Alert: OSHA Deadline for Electronically Submitted Injury/Illness Reports Approaching; See the news release (click link below) for full information on US States that accept electronic reports:
OSHA has issued interim guidance to highlight some of the requirements of the new respirable crystalline silica standard - check out the link below:
Check out what the participants at SET Solutions’s latest 30 Hour OSHA Course for Electric Utilities had to say about the program:
“Instructors were knowledgeable and related material to our company” – Jeff
“Interesting and very interactive” – Scott
“Great instructors” – Steve
“Lots of valuable information” – Shane
“A really great program” – Chadley
“Class was well presented” – Mike
For more information on SET Solutions’s training opportunities for your company, check out the website at: www.setsolutionsllc.com or give us a call at 803-407-4707.
Enforcement of OSHA’s respirable crystalline silica standard for construction went into effect on September 23. Check out the link below for the latest OSHA Memorandum outlining the 30-day Enforcement Plan.
Did you know the SET in SET Solutions stands for SAFETY, EXCELLENCE and TRAINING?
SET Solutions is dedicated to utilizing these concepts in order to provide organizations with the appropriate tools and support to build and manage a sustainable safety system. SET Solutions is committed to:
reducing or eliminating the risks of illness and injuries from workplace hazards
providing the most up-to-date technical and professional support to our clients
helping management control costs by adopting safe workplace practices and procedures
building our clients' trust through honesty and reliability
upholding the highest standards of professionalism and integrity
For more information on the Safety, Excellence and Training services offered by SET Solutions, check out more of the website.
By: Pam Tompkins, CSP, CUSP, CUSA
Has your organization implemented a new safety procedure that was well developed by the safety department but fails miserably in the actual application? If you answered yes, don’t feel alone because a large percentage of your peers will answer the same way.
Why do you think these well thought out safety programs and procedures, when implemented, are failing? I would suggest that failure can be linked to organizations that hold the safety department solely responsible and accountable for employees’ safety. Early in my working career, a top officer in my utility would ask me regularly “are you keeping people safe today?”. Reflecting back on his statement frankly infuriates me, but at the time, I really thought it was my responsibly in the safety department to keep people safe.
The safety department cannot own the safety program; rather it is the facilitator of the safety process that is owned by all employees. The top officer along with every level of management should know whether people are being safe, what is being done daily throughout the organization and what they personally need to be doing to ensure safety excellence. No ownership will equal no success! Without this understanding, safety will always be a program and the example given earlier will continue to occur.
Having management lead the process and take total ownership is a requirement for safety success. Without total ownership for all affected employees, the change may never occur uniformly throughout the organization. Management must be able to successfully gain buy-in from employees for the change to occur and safety excellence to prevail. Management and employees are responsible for owning the new procedure.
Do you think the new safety procedure would have a different outcome if all employees owned the actions and results, as described? When everyone throughout the organization is actively pursuing the same safety goals and working together in a synchronized manner to achieve the goals, safety success will occur.
Leaders and Management must be empowered to understand their safety role in the organization and to take total ownership for the safety of their team. All leaders must be actively involved and participate in safety decisions daily as they do with all other decisions made in their job. All leaders must support each other and understand each others’ roles. A frontline crew leader cannot be successful if he has no upper level support or he has not received effective training and coaching to support safety.
It’s not just the safety department’s responsibility. It’s not just management’s responsibility. It’s not just the frontline leaders’ responsibility. It’s not just the employees’ responsibility. Safety is everyone’s responsibility!
Be sure to attend the iP Utility Safety Conference and Expo in Louisville, KY October 2 - 4, 2017 to hear SET Solutions's Owner and President, Pam Tompkins, CSP, CUSP, CUSA. She will be speaking on Safety Improvement Audits and Incident Investigation.
Those in attendance will get the chance to register for a free Safety Perception Survey - a $2,500 value!
August 30, 2017:
OSHA Issues Proposed Rule to Extend Compliance Deadline for Crane Operator Certification Requirements
Click on the link to review the Trade Release: OSHA Trade Release
By: Pam Tompkins, CSP, CUSP, CUSA
Last month, employee training and the importance of developing a well planned training process were discussed. This month, several additional factors as they relate to employee training will be reviewed.
“Qualified” employees have specific training requirements defined by OSHA and NESC (National Electric Safety Code). A “qualified” employee is “one who is knowledgeable in the construction and operation of the electric power generation, transmission, and distribution equipment involved, along with the associated hazards”.
Training for “qualified” employees must establish employee proficiency in OSHA (safety standards) and utility specific work practices. This means employees must demonstrate proficiency and safety in performing all required tasks. OSHA and NESC list major requirements for “qualified” employees in the standards which are fairly straightforward and easy to understand. More difficult is the requirement to identify all associated hazards with each job function and to ensure qualification for the specific work performed. For example, a major storm hits and a URD journeyman is assigned to an overhead crew. Although the journeyman has demonstrated proficiency for safely completing URD tasks, the tasks were not specific for the type of work required in overhead operations. To ensure proficiency and appropriate qualification, the journeyman must demonstrate the ability to safely work on overhead equipment and lines.
OSHA considers tasks that are performed less than once per year to necessitate retraining before the work can be performed. OSHA further requires the employer to determine, through regular supervision and inspections conducted on at least an annual basis, that each employee is complying with all safety-related work practices.
Many utilities use external training organizations for various jobs. Although external training organizations offer great educational opportunities, they should not be used as the certifying authority. OSHA is very clear that qualification does not specifically correlate to school completion. The employer is responsible for ensuring employees are trained and qualified to work on the specific lines and equipment owned by the utility.
Years ago, I worked for an electric utility who participated in a state sponsored line worker school. Employees attended four (4) week long courses, which were offered over several years to achieve journeyman status. Several major issues became extremely evident. First, some employees finished training early depending on when the employee was hired and the scheduling of classes. Second, training was structured for a wide variety of duties, not always specific enough, since multiple utilities utilized the training. Third, employees who had been on the job for years were complaining other employees were moving to journeyman status too fast to learn the proper skills and did not always feel an employee was “qualified” to perform the work, especially in outage restoration situations. This type of training had no organized method of promotion to journeyman other than school completion and time in grade. We learned that employees who completed the schools had vast differences in knowledge and skill level although they ended up in the same job classification.
Management addressed these issues by developing an organized training plan which addressed academics, external training and on-the-job training requirements. Written and practical reviews were attached to the training process and a training team was developed to ensure identification of hazards and proven proficiency of employees before various levels of qualification were achieved. This program made a profound difference at the utility because all employees understood the requirements for each level of qualification, supervisors had qualified workers, employees were being paid for the job they were doing, and on and on…….
A well developed training plan is extremely important for every job classification. Without a plan, training becomes fragmented and many times left to chance. Keep in mind the plan should ensure employees have a well orchestrated method of development and an understanding of all specific requirements. Finally, the time taken to ensure training is developed and completed appropriately will equate to a well trained, safe employee! “Everyone cannot cross the finish line at the exact same time but everyone should be able to cross the finish line at some time if given the necessary plan and resources” (Russ Dantzler, 2011).
Which of the following is true in respect to the training required for employees whose work is nonelectrical in nature, but directly associated with a covered installation area as defined by OSHA 29 CFR1910.269 and 29 CFR Part 1926, Subpart V:
- The employee must know what is safe to touch and what is not safe to touch in the specific area where they will be working
- The employee must know what the maximum voltage of the area is
- The employee must know the MADs (minimum approach distances) for the maximum voltage within the area, and the skills/techniques necessary to maintain those distances
- The employee must be trained in the recognition and proper use of protective equipment that will be used to provide protection for them
- The employee must be trained in the work practices necessary for performing their specific work tasks within the area
- The employee must be trained to recognize the electrical hazards to which they may be exposed, as well as the skills and techniques necessary to control or avoid these hazards
- All of the above
The answer is g. All of the above.
Although the training required for qualified nonelectrical workers is not as comprehensive as the training normally required for qualified electrical workers, they are still required to have minimum training including all of the topics discussed above.
The OSHA Final Rule on Electric Power Generation, Transmission and Distribution; Electrical Protective Equipment (29 CFR Parts 1910 and 1926) requires host employers to inform contract employers of the “characteristics of the host employer’s installation that are related to the safety of the work to be performed”. This required information must be transferred via a printed, hard copy report to the contract employer. True or False?
False. OSHA does not specify how the required information is to be transferred. The transfer of information may be done by a telephone call, email or text message, as well as an orientation/training session or website. OSHA deems the method for transmitting information sufficient and appropriate as long as it effectively communicates the required information to the contract employer so that they, in turn, can comply with the appropriate standards and communicate this information to their employees. See the Final Rule 29 CFR 1910.269(a)(3) and 29 CFR 1926.50(c) for more information.
Check out more of our website for additional resources related to the OSHA Final Rule on Electric Power Generation, Transmission and Distribution; Electrical Protective Equipment.
OSHA releases information and resources concerning the final silica exposure rule – click on the link below.
For more information on the silica rule and other industry safety standards, check out more of SET Solutions’s website.
By: Pam Tompkins, CSP, CUSP, CUSA
Mark Twain said "There is nothing that training cannot do. Nothing is above its reach or below it. It can turn bad morals to good, good morals to bad; it can destroy principles, it can recreate them; it can debase angels to men and lift men to angels". We all know high-quality training must take place to ensure the overall development of employees.
Does having well trained employees mean the employee only attends a safety meeting monthly to gain training knowledge? Certainly not! Training should provide employees with a continual understanding of job task requirements, the hazards associated with the tasks and the appropriate abatement strategies for their safety. A monthly safety meeting may help validate these issues but it cannot be the sole delivery method for training. Unfortunately, many employees may never receive any additional formal training other than safety meetings.
Having the knowledge that training is important and required may not always ensure it takes place due to time constraints and a lack of funds and resources. Many utilities and utility contractors hire employees, then leave any training to time on the job and knowledge learned from existing employees who may use improper or unsafe work procedures. When no specific plan is developed for training, employees may never reach their full potential.
Developing a Plan
Developing a well planned training process is not easy. Each training plan should address the desired length of training, the number of training steps with compensation ranges and the requirements for employee completion and advancement. Ask the question- What knowledge is required to ensure full competency at the end of training? Academics, skills training, on the job training and demonstrated proficiency should all be addressed in the training plan. Plans must have full management and employee support to ensure success.
In many cases, a developed plan will change the structure of a job classification. This is especially true for jobs that only have one designation and salary range. Ensuring appropriate compensation for job knowledge and experience is a very important part of plan development.
Jobs such as customer service representatives, line designers and system operators (dispatchers) need a developed plan no less than an employee who works on energized lines and equipment. Although these employees do not necessarily perform work on or near live energized parts, their jobs directly impact other employees as well as the public. Customer Service Representatives need to understand electric system fundamentals to determine customer requirements; the line designer needs to understand how to design a system that is functional and safe for construction and maintenance; and a system operator needs to understand how to operate the system to ensure safety and reliability.
In the next article, we will discuss qualification requirements and training organizations as additional factors in employee training.
Check out this case study from the electric power industry which outlines the importance of safety and health programs and the role they play in keeping electrical workers safe:
You can find additional information on safety programs, management, oversight and training here on SET Solutions's website.
By: Pam Tompkins, CSP, CUSP, CUSA
In the previous Safety Improvement Audits articles, a traditional Safety Compliance Audit was discussed, including its lack of focus on creating effective safety management systems. The discussion continued on to Comprehensive Safety Improvement Audits and some of the tools that can be used to better understand how to improve the safety process. In this third and final article in the series, we will spend some time reviewing additional typical audit components and the importance of developing a plan for sustainability.
Safety Management Systems
Safety management system audits should address whether the safety process is monitored and managed. It is important to determine if safety oversight methods are effective to support the safety process. Safety success depends on leaders understanding their role and monitoring, coaching and improving workers’ safety performance. A successful improvement audit will identify the effectiveness of leaders’ influence on workers’ behavior. Some basic questions that should be answered during the audit process include:
- Do leaders support the safety process and understand their role in safety?
- Do leaders actively participate in strengthening the safety process?
- Do leaders know rules and procedures and understand how to apply them to their job sites?
- Do leaders effectively monitor work activities to determine if workers are adhering to procedures, safety rules and management expectations?
- Do field observations detect deficiencies relating to safe work rules?
- Do leaders effectively coach workers to correct unsafe or unacceptable work behaviors?
Each of the above questions should include “why, how and what” for successful leaders. Although many compliance audits include a basic review of management systems, the focus, as stated above, may center on a frontline leader rather than the entire management system. Safety improvement may not be effective by “fixing or replacing” a frontline leader. What if the frontline leader has no upper level support or the frontline leader has not received effective training and coaching to support the safety process? It is important to review the overall management system to ensure sustainability for future safety efforts.
A training system audit should address whether current training is in alignment with how work is actually accomplished in the field. An earlier example citing the distribution underground crew not using insulating cover-up while working inside a single phase underground transformer gives a clearer understanding of the importance of a review of training systems. Workers may know protective cover-up rules but not have a clear understanding of underground system hazards and how protective cover-up rules apply. Some basic questions that should be answered during the audit process include:
- Do training and qualification programs adequately provide workers with sufficient knowledge and skills to work safely on equipment?
- Is an effective method in place to assess worker knowledge and skill?
- How do leaders ensure workers have adequate knowledge and skill before assigning work?
Written Rules and Procedures
A written rules and procedures audit should address whether rules, procedures and safety manuals provide sufficient worker guidance in regards to safety. Do current documents meet regulatory and consensus standard requirements? Additionally, it is important to determine how specific rules and procedures compare with best practices of other electric power organizations.
A review of procedures should answer the following questions, at a minimum:
- Is the procedure correct?
- How is the procedure used?
- How often is the procedure updated?
For example, a utility required workers to review a procedure prior to removing a regulator from service due to a previous regulator incident. The procedure, placed inside the regulator control panels for ease of use, was faded and was not readable. Also, the procedure had not been updated in several years and some substation equipment had been upgraded after the procedure was developed. Hopefully you agree this procedure was not useful to field workers and should be updated prior to use. Procedures are only beneficial when they are current and used to improve a process. It is important to identify whether the procedure is a continuous use procedure, reference use procedure, information use procedure or a multiple use procedure. Each procedure is used differently, so it is important to understand when each would be appropriate for specific job tasks.
Developing a plan for sustainability
The final step of an improvement audit is to develop a management report identifying safety process strengths and weaknesses. The report should prioritize improvements based on risk assessment methodology.
Once strengths and weaknesses are correctly identified and risk assessment assigned, a strategic plan with short and long range improvement plans must be developed. Senior management should develop safety improvement plans, as they are responsible for ensuring the safety process is effective and that appropriate resources are in place to meet future goals. Safety plans should be viewed with the same importance as other business plans such as quality, productivity and profitability.
Although uncovering the “good and the bad” can be painful, the pain can be lessened when organizations use the information gained to make sustainable improvements in worker safety.
UPDATE: SET Solutions, LLC’s next OSHA authorized 30 hour Comprehensive Safety Compliance for Electric Utilities Course will start Monday, August 21, 2017 – the day of the much anticipated 2017 Solar Eclipse!
The 2017 Solar Eclipse has been a hot topic for the past year, and people from all over the world are traveling to cities in the United States to see this extremely rare event. The Lexington/Columbia SC area is in the eclipse’s narrow path of totality, and will experience the moon completely block out the sun. All area hotels, motels and rentals have been booked for months.
But …. SET Solutions, LLC has a set of rooms reserved for those attending the upcoming Safety Compliance Course. Participants will be able to receive their 30 hour OSHA training, and experience a very unique event. Our instructors will be sure to allocate plenty of time to view this total solar eclipse, whether you are on your own or sharing the experience with your family.
Don’t miss out! Sign up today.
By: Pam Tompkins, CSP, CUSP, CUSA
In the previous Safety Improvement Audits article, a traditional Safety Compliance Audit was discussed, including its lack of focus on creating effective safety management systems. This article will continue to discuss the Comprehensive Safety Improvement Audit and some of the tools that can be used to better understand how to improve the safety process.
Comprehensive Improvement Audit
A comprehensive improvement audit will identify gaps within the entire safety process so an effective plan can be developed for future improvement. A comprehensive improvement audit identifies gaps between an organization’s existing state of safety and its desired state, simply stated: existing versus desired. The desired state is typically determined by regulatory and industry best practices related to safety management systems, training systems and written rules and procedures.
Audits are typically completed through a series of employee interviews, field observations and document reviews designed to uncover weaknesses within work processes that allow unsafe conditions and contribute to worker errors. Many audits include a safety perception survey and a common cause analysis. These tools can be used to identify specific safety culture issues or areas of vulnerability. Also, these tools can be used prior to an audit to identify specific focus areas that may need more attention during the auditing process. Let’s take a look at both of these tools in more depth.
Safety Perception Survey
In a previous article, we discussed the importance of using safety perception surveys to gain a true picture of worker’s perception of the safety process. Surveys are used to gather feedback from workers so management can gain a clearer understanding of actual working conditions and worker perceptions and opinions. Understanding how workers perceive safety can help identify specific focus areas to address during the improvement audit. A more in-depth discussion on safety perception surveys was featured in the December 2015 issue of Incident Prevention magazine.
Common Cause Analysis
A common cause analysis is used to identify if a single deficiency has caused multiple incidents. Stated another way, do multiple incidents have a common cause? A common cause analysis includes reviewing existing data to determine areas of focused improvement that would yield the greatest sustainable positive results. This process involves reviewing all available data on recent events, close calls, and survey results. When analyzed as a whole, this type of data can be very accurate in pointing to those areas of greatest vulnerability.
For example, a performance assessment was conducted at a fossil power plant because they were experiencing a high number of incidents. Review of the event reports identified there were a high number of incidents of dropped loads from forklifts. To identify why there were so many dropped loads, interviews were conducted with people involved in the events and training records were reviewed. Talking to people is a critical part of this assessment. Interviews and document review revealed that all forklift operators had been trained, but that training did not include handling unwieldy or oddly shaped loads. Without the analysis, actions for improvement may very well have been to re-train all the fork lift operators with the same training they had already completed. After the analysis, the need to train forklift operators on handling unwieldy loads became self-evident. A common cause analysis is a critical element of safety improvement efforts.
In a future article, a better understanding of safety improvement audits will be discussed by reviewing some typical audit components beyond the use of safety perception surveys and common cause analysis.