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.