Proactive Methodology to Ensure Maximum Safety

By Lee Marchessault, CUSP. Incident Prevention Magazine December 2019.

Electrical utilities are among the most hazardous industries to work. This was recognized in the early days of electrical power distribution over 100 years ago with extremely high fatality rates. Since those days utilities have investigated and examined injuries and fatalities to learn how to prevent similar incidences by analyzing possible hazards and associated risks, mitigating the hazardous conditions, creating policies and procedures, providing protective equipment, and making the work place as safe as it can be… or have they? Unless we make a conscious effort to verify what was developed and provided is used properly, safe work practices done in the field can only be assumed. By conducting field personnel observations (OSHA terminology: “performing inspections”), on a consistent basis we can verify and measure the effectiveness of the organizational safety efforts proving that the safety culture is accurately represented.

Conducting field observations enables the organization to take a firsthand look, and document employees’ demonstration of knowledge and ability to work safely, and also sends a message to the employee that the company cares about their safety.

Prologue

I began my career in 1978 and worked in various electrical field positions mostly in substations and power plants. As an Electrician, I didn’t give much thought about my behavior other than be polite and respectful as my parents taught me. I followed the rules, went through daily job briefings (verbal at that time), and as a union steward helped to encourage safe work practices. Even though I worked safely and never had a lost time accident, I got too comfortable one day. My Forman and I were doing maintenance all summer on substation distribution breakers. This one day the 12.47 kV breaker we took out of service was much closer to other breakers than we had seen in other substations. After de-energizing and grounding, I set up my step ladder (in between breakers), climbed it a few steps and was removing the taps. For whatever reason, I looked to my right and noticed in the corner of my eye that the energized 7200 volt tap on the breaker near me was about 18” from my head (within arm’s reach). This could have been easily touched and was probably the closest I ever got to losing my life. It got me thinking about how we didn’t do an adequate job briefing and allowed complacency to kick in. We should have considered the other breaker in our briefing. Most infractions or deficiencies identified in the field or actual incidences whether near miss or injury-causing are due to a lack of communication or an inadequate job briefing.

After 20 years in the field, I hung up my tools and became the Safety Manager for the power company. With this new responsibility, my eyes were opened to a whole new world. I quickly learned that I needed more information to combat at-risk work practices that I knew existed, so I went back to college and got another degree with a primary concentration in behavioral psychology. Bringing this knowledge into the field has proven to be an effective tool for building trust and avoiding negative emotions that may otherwise be detrimental to the process.

Purpose of Field Observations

Let’s first examine what we hope to achieve when we visit personnel in the field:

Compliance with the requirements of OSHA 1910.269(a)(2)(iv) which states:

“The employer shall determine, through regular supervision and through inspections conducted on at least an annual basis, that each employee is complying with the safety-related work practices required by this section. (Note: the word “and” changed from “or” in 2014 which packed a big punch”)

With this change, conducting an annual “inspection” for field personnel becomes a regulatory compliance issue. This may include Line Workers, Substation Workers, Generation Electrical Workers, Meter Personnel, Relay Technicians, and any other electrical positions that may be part of the utility infrastructure. Although OSHA requires annual inspections, it would be more effective to conduct them at least twice per year for each employee for trending purposes and to ensure that no employee is missed within the calendar year. Also, be sure follow-up with another observation after corrective action has been implemented.

Provide leading vs. lagging indicators:

Injury and illness statistics are required to be recorded for OSHA recordkeeping, insurance companies and occasionally for the Bureau of Labor Statistics. This provides a lagging indicator because it records what happened. This can help measure the comparison with similar size companies but has little value to affect the safety culture of the organization.

Conducting regular observations can provide leading indicators to measure the current status of the safety program and determine if efforts are effectively implemented. Observations can also provide a means to forecast and avoid future incidences by identifying and rectifying deficiencies on the spot.

Provide a mechanism to bond with employees:

Companies often blame employees for infractions identified but in reality, the root cause of such behavior usually is related to the overall process, not the individual. People will react by the stimulus presented which may be in the form of policies, procedures, rules, regulations (low impact stimulus); or by disciplinary action and loss of pay (slightly more effective but is a negative stimulus), or by invoking a more positive and immediate stimulus such as a pat on the back with praise for a job well done and safe (most effective stimulus). This practice builds good relationships and encourages more of the same behavior.

Determine if training, written programs, tools and equipment are adequate:

Performing observations and tracking data provides of good tool for trend analysis focusing on the organizations future safety efforts relating to specific training topics, policies and procedures, or to examine the latest PPE, tools and equipment.

The observations will often present opportunities to conduct effective on the job training as well. The following examples depict work practice deficiencies observed in real-life incidences.

An Apprentice Line Worker was seen with a digger bar trying to free up a pole butt where an old pole was cut to about 4 ft. off the ground. A digger/derrick operator was unsuccessfully attempting to pull the pole butt using the winch line with a choker connection on the pole while the apprentice was digging. This prompted an immediate shut down. If the pole was suddenly released, the tension could have caused the pole butt weight of perhaps 200 pounds to fly up and spring back striking the apprentice, or if the winch line failed, the line could have seriously injured him. The corrective action following the shutdown was to purchase the proper hydraulic puller needed to safely pull the pole butt, train employees how to use it and why a choker on the winch line hook is not safe.
A job was shut down due to inadequate coverup. There were not enough rubber blankets available on the trucks or in stock to effectively insulate and isolate the work. We discussed why the pole and crossarms required cover in this case.
A job was shut down because an air monitor was not functional while work was being done in a vault. On-site training included calibrating and evacuation of the vault if the monitor is not functional.

In all cases, inadequate equipment and training were the issues, not employee behavior.

Reinforce the company’s safety culture by being in the field on a regular basis

A regular surprise visit to the field has not always well taken well especially in the beginning of an observation program, but over time attitudes change. If done right, most employees will embrace the visit.

Preparing for the Observation Program

Before starting an observation program, it’s important that there is buy-in from the top. Take the CEO and other senior management personnel on a few field observations regularly. Be sure they understand the PPE requirements as they enter the work area such as steel toe boots, high visibility vests, AR clothing if applicable, hardhat and safety glasses. This will support acceptance by field personnel to the program and help change or strengthen the safety culture of the organization. They should ask questions but never reprimand an individual in front of the crew.

Another important consideration before you begin is to look at the corrective action policy. If you have a policy that states a letter of reprimand is written for any safety infraction, it will be tough to get the program off the ground. You may need to negotiate a new or addendum policy to allow for coaching for minor infractions. This is also a good time to find out why the minor infraction was done. It’s often not a matter of violating the rule, but perhaps the PPE provided doesn’t fit or creates discomfort. So, the corrective action is to provide different PPE that fits and works. Major life-threatening infractions (such as not grounding equipment if working de-energized without PPE, or failure to wear rubber gloves within the minimum approach distance) will need to be addressed more firmly as per the company policy. The key to corrective action is that it should be consistent. On the flip side, it is important to provide plenty of positive feedback for good safe work practices. Once the observation is done, share the score with all field personnel and always emphasize the good work practices first, then let them know what is needed to get a better score next time. This will foster safe work practices also improving the safety culture and building good relationships with field personnel.

The documentation format should be developed with a scoring system that is as objective as possible to prevent inconsistencies among the various supervisors or other designated auditors conducting the observations. It should be a simple checklist that won’t take much time to look away from the work. Electronic versions that are downloadable to smart phones work well provided there are considerations for use in direct sunlight, and minimal data entry is needed allowing more time observing and less completing the form.

The outcome should be measurable and quantifiable. Trending may be achieved by separating the observations into parts such as tools and equipment, personal protective, and work practices. By measuring these items separately, it will help to target deficiencies and develop a means to correct infractions efficiently and effectively. The scoring system should be weighted according to the level of risk (i.e. 1- minor, 3 – moderate, 10 – major). This system fosters a more objective vs. subjective scoring system. Of course, a high-risk hazard identified should be cause for immediate shut down of the job.

To effectively conduct a worksite observation, plan on being there for no less than 1 hour, and if more than one crew is present, 2-3 hours may be best. For meter personnel observations, it’s best to ride with them to observe a variety of jobs and driving practices. Observations for power plant operators who may be responsible for racking and locking out breakers may be asked to do a simulated drill of doing this work live is not an option.

Who Performs the Observations

Worksite observation programs are best done by Operations Supervisors and occasionally their Managers with spot checks from the Safety Managers or neutral qualified designees who don’t work directly with the managers or those being observed. Safety management should facilitate the program but should not conduct all personnel observations. Supervisors performing observations in the field allow time to connect with field personnel, hear their concerns, and provides an opportunity to praise them for the safe work practices identified.

In order to be consistent, those assigned to perform field observation should be trained on how to conduct the observation including:

What actions, equipment, PPE, work practices to look for
Implementing corrective action and coaching when infractions are identified.
Methods of rewarding safe work practices
How to deal with different types of personalities
Scoring the observation while in the field (understanding the probability/severity matrix)

Taking digital photos throughout the process may be beneficial. These can be used at a later time for training. It is important to note that photos used against an employee for violations would be extremely detrimental to the program, so try to use caution on the type of pictures and when or where you use them.

If infractions or deficiencies are identified, take corrective action immediately. Start by having a verbal one-on-one discussion with the Leader but avoid discussions in front of other employees unless it’s related to improving a job briefing or similar group activity.

Tracking and Trending

After the observation is done it should be input into a tracking system that will provide reporting capabilities. This may be developed by the safety department or they may purchase a commercial program. This should have the capability to measure leading indicators or identify unsafe trends to help target at risk areas. The results (leading indicators) may also be used as an incentive program to promote safe work practices. Note: never tie incentives to OSHA rates (lagging indicators). Reports generated can provide valuable information to show upper management or regulatory agencies the effectiveness of the company safety program.

Summary

Field observations are required by OSHA, but more importantly provide a valuable tool for companies to determine if the training provided is effective, tools and equipment are adequate, and the safety culture is where it should be. If done properly, this process is more powerful than any classroom training and provides a solid foundation to an exemplary safety culture.

Lee Marchessault, CUSP is the President of Workplace Safety Solutions, Inc. He has worked with electric utilities for over 40 years and has conducted field observations including training observers for over 20 years. For questions, he may be contacted at lee@workplacesafetysolutions.com