Train the Trainer 101 Articles

This installment of “Train the Trainer 101” is a little bit different than usual in that we are going to write an operating safety policy. There are two goals here: to help you learn to develop policies that make a difference, and to prevent wrecked all-terrain vehicles (ATVs) and utility task vehicles (UTVs) on your job sites.

Over the last few decades, ATVs and UTVs have taken on a significant role in remote site access and large yard transportation. What have also occurred over the last few decades are serious and occasionally fatal injuries from the operation of ATVs and UTVs. In my own experience as a former transmission line contractor, we only had a few incidents with UTVs, but it was on every job where we used them. In my time since, I have received calls every year regarding incidents related to UTVs. They are probably involved more often because ATVs are not as useful on rights-of-way as they are in yards where managers employ them to get around more efficiently. In this article, we are going to discuss the elements of an ATV/UTV policy designed to address the most common issues related to ATV/UTV wrecks and how they can be prevented.

I’ve met a lot of people over the years while working in the utility industry. One of those people is in management with a respected manufacturer of aerial devices. Back when OSHA published 29 CFR 1926 Subpart CC, “Cranes and Derricks in Construction,” he and I and a few others were discussing how a utility operation could best comply with some of the standard’s requirements. The OSHA rules were formed with the perspective of typical construction sites in mind. In particular, we discussed the rule’s expectation that the site’s general manager will tell the crane operator about underground obstructions that might collapse and cause a crane to become unstable. It’s obvious that a crane operator setting structures on a right-of-way doesn’t have that luxury, so we were thinking about things we could do. The discussion landed on auxiliary outrigger pads. At the time, my friend from the aerial device company had this to say: “We have occasionally been sued by folks who turned over one of our cranes or aerial devices, but we have never been sued by anyone who had set up on auxiliary pads.”

I don’t know if that’s still the case with that company, but at the time I began to research why auxiliary pads appeared to be an important part of stable setup for aerial devices. Basically, it’s because sometimes even a few square inches of additional pad dimension can increase ground support by tons per square foot. When it comes to the four-point support of an aerial device that weighs in at tons, tons-per-square-foot increases are a good thing.

Are you concerned about cellular antennas? Decades of research on cellphones and cancer have not found a link between the two, but that hasn’t stopped some communities from creating laws and public service campaigns regarding protection of the public from cellular system threats. What these actions have done is created a sense that the risk exists, leading to much concern and confusion for the public. There are risks, and they are not to be ignored, but many of them are misunderstood.

As communications technology continues to develop, its next iteration – 5G – is already here. The idea of 5G is better coverage using smaller, low-power, overlapping range with multiple antennas. This is the same technology used in large offices and hospitals to overcome the cellphone signal shielding caused by buildings. The buildings have numerous low-power, overlapping antennas that ensure cellular signal communications. The communications industry needs more mounting locations, and utility poles are the obvious answer. 5G is more of a physical hazard than a radio frequency (RF) hazard because it includes a powered cabinet on the pole wired to the antenna above, creating more congestion on the structure for climbers. I receive lots of questions and rightly so because line personnel are finding themselves looking at antenna installations where they have never seen them before. 5G is very low energy compared to other RF emitters but should not be ignored. Most of the 5G hazard is the antenna at the top of the pole, which can be anything from a 30-foot light pole to a 60-foot transmission pole. The obvious precaution, as with any antenna, is to not put yourself in the antenna beam. So, a 360-degree 5G antenna is like any 360-degree antenna: Don’t put your body in the beam.

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.

This is a review of ANSI/SAIA A92.2-2015, “American National Standard for Vehicle-Mounted Elevating and Rotating Aerial Devices.” As a consultant, investigator and auditor, I have been surprised time and again that people who should know this standard do not know it that well. Most fleet managers are familiar with the rules, which is important because the A92.2 standard obligates owners of aerial lifts to be held liable for equipment they sell in certain scenarios. On the employee side, a working knowledge of A92.2 can prevent incidents and loss of life. In fact, a recent live-line barehand training class was what inspired this topic. We found that a bucket truck had the leasing company’s logo sticker adhered down both sides of the insulating boom section. That bucket truck was designed and rated for barehand use at 500 kV, yet a vinyl-plastic printed logo installed by the leasing company, spanning two-thirds of the insulation length, could have had some serious implications for the safety of that boom.

In this article, we are going to review some of the information covered in the A92.2 standard. Readers should recognize that ANSI/SAIA consensus standards are protected by copyright, so we will not directly reproduce the text of the standard itself. The A92.2 standard can be purchased directly from the ANSI website (https://webstore.ansi.org).

The target audiences of this review are the owners and users of aerial lifts (bucket trucks) as well as safety departments, with the goal of familiarizing those parties with both the safety aspects and owner responsibilities regarding aerial lifts. Unlike many consensus standards, A92.2 has been incorporated by reference into the OSHA standard, meaning that certain parts of the A92.2 standard are enforceable by compliance officers. In addition, the incorporated parts of the standard essentially are “living” – they have been published in the Federal Register and made available to the public so that updates to the A92.2 standard are automatically part of the legally enforceable federal OSHA standard. Now that we have the applicability of the standard covered, let’s take a look at what the standard requires.

In the June-July 2020 issue of Incident Prevention magazine, I made a mistake in the Q&A. I stated that there is no consensus on a particular procedure when, in fact, there is. It is new in the most recent edition of the National Electrical Safety Code, but I missed it when it was published in 2017. In light of my error, I decided I should take a closer look at the most recent revision of the standard and present my findings here for the benefit of iP’s readers.

The NESC is one of the consensus standards that I regularly recommend as an important resource – every safety professional should have a copy of it in their library. Here’s some important information about the use of consensus standards: First, the standards are more procedural than the OSHA performance language. “Performance language” means that a rule is written in a format that tells the reader what must be accomplished. Procedural language, on the other hand, tells the reader how to accomplish something. Second, OSHA classifies consensus standards into two categories, adopted and referenced. Consensus standards that are adopted are incorporated into the OSHA standards by references listed in 29 CFR 1926.6 for construction and 1910.6 for general industry. Referenced standards are adopted into the OSHA rules with the force of law and can be cited in compliance actions against employers. Consensus standards that are referenced are helpful to the employer, as OSHA puts it in the introduction to Appendix G of 1910.269. OSHA defines “recognized” consensus standards as “helpful in understanding and complying with the requirements contained in § 1910.269. The national consensus standards referenced in this appendix contain detailed specifications that employers may follow in complying with the more performance-based requirements of § 1910.269.” You will find the same referenced standards in Appendix G to the 1926 Subpart V construction standards.

Recently I have received numerous emails and phone calls regarding respiratory air-filtering masks rated for arc flash. I’m sure everyone reading this, no matter what country you’re in, is aware why that’s the case: the COVID-19 pandemic.

If you are a regular reader, you know it is my methodology to address topics by first citing the related safety standards in effect and then discussing the issue from a practical perspective typically related to the utility industry. This time is no different – for the most part.

Initially, the use of masks during the pandemic was limited as effective respiratory protection and still is for the public per the Centers for Disease Control and Prevention. As far as OSHA was concerned regarding workplaces, the only approved mask was the NIOSH-approved N95 filtering facepiece respirator (FFR). The N95 rating means that the mask meets the criteria for effective filtering of airborne particulates and moisture at 95%. The rating system also was established by NIOSH. It is important to understand that the N95 rating is based on the assumption that the masks are utilized by trained users meeting the OSHA respiratory protection worker training and fit-testing standard, which also can require a medical evaluation of the user.

Across our industry, I have found all kinds of policies for grounding trucks. I also have found that in many cases, employers’ rules for grounding trucks are not based on OSHA requirements and – even more concerning – are not based on sound principles of protection. I believe the grounding policies are well intentioned, but they fail to achieve two important goals: (1) meeting the OSHA standard and (2) protecting workers where electrical contact hazards exist. So, let’s take an ABCs approach to the issue because even though some detailed explanation is required, it really is that simple.

A Defensible Plan
You must be able to defend your plan or policy. This is the case for every plan or policy. Defense is built around establishing and accomplishing a goal, understanding the hazard, understanding the mitigation of the hazard, training at-risk employees, and conducting periodic audits to ensure the plan or policy is properly employed.

When analysts look at utilities, and to some extent utility contractors, they often see what’s referred to as “mission creep.” That occurs when the expertise of the utility should be focused on quality and continuity of service but begins to be compromised by focus on too many other areas. The opposite of mission creep is when business elements that are critical to successful progress toward the goal get overlooked because of focus on the goal. One business element that gets less attention than it deserves are big trucks and the Federal Motor Carrier Safety Regulations (FMCSR). Granted, 75% or more of the FMCSR do not apply to utilities, and many parts that do apply are difficult to implement. Implementation is tough because, even as employers with drivers and big trucks, we are not carriers, which is the target audience of the rules, but we still are regulated by those carrier-related standards. The key areas of compliance for utilities are driver qualification, record of duty status (RODS), safety equipment and load securement. There also are a couple of new initiatives that we should keep an eye on.

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.

The date was January 28, 1986. The event was the tenth and final flight of the Space Shuttle Challenger. Seventy-three seconds into flight, the booster rocket that was lifting Challenger into space exploded, killing all seven astronauts aboard.

When events like the Challenger explosion happen, you never forget where you were at the time. You remember the iconic photos and the national days of mourning for those lost. After the Challenger explosion, President Reagan appointed the Rogers Commission to investigate the disaster, and some of you may remember the news commentary on the Rogers Commission Report. If you didn’t study the reports from the incident, you likely aren’t aware of the stunning findings, the changes that were called for and, even more importantly, the effect the changes at NASA have had on industry – including the utility industry. It’s worth taking a look. You can read about lessons learned from the incident at https://ocw.mit.edu/courses/aeronautics-and-astronautics/16-891j-space-policy-seminar-spring-2003/readings/challengerlessons.pdf.

The occupational safety and health industry and civil authorities require that employers provide training to employees. In the U.S., OSHA mandates safety training related to tasks assigned to employees. The agency often also requires the employer to certify that the training has been completed. In fact, if you have an incident requiring OSHA notification, the first question that will be asked is, “Was the employee trained for the task?” The second inquiry will be a request for documentation of the training, usually followed by an enforceable subpoena for those training records.

Training and certification of training are important for two reasons. The first is that training has clearly been demonstrated to reduce incidents and injuries to workers. Second, OSHA will hold employers accountable for the training they conduct. The penalties for willful violation of training requirements are rarely discussed, and I hesitate to do it here, but the record shows that if an employer does not train, and OSHA can show the employer knew training was required, the penalties are based on willful violation. Penalties for willful violations that result in fatalities can include jail time for the employer. In addition, if OSHA wins a willful violation case, the employer can expect charges of negligence under both civil and criminal liability standards. Don’t take this training responsibility lightly. I, like OSHA, would prefer employers be compliant for the welfare of the workforce because they are ethical and care about their employees. But if the threat of prosecution works, we still accomplish the desired outcome: a safer workplace.

Over the past few weeks I have received several inquiries regarding horizontal directional drilling (HDD). It’s not unusual in our industry for questions to make the rounds of utilities and contractors, generating interest and often controversy. I also have recently received several inquiries regarding OSHA allegedly canceling the digger derrick exemption in 29 CFR 1926 Subpart CC, “Cranes & Derricks in Construction.” OSHA hasn’t done that, but somebody said they did, and folks started asking around. Soon after, I received calls for clarification on the matter. In the digger derrick case, there was nothing to it; OSHA has not changed anything about the exemption. However, concerning HDD, there is an issue that raises an interesting question for those who administer compliance.

The point of the rest of this article is not to recommend or criticize any safety procedure associated with HDD. The point is to examine the role of manufacturer warnings and OSHA-compliant safety performance in the workplace. There is no doubt that I will get emails from HDD machine manufacturers and adherents of overshoe use, as well as overshoe sales or manufacturing representatives. I invite your response. To be clear, both Incident Prevention magazine and I are solely interested in providing an opportunity for perspective and analysis of a process that will help individuals learn how to deal with challenges in the workplace.

I’m not sure how I became an analyst. I don’t think it’s a career goal you necessarily plan for. My understanding of the analyst role is that it’s an individual who studies the elements of an event or occurrence. Analysts break down the elements of an event to learn how those elements are related. The purpose of analysis is to understand the nature of the event being studied. Through effective analysis, we ultimately create or assure desired outcomes and prevent or minimize the likelihood of undesired outcomes.

Over the past 10 years I have analyzed a half-dozen training accidents that occurred in apprentice training yards. Recently I also have seen a couple of videos of incidents involving apprentices in which no one was hurt; they were actually kind of funny to watch. But to an analyst, those videos have a lot more to offer than the lighthearted “been there” sympathy. Lineworkers often learn the hard way how not to do things. It’s that hard way that I want to eliminate because sometimes the hard way becomes the final act to what might have been a great life.

I was once engaged to write an opinion on a root cause analysis (RCA) that OSHA and a utility performed based on an incident that hospitalized three apprentices in a single event. OSHA only performs RCAs to identify where the employer may be at fault, but in this situation, the RCA listed all kinds of physical conditions and procedural mistakes that caused the incident. All of those items were causally related, but none were the real root cause. Before we move ahead in this edition of “Train the Trainer 101,” readers need to understand RCAs and how they fit into the lessons learned from training accidents.

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.