Q: Where does OSHA’s switching and lockout/tagout policy draw the distinction between generating plants and the plants’ substations, particularly with metal-clad substations?
A: It depends more on the equipment used than a distinct line, and it has to do with OSHA’s intent, equipment design and practicality. Let’s look at this from the perspective of intent. OSHA intends that employers have an energy control plan that protects workers. LOTO was developed for that and has worked very well over the years. The data shows that LOTO has been directly responsible for a dramatic decline in severe and fatal incidents related to hazardous energy releases. The utility industry was ahead of OSHA with switching policies and procedures, and OSHA recognizes the effectiveness of that history.
OSHA 29 CFR 1910.269(d)(1) explains that the provisions of paragraph (d) “apply to the use of lockout/tagout procedures for the control of energy sources in installations for the purpose of electric power generation.” The paragraph goes on to explain that locking and tagging procedures for the de-energizing of transmission and distribution are addressed by 1910.269(m). A note to 1910.269(d)(1) states, “Installations in electric power generation facilities that are not an integral part of, or inextricably commingled with, power generation processes or equipment are covered under §1910.147 and Subpart S of this part.” OSHA has given the industry lots of leeway in how we handle switching because of how disciplined we are and the historical integrity of the process. OSHA noted that history when they declined to establish a LOTO policy for transmission and distribution and instead allowed us to follow the NESC and IEEE consensus standards that we created over the decades.
Now, back to the generation substation and intent. We suggest that if a substation is iso-duct and metal-clad gear, it would have been designed with all of the switching and locking provisions, making 1910.269(d) applicable. We also suggest that if the plant feeds into a conventional exposed substation tube or wire bus with typical substation apparatus and exposed switches, the switching would be covered in 1910.269(m), the standard applied to transmission and distribution.
Q: We recently had a discussion with human resources and employee representatives after a well-regarded employee self-reported a violation. We know Incident Prevention has relationships with a lot of personnel management experts and wonder what they would recommend in such a case.
A: We ran your question around the block and almost all the advisers first asked, did the violator self-report in an effort to minimize their accountability or was it about duty in a demonstration of safety culture and honesty? Their second question was, does your activity in deciding the issue set a precedent or contradict your current personnel policies? Third, is there a policy in place that covers self-reporting?
Over the years, leadership training has always recommended written policy guidance on rule violations and consequences as well as training. Most experts suggest that the first question to an alleged offender in a disciplinary hearing should be, were you aware that you were violating an established rule and are you aware of what the disciplinary actions are for this violation? The second question should be, if you were me, what would you do? Those two questions lead to a conversation that usually reveals the real attitude of the violator as well as their culture, integrity and accountability.
Regarding the written procedure for discipline, the first rule is to allow for some measure of adjustment of consequences backed by a serious and respected process of consideration and vetting by others before a reduced consequence is allowed. The who, why, employee history and extenuating circumstances may play a role in justifying a reduction of discipline terms. Self-reporting, especially when a violation may not have been discovered except for the self-report, is a noble act that deserves consideration. How it’s handled can be a valuable message and an example to the workforce and culture. The bottom line is that if there is no discipline, effectively there is no policy. Everyone has to understand that, even those highly loved and respected individuals who would never be expected to break a rule. That is why one of our favorite rules about policy is that it’s only as good as the training you do when you roll it out and the accountability that’s enforced once it’s implemented. A few days off, letters in files, probationary periods and so forth are not that debilitating to the relationship between employer and employee when there is understanding and justification. Three days is not that much; one or two is a good measure that shows consideration if it’s justified.
Justification means eliminating causes like intent to ignore a rule, willful violation, aggravated circumstances, poor judgment, and if there was injury or property damage. Where those elements exist, you can’t reduce the discipline.
Q: I never thought about it when I was a lineman, but after becoming a trained safety adviser, it suddenly occurred to me that hanging banners and flags between elevated buckets at the entrance to a safety fair might be considered a problem. Do you have an opinion?
A: Yes, we do, and it probably won’t be too popular. There is a problem if the manner of setup creates side strain or down strain of the bucket that exceeds the manufacturer’s ratings, at least as far as the manufacturer’s standards are concerned. As an industry, we sometimes forget that standards and operational limits apply even when we are not doing line work. For a good reason, all manufacturers have no-side-load policies for booms, and it wouldn’t matter whether the side load was dragging a pole or holding a flag in the wind. Manufacturer representatives are at every one of these events and surely struggle with the issue. After all, how much strain could it be, and who wants to tell someone they can’t hoist the red, white and blue? In my own experience, I have seen a manufacturer's rodeo loaner digger derrick used to hoist the flag. On another occasion, I saw a bucket truck with the flag suspended on the material-handling jib; a 40-pound bucket of concrete was weighting the bottom of the 30-foot flag in an attempt to keep it vertical in the wind.
The issue with the boom is that the whole structural design is intended to manage lifting loads straight down from the tip of the boom. All training for crane operators trains to this exact policy. There is no rating on any boom for side load. Mechanics will even tell you that the turret ring gear and the motor pinion gear backlash are worn simply by fast stops in rotation. Side-loading does damage and is to be avoided. I can see that from a digger derrick, if the hoisting is off the boom tip straight down and there is no wind, it’s probably not an issue.
So, here’s our opinion: Using a boom to hoist Old Glory in the wind can be a side-loading issue. It’s probably a minor one, but doing so still contravenes the operational recommendations. The issue shouldn’t fall into the category of rules we don’t follow because they are inconvenient. And yes, in good conscience and with a commitment to safety, we don’t think we should be doing it. If we have to do it, we should consider the issues and have a plan to limit the stress.
Q: Where are we in the industry on analyzing lightning hazards for exposed workers?
A: If you are researching, you probably found various numbers around 20 miles out (the National Oceanic and Atmospheric Administration says 25 miles). You measure distance using seconds as miles timed between visible lightning and thunder. This is because of monitoring over the years conducted by the Lightning Protection Institute that shows occasions when lightning does hit as far as 20 miles ahead of a storm front.
It’s good when there are trees and cities in the path between you and the storm front because they project grounded targets into the air that take lightning hits. If you are out in the desert, you should consider making the number at least 30 miles. In deserts, there are miles of open area without trees or buildings to deflect lightning, causing longer strike fronts ahead of a storm.
There is one more thing you don’t hear much about – anvil lightning – and that’s what gets outdoor workers and golfers in trouble. The name comes from the cloud shape associated with a storm front. You might have a storm 40 to 60 miles away with concentrated dark clouds and lightning. Above that are white clouds stretching out several miles ahead. From the ground it looks like a blacksmith’s anvil. That anvil cloud has energy, and often that is where “out of the blue” lightning comes from.
Q: We are a gas and electric utility. In the past, our gas crews have been responsible for excavating and supporting URD cable when it is encountered on gas projects. We recently became concerned that our gas employees may not be considered qualified for that task in accordance with the OSHA standards. Can you help?
A: There is always a risk excavating URD primary, even for qualified persons. It’s even greater for untrained persons who might not understand how dangerous it is, how to examine a cable, cable failure modes and safe cable-handling practices. Short of having a line crew switch it out to protect the gas crew, there is not much support for allowing a gas crew to excavate an energized cable. Even switching it out has some issues since it may not be possible to ensure you have the right cable, and for non-jacket cable, you still have the exposed neutral. We recently heard a guffaw in a group setting when we said an exposed concentric on an unjacketed cable was a threat to unqualified, unprotected workers. Our response was a comparison of a gas worker in a ditch against a URD concentric and allowing a gas worker to go up in a bucket truck and contact the system neutral. They are the same thing. This goes to qualification. Gas workers are not qualified by training to handle primary cable. The people who are qualified as required in OSHA 1910.269(a)(2) go through training and assessment so the employer can assure the workers are qualified for the task.
We think the OSHA standard would suggest a model procedure that might look like this:
Regarding the question of the employee self-reporting a violation. The response to that question is a primary indicator of why incidents go unreported in this industry, and why incidents continue to occur. The comment of "The bottom line is that if there is no discipline, effectively there is no policy." is very irresponsible. Setting a safety culture is a difficult thing to do, and very difficult to sustain. Having a policy that disciplines for self-reporting will prevent future violations/incidents from being reported. Instead, recognize to the organization that self-reporting is part of the safety culture that is desired, and the self-report will be used to learn and prevent a similar incident from occurring. The old-school culture of discipline is not effective as maybe it was in the past.
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