Train the Trainer 101 Articles

The question that is the title of this installment of “Train the Trainer 101” originally came to me from a client during safety training for the company’s distribution employees. The client is a T&D contractor with a telecommunications (telcom) division. And yes, the question was regarding arc flash, which is not the same thing as FR. To utility workers, FR formerly meant “flash resistant.” The acronym FR was stolen from the utility industry by the road construction industry for traffic safety vests and now has come to stand for “flame resistant.” Flame resistance is the quality of a material designed for protection from exposure to fire or flame, not electrical arcs. OSHA, which does not use “FR” in the standards, requires that arc flash protective clothing also must be flame resistant to ensure clothing does not continue to burn after exposure to an electrical arc. In addition, flame resistance is required for the outer layer of clothing worn by an electrical worker who could be exposed to a heat source that could ignite that outer layer. There has been confusion, so it is important to recognize that use of the term “FR” on a traffic vest label does not mean the vest is arc protective; it is only flame resistant, meaning it has resistance to burning and will not continue to burn if the flame exposure is removed. It’s a habit to use the term FR when referring to arc flash protective gear, but we all need to understand the difference in labeling.

Now, back to the initial question. My first thought upon hearing it was that telcom workers are not required to use FR. After all, telcom is regulated by OSHA 29 CFR 1910.268, and 1910.268 does not require arc protective clothing like the 1910.269 standard does. But the answer doesn’t end there. So, if you are in the telcom business, don’t stop reading here. This is a lesson on interpretation of the standards as much as it is an answer to the question, who is required to wear arc flash protection?

This installation of “Train the Trainer 101” may have an odd title, but it was inspired by some recent conversations I’ve had. I’ve learned a lot about personal protective grounding (PPG) in the past 20 years, and I continually learn even more as others share their research and experiences. Some time ago I learned that much of the fundamental electrical math upon which electrical circuit theory is based does not adequately explain the risk from high currents imposed on grounded systems. That does not mean there are not theoretical explanations for all of the results in high-current fault testing. But the simple circuit math of Ohm’s law cannot explain the complex electrical physics that occur in a high-current fault, and that is partly what confuses the issue concerning EPZ.

What is simple is this fundamental of worker protection: It takes 50 volts to break the electrical resistance of a worker’s skin. If you can break the electrical resistance of the skin, current can flow, and the worker can be injured. However, if voltage cannot penetrate the skin, current cannot flow. You cannot eliminate system current by grounding; you can only divide it (i.e., send most of it through a different path) and hope for the best. But you can eliminate voltage in the worker exposure. You eliminate voltage potential by bonding. Once you’ve eliminated the voltage potential hazard, current no longer matters and thereby the risk is altogether eliminated.

We provide tools and equipment for our crews. Sometimes they are special tools, and sometimes they are generic tools necessary to support routine crew work. Sometimes they are accessories for trucks and equipment, and sometimes they are simply extra tools or equipment to make things easier on the people in the field. The question then is, are these tools approved?

The following is going to aggravate some readers, so let’s start with a reminder: I attempt to clarify and simplify compliance with this series. This is about making compliance easier and sometimes less expensive. So, here is an example.

About 20 years ago I was organizing a training school for a community college in Florida. I was recruiting utilities as clients. A visiting utility safety director saw that we had 40-foot-length retractables at the tops of the training poles. He said, “You are going to get into trouble with those yo-yos. They have to be mounted on approved davits.” My first question – and what should be your first question, too – was, approved by who? Without skipping a beat, the safety director responded, “OSHA.” We then went to his office where he had a similar device for which they had paid a little over $2,000. And just like he said, right there on the box was clearly printed “OSHA approved.” It only took me a few minutes on OSHA’s website to show him reference after reference and interpretation after interpretation in which OSHA stated to employers and manufacturers that it does not approve equipment. If an employer writes to OSHA and asks if they approve of having the employer’s employees in a specific type of exposure, and the employer intends to use a specific tool and equipment in a particular configuration, OSHA will respond that the agency does not approve equipment. The agency will then go on to state that in the situation described, using the equipment as described, OSHA believes the employer’s solution would – or would not – meet OSHA’s requirements.

If you follow OSHA’s guidelines, you train your workers to perform hazard analysis. You probably have a tailboard process as well, although your company might have a different name for it. Tailboards and crew hazard analysis are fundamental leading indicators of a good safety program. But hazard analysis and tailboards are only two elements of what really makes a difference in a safe approach to work. A health and safety site-specific plan (HASSSP) and the HASSSP process bring with them innumerable benefits – not just prevention of unwanted incidents.

When I was a contractor safety manager, I wrote a site-specific plan for every project. I started doing so about 15 years ago, after a series of preventable incidents and conditions that wouldn’t have occurred if I had provided prevention information to the supervisor and crew prior to the events. It occurred to me that for all the planning our company did, we missed some pretty big issues – issues that cost us pain and treasure.

A health and safety site-specific plan is not just a contractor tool. Many utility projects will benefit from a HASSSP since the level of detail for the plan itself is relative to the type and complexity of the work. Contractor HASSSPs typically are more detailed and developed if the local area is new to the company and particularly if the contractor is hiring new personnel for the duration of the project. The HASSSP is the product of prework research and analysis of the worksite and conditions that can or will affect crew performance or success.

In the past few months, I have received comments and inquiries from all over the U.S. regarding what appears to be stepped-up enforcement of both load securement and vehicle weight rules. It’s not unusual that these topics garner attention from the U.S. Department of Transportation when it comes to carriers, but this recent uptick seems to be for smaller commercial vehicles, mechanics trucks, pressure diggers, and bucket and digger derrick trucks.

Not all utility safety professionals may be up to date on this topic because DOT issues are not front-burner issues. Typically, the human resources department handles a driver’s qualification file and drug testing for the DOT. Drivers at utilities only spend a few hours a week on the road between calls and jobs, idling most of the workday. We recognize that there are utilities with rigorous DOT management programs for equipment and drivers, but generally we find a more lax daily inspection protocol among utilities and contractors than you would find with a carrier. That might be justified considering the time a utility truck spends in transit compared to a carrier that is preparing to put a rig on the road with two drivers for 20 hours a day over the next two weeks. But it’s not the rule, and mistakes or latitude over trucks can suddenly become a serious liability when one of those overlooked trucks loses a steering link as it is driven through a school zone full of first-graders.

Craft Worker Compliance
Recently there have not been any changes of note in the rules for vehicle weight and load securement; however, it appears that some of the latitude taken by utilities, if not given by the DOT, has caught the attention of those responsible for enforcement of the rules. 

In the last couple of years, state enforcement agencies used local media to inform local commercial businesses – that are not carriers – that they would be stopped if they did not appear to comply with loading and marking standards for their class of vehicles. In Arizona, New Mexico, Washington and Colorado, my colleagues and I began to hear of roadside stops involving lawn maintenance companies and small construction concerns that were pulling dual-axle, 5-ton trailers behind a Ford F-350, carrying loaders, backhoes and super lawn machines. That soon extended to power company trucks, especially those loaded with large wire reels. I even heard of one instance in which state enforcement set up scales in a shopping center parking lot on a well-known route out of a power company service center. Within 40 minutes they cited 22 vehicles for being overweight. You would think drivers would have warned others, but the DOT waved them into the parking area before they started weighing and inspecting the vehicles, so no one knew what to expect. It shouldn’t have been – but it was – a big surprise for that utility’s fleet management to learn what kind of loads lineworkers were putting on those trailers.

Over the past six months, three things have happened that I want to mention. First, I have answered numerous questions from clients and Incident Prevention readers regarding personal protective grounding (PPG). Second, the industry has experienced a rash of injuries and fatalities related to current in grounded circuits. The incidents most often have been associated with induction, but not always. And third, I have consulted with utilities and contractors, large and small, who are just now recognizing they have issues understanding PPG. It’s been hard to gauge the numbers – such as the frequency of incidents and especially comparing the seriousness of injuries – because there is no reliable clearinghouse for tracking incidents other than fatalities reported to the U.S. Department of Labor.

All of this is beside the real point, however, which is that there is no reason for any of these incidents to have occurred at all. Well, there is one: The utility industry is behind the curve in their understanding of the phenomenon of current in grounded conductors. There is an explanation for that, and it’s time to write about it again.

Let me be clear: The purpose of this article is to work toward solving the problem, not to find fault. To understand how we got to where we are, let’s first talk about industry awareness. Anyone who does research on the fundamentals of utility system grounding will notice that we have been struggling with PPG since as early as the 1950s. This has been documented in various papers from the IEEE archives of “Proceedings of the IEEE” – one of the first electrical industry journals, established around 1927 – and in “IEEE Transactions on Power Systems” since 1985.  

As the IEEE 1048 standard, “IEEE Guide for Protective Grounding of Power Lines,” points out in the introduction to the 2003 edition, “Protective grounding methods have often not kept pace with their increasing importance in work safety as the available fault current magnitudes grow, sometimes to as high as 100 kA, and as right-of-ways become more crowded with heavily loaded circuits, leading to growing problems of electric or magnetic induction.” Did you notice the date of the standard? The 2003 edition is a revision of the 1990 standard on protective grounding. As I stated earlier, we’ve been struggling with PPG since as early as the 1950s. Over 60 years is a long time to still not have figured it out.

I read the menu board and placed my order through the drive-through speaker. In her native Spanish, the employee assisting me rapidly confirmed my order and asked several follow-up questions; I answered “yes” to each question even though I didn’t understand what she was asking me. In the end, the order totaled $9.62. When I opened the contents of the bag, it was like opening a Christmas present, since I had no idea what I had just ordered. And, well, it was Christmastime after all, even though I happened to be in Puerto Rico.

That experience was my first lesson as an American who only speaks English in a place where – although both Spanish and English are official languages – Spanish is the dominant language. Over the years I had wondered why non-English-speaking workers would indicate understanding during training when they didn’t understand. Now I realize it’s a case of assumptions. I thought I knew what the employee at the fast food restaurant was asking, but I was way off. I had never been on that end of the conversation, and now I have a fresh perspective on non-native English speakers and training in the U.S.

I also have a new appreciation for the people of Puerto Rico. While there recently, I was in daily contact with people who’d had no power for 12 weeks. And for some of them, they knew it would be many more weeks before they did have power – and that might be a little optimistic. Not one person was rude or even expressed aggravation at their plight. In contrast, I am aware of utilities that had their front-office glass shot up by angry customers three days after a storm passed.  

Even in Puerto Rico’s larger cities, such as San Juan in the northern part of the island and Ponce in the south, where some power has been restored, there are still few working streetlights or traffic signals. Driving outside of San Juan, where there is no working traffic control, has become a mix of jousting and bluff. The practice is to speed up to the intersection and see if anyone slows. If they do, you are in. If they don’t, you wait and surge forward at the next driver. Yet this contrived system of driving is absent the aggression and manic reaction you might expect. No one blows their horn, points a gun at you or even gestures. It’s how you get around, and everyone is simply working it out.

Two U.S. Navy ships recently were involved in collisions at sea. It seemed impossible that one event, involving the USS Fitzgerald, would even occur. Then, a second collision occurred in the same region. In fact, in the last year, the Pacific fleet has experienced four serious navigational awareness errors, which has raised a question: Could the Navy have become so slack in discipline and readiness that these events were destined to happen?

We all know that, just as in the military, frontline leadership in the utility industry has a direct bearing on performance in the field. Yet after-action analysis indicates that when the Navy incidents occurred, the front line performed above expectations, indicating their competency and competency in their training as demonstrated by the actions of sailors. As was expected of the military, a quick response by Command relieved the ships’ leaders of their duties, citing loss of trust. Was Command correct? Did the ships’ leadership lose trust, or was it something else?

Some speculation arose among naval defense analysts that hackers may have caused electronic mayhem. A naval ship’s protection system depends on its electronic eyes and ears. Systems have evolved greatly since the days of the direct-wired blip from the antenna to the screen interpreted by a trained radar man. Early radar sent out a specific frequency wave that was several meters wide. The return wave depended on density of mass to return a reflection of that same frequency wave. The blip was interpreted by a trained observer to differentiate between an enemy bomber and a flock of geese. Today’s electronic radar frequency wave shifts are as small as 1 millimeter. A radar reflection comes back as thousands of bits that are interpreted by a computer. The radar screen now delivers an information-laden message to the radar man, who reads and reports the information displayed to him – by the computer. Some reports suggest that contemporary radar used by the military can detect a suitcase-sized drone that is miles away. The same types of systems scan for other threats, such as missiles and warplanes. If a hostile force wants to disable such protection, hacking a ship’s digital protection capabilities would make it vulnerable.

It was a little over 40 years ago that a Vietnam veteran helicopter pilot in Florida made the first live-line contact with a live transmission circuit, bringing a quantum leap for power-line applications using helicopter methods. The FAA regulates what they call “rotorcraft” work with specific qualifications for pilots, flight crews and the airships and auxiliary equipment used.

Many utilities and contractors think helicopters – or HCs, in flyers’ lingo – are for use on difficult projects because of the expense. But I have been working with contractors for the last 15 years who recognize the value of HCs in construction and use them as often as possible. An hour of HC time may cost the same as the monthly rental of a bucket truck, but when you can clip, space, dame and ball 20 times the structures in a day over bucket access, the expense really makes sense. I also am aware that some contractors and utilities think HC use raises risk. I know that some utility clients prohibit HCs on their properties while others actively assist their contractors by prequalifying HC companies.

The primary use of HCs has been to string rope or, in some cases, hard-line for pulling wire in transmission construction using HC blocks. These blocks are equipped with a spring-loaded gate at the top of the frame. The gate has extensions that guide the rope into the sheave, provided the pilot is good enough. It looks easier than it is. Since Mike Kurtgis of USA Airmobile put his ship on a hot line in Florida, skid and rope-suspended work, inspection and insulator washing have continued to advance as accepted work practices. The FAA refers to working from a skid or rope (short haul) as “human external load,” or HEL. By some it is called the most dangerous work method in the line industry. In fact, even the FAA has a sense of humor about it, as noted in their wording of a safety requirement in the HEL rules. In guidance document FSIMS 8900.1, Vol. 3, Ch. 51, the FAA provides examples of the types of persons that can be carried on an HC skid – they include movie camera operators and clowns as two of those examples. We always assumed that the lineman with the nerve to work from the skid was not the camera operator.

A number of years ago I investigated a pole-top flash that took place during a transfer. The flash occurred when an improperly installed blanket left a dead-end flange exposed on the backside of the metal pole-top. During untying, the tie-wire contacted the exposed flange. No one was hurt. The issue was the lineman’s selection and installation of the blanket. The foreman assumed the lineman was experienced and competent to perform the three-phase transfer with minimal instruction. The problem was the lineman had spent the last several years on a service truck, had little transfer experience and had never worked a steel distribution pole. The foreman’s assumption was based on the fact that the lineman came from the IBEW hall. Even though they had never met, he assumed the lineman was sufficiently experienced – and so the root cause for the incident was established.

Training and verification of training for new, already-trained employees is another subject that has caused headaches for those professionals charged with OSHA training compliance and the employer liability that goes with it. OSHA, just like CanOSH, the agency’s Canadian counterpart, knows that training plays a huge role in incident prevention. It should be obvious that training prevents incidents, but the investigation of incidents across the continent proves that is not so. I have long said that the quality of your safety program and all of the component procedures, rules and policies that go with it, no matter how innovative and well-written, are only as good as the training you provide to the workforce. A safety program is supposed to protect the workforce first and the employer second. How can that happen if the workforce doesn’t know what’s in the program? And if the workforce doesn’t know what’s in the program, how does the employer expect the safety program to protect the employer?

To begin this article, I want to offer a disclaimer. One of the reasons the “Train the Trainer 101” series was created is to examine the practical aspects of compliance as they relate to the utility industry. We do that by reading the statutes, looking at how OSHA interprets and enforces the rules, reviewing what the consensus standards state and then determining practical ways the employer can manage and comply with the rules. Sometimes I raise an eyebrow, but in working with the group of professionals who review every article published in Incident Prevention’s pages, we endeavor to ensure the advice given is not merely good but also compliant. With that said, in the following pages I am going to address some fall protection issues that iP has received many questions about in recent weeks. Several of them are driven by the latest OSHA final rule on walking and working surfaces, which contains some new language and expanded rules on fall protection.

Who is Responsible?
I get a lot of questions about fall protection that stem from a salesperson telling an employer they need to do a certain something in order to comply with OSHA. First, a nod to our partners in the industry: the vendors and manufacturers. They have done a great job meeting the needs of the employer by innovating, creating and often collaborating with the industry to get the tools we need into the field. Work with your vendors and manufacturer representatives, but be clear about your responsibilities in the relationship. Understand that there are no OSHA-approved devices for sale in any marketplace. OSHA does not approve equipment for manufacturers even though they may comment on a method of compliance if a written request is made by an employer. Even then, OSHA’s language to the employer often is something such as, “OSHA does not approve a particular device or piece of equipment, but the method you describe would meet the requirements of the standard.” And never forget that – no matter what the manufacturer’s rep says – you, as the employer, are ultimately responsible for how you comply with OSHA’s expectation. As I said, work with your vendors, but do your homework and educate yourself about the requirements. We aren’t just complying with standards – we’re protecting our employees and co-workers.

Common Misconceptions About Harnesses
I have often heard that you can’t arrest at the waist or chest. That is correct if you are truly arresting, which usually means the act of interrupting a fall from height by a personal fall arrest system attached to an anchorage limited to a distance of 6 feet. If you fall 6 feet, you must limit the fall arrest’s load, and the fall arrest’s load must be distributed across the body. That is why we use a full-body harness.

OSHA’s final rule on 29 CFR 1910 Subpart D, “Walking-Working Surfaces,” is finally here. It’s 26 pages of nine-point font equaling 21,675 words, and I read them all. It’s big, and if you include the preamble in your analysis, it is also complicated. It was just as hard to write about as it was to read. I guess that shouldn’t be unexpected for a final rule that has been in the works since 1983. The original 1910 Subpart D was published in 1971. The first update was proposed in 1983, but it was never ratified. Proposals were again considered in either the Construction standard or the General Industry standard in 1990, 1994 and 2003. This edition of the final rule for 1910 Subpart D covers it all. OSHA should be congratulated for bringing almost all of the fall-related standards into one location, making it easier for the employer to find rules related to working surfaces under one subpart instead of having to search for those rules that may affect the employer’s workplace. This may be news to some novice safety professionals in the utility industry, but not all regulations affecting us are restricted to 1910.269 or 1926 Subpart V. Subpart D applies, so it is important to be familiar with it.

What’s New?
Preventing falls is almost the entire purpose of rules for walking-working surfaces. The surfaces are not always those spaces of aisles between walls. Most walking or working spaces in the workplace are not defined aisles; they are more likely to be incidental spaces about the work area. It is quite easy for those incidental spaces to be encumbered by tools, materials and process waste that create stumbling or tripping hazards. In addition, many of those working spaces are raised surfaces, from the tops of foundations to the tops of skyscrapers. That being the case, OSHA has brought into Subpart D the body of fall protection standards. You will now find a greatly expanded section on ladders; step bolts (towers) and manhole steps; scaffolds and rope descent systems (building maintenance); the duty to have fall protection; new and expanded requirements on fall protection equipment design; and some expanded language on the training of employees to recognize and prevent falls in the workplace.

In the last installment of “Train the Trainer 101” (see http://incident-prevention.com/ip-articles/train-the-trainer-101-understanding-canine-behavior-for-the-protection-of-utility-workers), I provided information to help utility personnel understand, in part, why dogs do what they do. In particular, I addressed the pack mentality, dominant and submissive behaviors, and when and why a dog may feel threatened and try to attack. In the conclusion to this two-part article, I will explain how best to respond to unfamiliar dogs and what to do if you are attacked, as well as discuss breeds that are more commonly involved in biting incidents.

How to Respond to Unfamiliar Dogs
A dog’s response to a stranger will vary depending on whether he is with a handler or alone. When the dog is with a handler, remember what you know about the dog and human family relationship. The dog will respond to his handler’s actions as well as his own interpretation of an encounter with an unknown human. If you are the unknown human, speaking in casual tones to the handler, as well as the handler responding in a casual tone, will immediately set the dog at ease.

Workers in residential areas often are attacked by dogs who never posed a threat to people in the neighborhood. One reason behind this may be that workers focused on their task don’t exhibit the same mannerisms as visitors to the home or the people who frequent the property. This “unusual behavior” raises a dog’s suspicion and consequently his alertness level.

If you are walking toward a dog and his handler, stop a few feet away. If you are jogging or moving briskly, that may signal aggression to the dog. Stopping and allowing the handler and dog to approach you tends to reduce the dog’s alertness level.

Utility personnel are going to find themselves in confrontations with dogs. It is the nature of our work. How a worker responds during that type of engagement will have consequences that can be good or bad. The best consequence is when the parties go their separate ways and no one is left bleeding. Frankly, bleeding is not the worst outcome of these situations. People sometimes die as a result of confrontations with dogs, and the dogs can be hurt or killed, too. As a dog person, I would choose to see everyone walk away if at all possible.

While there is no magic formula that can be used to prevent you and your employees from being attacked by dogs, there are many good training programs out there and many good companies that provide dog attack prevention training. I have witnessed many training sessions and one thing is certain, not all of them provide the same information or approach. A few years ago I decided to perform some research on my own and compare it to what I knew about dogs as a longtime dog owner, a former dog breeder, and someone who is experienced with trained canine service members in the military and on police duty. I should also mention that some of my experience comes from four or five up-close engagements with big, seriously aggravated dogs in the backyards and pastures of utility customers. I can assure you that the nature of those incidents squared well with what I have learned over the years.

Now I must offer this disclaimer: Dogs can’t read. They don’t have the benefit of the wisdom offered throughout this two-part article (check out part two in the December 2016 issue of Incident Prevention). No one can account for or predict every dog’s response. What you read during the course of both of these articles will help you understand, in part, why dogs do what they do. You may also find some practical ways you can improve your chances of having safe experiences with dogs, both those that are friendly and those that are not so friendly.

Incident Prevention has been covering personal protective grounding (PPG) for many years. Most of the emphasis has been on overhead applications for transmission and distribution. Lately, however, iP and many consultants associated with the publication have been receiving more and more inquiries from utilities seeking to understand the issues related to PPG applications in underground.

Part of the issue with PPG is that, as I mentioned, most training and rules seem to coalesce around overhead applications. The majority of the written standards – both OSHA and consensus – are found in sections dealing with overhead scenarios. It’s anecdotal, but it seems that most of the injuries or accidents discussed in the industry are also related to overhead. Still, the OSHA standard has requirements for PPG that do not specify or exempt underground applications, such as 29 CFR 1910.269(n), “Grounding for the protection of employees.” Employers have recognized that the risks we are discovering related to current flowing in grounded systems exist in underground, too. As responsible employers, they are seeking information, and not all of the information out there is good.

In the last installment of “Train the Trainer 101,” we discussed grounding when stringing in energized environments (see http://incident-prevention.com/ip-articles/train-the-trainer-101-grounding-for-stringing-in-energized-environments). Many readers responded with questions regarding the myriad issues they have faced during stringing. I learned a lot about this type of work during my first 25 years in the trade. In stringing hundreds of miles of conductor, I am proud to say I never dropped wire. I also have to say it’s most likely I have that record because I learned a great deal from other workers’ accidents. In fact, I am seriously afraid of dropping wire. Stringing incidents are some of the most dangerous in the trade, not only risking the lives and limbs of line personnel, but creating a serious risk to the public. Over the years I have heard of or investigated every kind of incident, including one in which a phase dropped during clipping, shearing off 26 side-post insulators before the carnage ended. Wire ended up across school driveways, shopping center parking lots and intersections. More than 40 cars suffered damage and dozens of people reported injuries. I’ve seen wire dropped across interstates and rivers, and it always happens at the worst time. You’d be surprised how much damage 1272 can do to a luxury boat. So, the remainder of this installment of “Train the Trainer 101” will focus on some recognized issues and tips that might help prevent future disasters when stringing goes bad.

A few years ago I came upon a crew using 6-inch chocks to hold back a 38-ton crane truck. I told the crew I was happy that they were making an effort at compliance, but I had to ask them, “Why do we place chocks under a truck’s wheels? Is it to comply with our safety rules or to keep the crane from running away?” It was obvious to me that the short chocks would not hold the crane. The driver proved my assumption true a few minutes later. From the cab, with the transmission in neutral, he released the parking brake. The crane easily bounced over the chocks and, unfortunately, hit my pickup truck.

Sometimes I ask similar questions about grounds installed during stringing. That’s because it seems we do not pay as much attention to the value of grounding as we do to the perceived value of an act of compliance. Grounding during stringing plays a very important role in protecting workers; however, that’s only the case if we know why we are grounding and then install grounding so it does what we want it to do.