, it’s a capacitor. The right perspective is that all construction-related lifting of loads by cranes is regulated under 1926.1400, except lifting poles and pole-mounted equipment that are installed using a truck specifically designed for digging and setting poles. 

My son once told me, “Daddy, I’m an excellent listener. You’re a bad talker.” I won’t get into the details of what started that conversation, but I will say this, he was right. He did exactly what I told him to do, which was nowhere near what I wanted him to do. I didn’t communicate effectively. Pause for a moment and think about how often undesired results happen because someone didn’t understand our expectations.

Think about these questions, too: Have you ever agreed with someone just so they would shut up? Have you ever sent a text message to avoid a verbal conversation? Are you guilty of inundation communication, ambush communication, vague-garbage communication or CYA communication? Whoa! It’s not my fault. I sent an email and I have a read receipt.

Speaking of email, your account provides a tremendous amount of insight into communication. When you are the receiver, you have filters that automatically send certain messages into your junk folder because you don’t care about them and don’t have time for them. You manually delete certain messages without reading them simply because you get so many from that sender. When you are the sender, you set levels of importance and decide whether you want read receipts. I can almost guarantee that you have sent an email to the wrong person, and you also have sent an incorrect message because of autocorrect. You probably have a favorites folder for certain people that makes messages important before they are created and sent. Your signature line might include specific instructions and insight into safety that take the form of “Stay safe” or “Take care of each other.” These aren’t bad messages; there just needs to be more.