Incident Prevention Magazine

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.

Have you ever questioned whether a contractor or subcontractor was qualified to perform electric power work? If so, you should consider developing a contractor safety management standard. This type of standard defines minimum safety requirements that contractors must adhere to when they perform work for your company.

Years ago, many electric power organizations used contractual language and a hands-off approach to establish contractor safety responsibilities. In fact, organizations hired contractors to perform work they felt was unsafe because they knew the contractor would do whatever it took to complete the job. These work practices have significantly changed throughout organizations that recognize employers share responsibility for working conditions and safety at multiemployer worksites. Utilities and contractors are adopting a shared commitment to worker and system safety within their organizations.

Regulatory Requirements
In the preamble to 29 CFR 1910.269 – the electric power generation, transmission and distribution standard – OSHA states the following: “When OSHA promulgates new safety and health standards, it does so against this background principle that employers share responsibility for working conditions, and thus for OSHA compliance, at multiemployer worksites. Therefore, when the Agency issues a new safety or health standard, it is with the intention that creating, exposing, and controlling employers at multiemployer worksites will exercise their respective responsibilities to ensure that affected employees are protected as required by the standard.”

Your safety program can have fully developed rules and procedures, a top-notch training program and the best safety equipment and tools money can buy – and there is still the possibility that it may not be successful. Although these things are extremely important and necessary, safety success will not occur until your safety program becomes a fully functional safety management system. This means that everyone in the organization is actively pursuing the same safety goals and working together in a synchronized manner to achieve those goals. A fully developed and well-executed safety management system is the backbone of safety excellence.

Safety Management System Components
What does a safety management system need in order to be effective? According to ANSI/AIHA Z10-2012, “Occupational Health and Safety Management Systems,” the following components are required for success:
• Management leadership and employee participation
• Planning
• Implementation and operations
• Evaluation and corrective action
• Management review

Let’s take a closer look at how each component is defined.

Are your employees performing work on or near electric power generation, transmission or distribution facilities? If so, whether they are performing electrical or nonelectrical work, electrical training is required. The training provided must ensure employees can identify electrical hazards and employ safe work methods to remove or control the hazards for their safety.

Covered Work
To simplify the application of OSHA 29 CFR 1910.269 and 1926 Subpart V, many companies use the term “covered work,” which includes work areas with electrical system hazards. For example, the construction of a power plant is the same as general building construction until the plant begins startup and commissioning. Once electrical systems are started, the job tasks become covered work due to the additional electrical system hazards.

Another example is the construction of a substation. Substation construction is similar to general building construction until the substation becomes energized or is being built in an area with transmission lines. Consider the difference between a substation built in an open field with no transmission lines and a substation built under transmission lines. Although each substation has hazards, the substation under the transmission lines has electrical hazards that would not be found in the substation built in an open field. The substation built under transmission lines is considered covered work due to the electrical system hazards.

The 2012 edition of the National Electrical Safety Code (NESC) hit the streets August 1. The updated code adds a new dimension to electric utility arc flash implementation with the inclusion of voltages from 50-1000V. Previous editions have required employers to assess voltages over 1000V for potential electric arc flash exposure and to provide clothing or a clothing system with an effective arc rating for the anticipated arc energy.

We all know high-quality training must take place to ensure the overall development of employees. Does having a well-trained employee mean the employee only attends a monthly safety meeting to gain training knowledge? Certainly not. Training should provide employees with a continual understanding of job task requirements, task-associated hazards and the appropriate abatement strategies for their safety. A monthly safety meeting may help validate these issues, but it cannot be the sole delivery method for training. Unfortunately, many employees receive no additional training beyond apprenticeship other than safety meetings. Some employees, depending on their job classification, may never receive any additional formal training besides safety meetings. 

Electric utilities have unique issues that are not easily addressed in a traditional LOTO program. Traditional programs typically address equipment and system designs that rarely change. This is certainly not true with electric utility Transmission and Distribution (T&D) programs. LOTO procedures are dynamic, changing from day to day and sometimes from hour to hour.

If you’re in a quandary over arc flash compliance, you’re not alone, according to Incident Prevention’s recent survey.

NESC-2012 change proposals have been published and are available for comment through May 1, 2010. Subcommittee 8, Work Rules Sections 40-44, is responsible for the changes to Part 4 of the NESC. The main change proposal includes a requirement for employers to determine potential electric arc exposures for employees who work on or near lines, parts or equipment 50- 1,000 volts. NESC-2007 does not specifically require employers to perform an arc hazard analysis on low-voltage systems so this will be a major change for 2012.

Information technology has profoundly transformed the electric distribution dispatching center. Historically, a dispatching center’s primary responsibility was to receive outage calls, assign daily work and communicate to field crews via the company radio.

Some utility personnel have resisted arc-flash compliance with the presumption that arc flashes and blasts are not a major issue for the utility industry. Organizations and standards committees such as IEEE (Institute of Electrical and Electronics Engineers), NFPA70E (National Fire Protection Association), EPRI (Electric Power Research Institute), CRN (Cooperative Research Network) and others confirm this as a false statement. An IEEE study concluded, “To decrease the number and severity of non-fatal electrical burn injuries, direct worker exposure to electrical arc energy must be reduced.”

The 2007 edition of the National Electrical Safety Code may pose significant work rule changes for electric utilities. The updated code, which is detailed in the NESC-2007 handbook, covers the following areas.