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Employee Training - How hard can it be?, Part II


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.

Qualification Requirements

“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.

Training Organizations

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).


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Electric Power Industry Case Study


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:

Case Study

You can find additional information on safety programs, management, oversight and training here on SET Solutions's website.

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SET Solutions

Safety Improvement Audits, Part II


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.

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Fall Protection Requirements

Fall Protection Requirements

When OSHA passed the new Walking and Working Surfaces Standard for the General Industry in 2016 they also updated the fall protection requirements in the Regulations Standard 1910 Subpart I. Due to the fact that Subpart I has been updated, OSHA also updated the fall protection requirements in the Electric Power Generation, Transmission and Distribution Standard for the General Industry (Standard 1910.269).

 The new requirements now reference 1910 Subpart I rather than the previously referenced 1926 Subpart M. The requirements in the new Subpart I can be found here:


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Information Sharing Requirements

Information Sharing Requirements

Information sharing is required when a contract employer/subcontractor is working in a covered process

Information sharing applies when:

  • Work is performed as a “Qualified Employee” under 1910.269 or 1926 Subpart V.

  • Nonelectrical work is performed by an employee within a restricted area covered by 1910.269 or 1926 Subpart V. (i.e., substations, poles, towers and similar structures, testing facilities, generation facilities, etc.)

Host Employers are required to share the following information: (Note: specific areas of the standard may require sharing such network protectors, unique electrical equipment, etc.)

    • System characteristics

      • Nominal voltage of lines and equipment

      • Max switching-transient voltages per unit (T-factors)

      • Hazardous induced voltages

      • Presence of protective grounds and equipment grounding conductors

      • Location of circuits and equipment including supply, communication and fire protective signaling circuits.

      • Other know system information related to safety and requested by contractor.

    • Known conditions

      • Known condition of protective grounds and equipment grounding conductors.

      • Known condition of poles.

      • Known environmental conditions relating to safety.

    • System design information needed for assessments

      • Whether an enclosed space must be entered as a permit-required confined space.

      • Whether forced air ventilation has been maintained long enough that a safe atmosphere exists.

      • What is the MAD for the work to be performed.

      • Whether employees are exposed to hazards from flames or electric arcs.

      • What is the estimated incident energy from an electric arc.

      • Whether devices are designed to open or close circuits under load conditions.

      • What are known sources of electric energy, including back feed, supplying electric circuits.

      • What are the sources of hazardous energy including potentially hazardous stored or residual energy.

      • Whether protective grounds have adequate current carrying capacity.

      • Whether there is a possibility of hazardous transfer of potential should a fault occur.

      • Whether overhead structures, poles and towers, are capable of sustaining stresses imposed by work.

    • Other known system information related to safety and requested by contractor

 Host is required to:

  • Develop and implement procedures that are adequate to communicate the required information effectively to contractors and subcontractors performing work under the covered process. Host has the responsibility to implement procedures that are adequate for subcontractors to have information necessary to comply with covered process standards.

    • Employers can either exchange information directly with each other or can arrange to handle their information exchange through contacts with entities that do have contractual relationships with each other.

    • Procedures may include but are not limited to the following:

      • Host can instruct, though an appropriate method, subcontractors hired to perform work under the contract.

      • Host can contract for the contractor to share the covered process required information with any subcontractors hired to perform work under the contract.

      • Host may establish centralized procedures for contract and subcontractor employers to obtain, or share, required information.

      • Host may be able to use maps, tagging or barricade systems to provide necessary information.

        • The Host employer is required to provide information or guidance to understand the system used.

  • Coordinate work rules and procedures to ensure each employee is protected as required by the standard.

    • The coordination process must communicate how the host employer and the contract employer will exchange information required under the covered process.

Information can be provided through any appropriate method which includes but is not limited to the following:

  • telephone call

  • email

  • text message

  • bid package

  • contract

  • orientation session

  • Developed website or other computer program

  • Map or similar document along with the information or guidance to interpret the map or document.

Appropriate Method - Must effectively communicate the required information to the contract employer in a manner to enable the contact employer to pass the information to its employees and to use the information to comply with the standards.


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Host employer responsibilities regarding distribution of safety information

Host employer responsibilities regarding distribution of safety information

Did you know, before any work begins, that Host employers must inform Contract employers of know conditions that are related to the safety of the work to be performed, including environmental conditions to the extent they relate to electric lines and equipment?

For example, the Host employer must inform the Contract employer of known ground conditions that impact the stability of, or an employee’s ability to safely climb, a pole. In generating plants, the Host employer is required to inform Contract employers of the known presence of coal dust or fly ash to the extent the presence of those substances relate to electric lines or equipment.

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Does a Host Employer have any responsibility for subcontractors performing non-electrical work inside restricted work areas?

Does a Host Employer have any responsibility for subcontractors performing non-electrical work inside restricted work areas?

The answer is Yes!

Host Employers have the responsibility to develop and implement appropriate procedures to ensure required information is communicated effectively to subcontractors so they can comply with the OSHA Electric Power standards and pass the information on to employees for their safety. The required information would include voltages, MAD distances, arc flash hazards and many others inside the restricted work areas. 

Ultimately, the Host Employer may establish centralized procedures that subcontractor employers and contract employees would use to obtain, or share, required information.

For more information on safety solutions, visit our website at:


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Auditing for Safety Improvement

The mere thought of participating in an audit can be unnerving. Consider IRS audits for a moment – they can never mean good news, right? So why would an organization want to spend time, money and other resources to conduct an audit when it could be painful? The answer is that, regardless of the feelings they evoke, audits – when done right – can be a powerful organizational improvement tool rather than just a way to monitor compliance.

To better understand the importance of auditing for improvement, let’s review an example of a traditional compliance audit. In this example, the audit identified a distribution underground crew whose members did not use insulating cover-up while working inside a single-phase underground transformer. The apparent cause of the violation seemed straightforward – the crew members had simply failed to use appropriate insulating cover-up, so management reviewed the violation and mandated the crew to follow the rules in the future.

The action taken by management in this example seems acceptable, but was it truly enough? Will the apparent cause of this violation be completely remedied through talk and discipline? Although rule compliance is extremely important, audits that focus solely on this type of compliance may neglect to identify major gaps that contribute to an ineffective safety system. What happens if a utility doesn’t have the right people in place to support safety? For instance, it’s possible that workers have not been properly trained and frontline leaders don’t know how to apply the rules on a job site. In the previous example, the crew may not have understood how to use insulating cover-up on underground applications as they were only trained for application of cover-up on overhead lines.

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Pam Tompkins

Understanding OSHA Electric Power Training Requirements

Understanding OSHA Electric Power Training Requirements

Are your employees performing work on or near electric power generation, transmission or distribution facilities? If so, whether they are performing electrical or nonelectrical work, electrical training is required. The training provided must ensure employees can identify electrical hazards and employ safe work methods to remove or control the hazards for their safety.

Covered Work
To simplify the application of OSHA 29 CFR 1910.269 and 1926 Subpart V, many companies use the term “covered work,” which includes work areas with electrical system hazards. For example, the construction of a power plant is the same as general building construction until the plant begins startup and commissioning. Once electrical systems are started, the job tasks become covered work due to the additional electrical system hazards.

Another example is the construction of a substation. Substation construction is similar to general building construction until the substation becomes energized or is being built in an area with transmission lines. Consider the difference between a substation built in an open field with no transmission lines and a substation built under transmission lines. Although each substation has hazards, the substation under the transmission lines has electrical hazards that would not be found in the substation built in an open field. The substation built under transmission lines is considered covered work due to the electrical system hazards.

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Pam Tompkins

Electric Power Standards- What does OSHA consider reasonable estimates of available heat energy?

arc flashWhat does OSHA consider reasonable estimates of available heat energy? Understanding that the largest available amount of fault current does not necessarily translate into the highest levels of available heat energy is extremely important. Device clearing times plays an important factor when determining reasonable estimates. An electric power system could have system locations with small amounts of fault current and large clearing time which could equate to to large amounts of available heat energy. Many utilities are looking throughout their system to determine if locations are fully protected by adding Hot Line Tag devices which clear instantaneously, 3 cycles or less. This requires utilities to have a strict Hot Line Tag procedure in place to ensure all work performed on or near electric power lines and equipment has been placed in a Hot Line Tag position. Note the compliance date has been extended to April 1, 2015 for completion of estimates of available heat energy exposures faced by employees who are exposed to electric arc hazards. Appendix E located in 29 CFR 1910.269 and 29 CFR Subpart V outlines methodology to comply with the standards. For more information contact us at SET Solutions, LLC. 

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Pam Tompkins

Electric Power Standards- Aerial Lift Fall Protection

bigstock Power Worker In A Lift Bucket 3103043Can a 6 foot shock absorbing lanyard be used while working from an aerial lift?  The answer requires an assessment to determine if the system will provide worker protection in the event of a fall. A 6 foot shock absorbing lanyard is a fall arrest system with clearance limitations that must be assessed. The system will tipically require between 16 to 20 feet of clearance before it fully engages which could allow a worker to sustain a serious injury from hitting a surface below. An employer has to determine if work is performed when an employee could be at distances to hit a structure or lower level, such as working on secondary, decorative street lights and many other work tasks. OSHA recommends that workers use the shortest lanyard practicable during ascent and descent and when working over structures to maximize worker protection.

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Pam Tompkins

Electric Power Standards- Subcontractors Performing Nonelectrical Work in Restricted Areas

Electrical Power Plant 1200Does the Host Employer have any responsibility for subcontractors performing nonelectrical work inside restricted workareas. The answer is Yes! Host employers have the responsibility to develop and implement appropriate procedures to communicate required information effectively to subcontractors. The required information would include voltages, MAD distances, arc flash hazards and many others in the restricted workareas. 

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Pam Tompkins

Electric Power Training Requirements for Nonelectrical Employees

electric power substationDoes OSHA require nonelectrical employees to be "Qualified"? The answer is yes when nonelectrical employees need to access areas, or perform tasks restricted to "Qualified Employees". Areas could include substations, generating facilities, transmission and distribution lines and equipment. An few nonelectrical examples include extending a substation fence in an energized substation,  adding a communication tower in an energized substation, spraying herbicides in substations and around underground energized equipment , forming concrete foundations under energized transmission lines, adding pole treament chemicals to wood poles, and many more. All of these jobs require employees to access areas restricted to "Qualified Employees" and OSHA requires the following minimum training requirements. Employees must know what is safe and not safe to touch, the maximum voltage in the workarea, the MAD distances for the maximum voltage and how to maintain the MAD for their work, how to identify and use protective equipment and most importantly, how to recognize electrical hazards and control or avoid the hazards for the work being performed. 

Training for nonelectrical employees working in substations


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