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Incident Prevention Magazine

Pam Tompkins, CUSP, CSP, and Matt Edmonds, CUSP, CIT, CHST

What are OSHA’s Training Requirements?

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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.

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Bill Martin, CUSP, NRP, RN, DIMM

A Lineworker’s Three Safety Superpowers

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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.

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Jesse Hardy, CSP, CIT, CUSP

Leading Change Through Faith, Hope and Tough Love: Part II

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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.

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Michael Stremel, CUSP

Are You Using Your Five Senses to Stay Safe?

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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.

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Jim Vaughn, CUSP

Trailers, Brakes and Common Usage Errors

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.

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Danny Raines, CUSP

Lone Worker Limitations

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.”

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Jim Vaughn, CUSP

December 2020-January 2021 Q&A

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.

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David McPeak, CUSP, CET, CHST, CSP, CSSM

Assessments: Highlights and Implementation

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.

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