Q: We are a small, distribution-only municipal utility that has been looking into human performance. We are having some trouble understanding it all and how it could benefit us. Most of the training resources are pretty expensive. Can you help us sort it out?
A: We can. Human performance management (HPM) has been around in various forms and focuses since before the 1950s. Throughout the ’50s and ’60s, it seems the focus was on companies performing functional analysis and correcting issues that created losses, thereby promoting more efficient and error-resistant operations. In the ’60s and ’70s, much of the literature on HPM seemed to surround the nuclear power industry, and indeed the introduction of HPM into the transmission/distribution side of the utility industry appears to have come through the generation side. In the ’70s, researchers began to experiment and write about more closely analyzing the knowledge and skills of the performer. It took a while to sink in, but the safety industry began to research HPM as a culture analysis and risk prevention tool. It makes sense. Human performance – in particular knowledge, skills modes, decision-making modes and performance – affects all of every enterprise whether you have an HPM program or not. Organizations are made of people. HPM has identified and categorized commonalities in types of personalities that predict how people make decisions and perform tasks. Studying human performance also can help identify safety culture issues and risk behaviors. It’s not a big or expensive step to train your workforce on problem-solving and decision-making characteristics of the human mind. Soon they will understand their own processes and the limitations of the way they naturally think, allowing them to make adjustments toward better performance. So if we can take advantage of HPM to prevent incidents, why not do it? Most organizations start small. Pick a few key people to begin training on the basics of HPM, and then look at your organization to see where the initial undertakings can do the most good. There are several experts associated with Incident Prevention who will be glad to help should you need it. Additionally, on the iP website (www.incident-prevention.com) you can find numerous HPM articles in the iP archives as well as information and training sessions from past iP Utility Safety Conferences. HPM works. We hope you will pursue it.
Q: In our company, substations have been under the radar as a safety concern because we haven’t had any issues until recently, when one of our longtime contractors stuck a backhoe boom in a distribution bus. He’s been operating backhoes in substations to excavate for expansions. How do we electrically qualify him and others like him for various nonelectrical crafts?
A: There is a reason we build 10-foot-high fences around substations and cover them with warning signs. It’s dangerous in there. A worker may have performed a task in a substation many times, but that does not make him qualified to be inside that fence, and OSHA has some very particular rules for qualification of a worker that many utilities don’t regard. The very first step is clearly established in 1910.269(a)(2), entitled “Training,” all the way through the note to paragraph 1910.269(a)(2)(ii), which states: “For the purposes of this section, a person must have the training required by paragraph (a)(2)(ii) of this section to be considered a qualified person.”
That’s pretty clear and we could stop right here, but there would be lots of questions, such as “Do I have to send my backhoe operator to apprentice school to make him electrically qualified?” The answer is no, you don’t have to make him an apprentice, but you can’t just assume the years inside the fence make him qualified. The criteria to be a qualified person is clearly detailed. Those requirements – specified in 1910.269(a)(2) – are training and competency in safety-related work practices, safety procedures and emergency procedures related to the individual’s work that are necessary for his or her safety; the skills and techniques necessary to distinguish exposed live parts from other parts of electric equipment; the skills and techniques necessary to determine the nominal voltage of exposed live parts; the minimum approach distances specified in this section corresponding to the voltages to which the qualified employee will be exposed and the skills and techniques necessary to maintain those distances; the proper use of the special precautionary techniques, personal protective equipment, insulating and shielding materials, and insulated tools for working on or near exposed energized parts of electric equipment; and finally, the recognition of electrical hazards to which the employee may be exposed and the skills and techniques necessary to control or avoid these hazards. These requirements are written by OSHA in such a way as to eliminate the question, “Can’t we just put a journeyman lineman in there with the civil crew while they work?” The answer is, absolutely not. Read the very first rule under 1910.269(a)(2)(i). It states, “All employees performing work covered by this section shall be trained as follows.” There is no way to make that rule allow an observer in lieu of training. You may have that observer as part of the protocol for those task-specific-trained craftspeople, but not in place of training.
So, you do have to provide training meeting the listed criteria, but it’s not as complicated a process as it sounds. An important provision by OSHA sets out the specific expectation of the level of the training, explaining in 1910.269(a)(2)(i)(C) that the “degree of training shall be determined by the risk to the employee for the hazard involved.” This is where job-specific or task-specific training comes in. A non-electrically qualified craftsman may be trained specific to his job or task. The employer decides which one to choose. The task- or job-specific training is not a free ride or without a catch. The catch is that the employer better take this provision seriously, meaning the training has to meet the requirements and, like all training, there has to be a mechanism to show the worker has the skills required. The training should be formalized, documented, delivered by a competent trainer and include written and practical demonstrations of skills. Whatever you choose to do, you had better be able to defend it if the worst should happen.
Q: We are a contractor that has been prohibited from working de-energized lines in gloves without grounds. The client states that OSHA requires grounds to be installed once the line has been de-energized. What are your thoughts?
A: OSHA has long been cited as saying it’s not dead until it’s grounded and also that you may handle the conductors barehanded if they are grounded in accordance with the standards. Of those statements, the first is misquoted, and we have not found any OSHA reference that states it is permissible to barehand conductors after they have been grounded. In fact, that is a misreading of the language in the standard. OSHA does not refer to handling methods in these rules; they simply refer to the wire as being “considered deenergized.” They make no mention of how to handle it. There are references to methods of handling conductors under isolation and grounding that can be found in section 7.2.4 of the IEEE 516 consensus standard, “IEEE Guide for Maintenance Methods on Energized Power Lines.”
Some utilities also believe OSHA requires that grounds be installed after de-energizing to be in compliance with the standard. They are understandably mistaken if you read 1910.269(m)(3)(vii). That rule states that the “employer shall ensure the installation of protective grounds as required by paragraph (n) of this section.” It would appear that the rule requires installation of grounds unless you actually read what is required by paragraph (n). Paragraph 1910.269(n)(2) states that for “any employee to work transmission and distribution lines or equipment as deenergized, the employer shall ensure that the lines or equipment are deenergized under the provisions of paragraph (m) of this section and shall ensure proper grounding of the lines or equipment as specified in paragraphs (n)(3) through (n)(8) of this section.” So, rule (n)(2) does not say it must be grounded as part of de-energizing; it says that it must be grounded to be considered de-energized. If you simply switch it and remove the source, but work it as if it is energized, you have made the circuit work safer for employees by reducing flash or contact potentials. Grounding is not required by the rules. The risk is that crews working with this method take into account it is de-energized and fail to follow insulation or isolation protocols. Doing so raises risks should the circuit become energized by any means. Rule (n)(2) does allow crews to consider a circuit that is ungrounded to be considered de-energized under very specific conditions. In fact if you go a little further, rule (n)(2)(i) states that the lines and equipment may be treated as de-energized provided that the employer establishes that all of the following conditions apply: The employer ensures that the lines and equipment are de-energized under the provisions of paragraph (m) of this section, there is no possibility of contact with another energized source and the hazard of induced voltage is not present.
Employers should be wary of implementing these OSHA-allowed procedures unless you can confidently train your employees to recognize the hazard of working isolated, ungrounded circuits so that they follow the protocols and procedures appropriately.