Uncovering the Indicators that Lead to Disaster
Copyright Material IEEE Paper Number ESW2018-17
978-1-5386-1559-1/18/$31.00 ©2018 IEEE
Robert S. LeRoy, CESCP, CUSP LeRoy Electrical Enterprizes, Inc. PO Box 6025 Lakeland, Florida 33807 USA
Abstract – One of the hardest things safety professionals, managers, front line supervisors and design engineers have to do is after an incident or accident has taken place. Discovering the key indicators on how highly skilled, trained, competent and qualified workers managed to get themselves hurt is both excruciatingly painful and time critical. Ensuring a similar incident cannot occur is essential. If US OSHA conclusions are true, that approximately 80% of all accidents happen due to something a worker did or failed to do, there must be equal or greater attention given to the preparation of every job task as there is during its performance. Every element of a task has varying importance. In the appropriate balance these elements can provide the greatest level of assurance that qualified workers can safely perform required assigned tasks. This paper will list key indicators in both company documented directions and worker's implementation filtered through their skills of the trade, knowledge of the task and rules guiding their action.
Index Terms – electrical safety, NFPA 70E, OSHA, human performance, worker compliance assessments, electrical safety program
Index Terms – electrical safety, NFPA 70E, OSHA, human performance, worker compliance assessments, electrical safety program
I. INTRODUCTION
Companies routinely expend great effort and expense to hire the best-qualified workers available at the time. In decades
past the on-boarding process of these new employees consisted of high-level safety expectations mixed with pay, benefit and retirement information in one big meal. “Do this, don’t do that, sign here, now let’s get to work” was the common practice. Tracking and probing accident data in root cause analyses to discover the key missing pieces which allowed the incident to occur became an industry unto itself. Subject matter experts would be called in to assemble a snap shot of the company safety culture and recommend effective paths forward. The result was often a blind trust in recommended actions with little critical understanding by front line supervision of the day-to-day indictors they should observe and correct.
A 2015 Engineering Portal study reported in the internationally circulated electrical inspector’s IAEI magazine concluded that the number one cause of accidents is workers taking shortcuts to known and accepted safe work practices. (1)
In recent years new opportunities have emerged for those tasked with mitigating worker behaviors prior to an incident
occurrence. Certifications from at least two key players in the electrical industry have helped to raise awareness and hope
that incident free operations can be a sustainable reality. NFPA’s CESCP or Certified Electrical Safety Compliance professional program ensures those tasked with managing electrical workers have the tools, knowledge and resources
required to effectively direct activities around energized circuit conductors and parts. Although NFPA’s CESCP program is
focused on any energized work wherever it may be encountered, the primary application has been on conductors
and parts that are at ground level. The common understanding is on electrical systems covered in the companion NFPA 70, or National Electrical Code. These types of installations are primarily under the safe work practice governance of OSHA 29 CFR 1910.331 – 335 requirements. Overhead line work, commonly called “utility type” installations are more thoroughly covered under different documents targeting their unique safety issues. OSHA 29 CFR 1910.269 and IEEE C2, known as the National Electrical Safety Code (NESC) are better suited for these overhead, non-insulated and often-higher voltage types of conditions.
With accidents so prevalent and often fatal, these line workers have begun awareness campaigns on their own through
social media sites such as “Lineman Take a Stand for Safety”, “Power Lineman” and “LineJunk”. It is often thought that in the line industry the line workers are the most trained and most supervised than in any other sector of the electrical industry. And rightfully so, as their work is often done at heights and in electrical environments of greater exposure than others doing energized electrical work. Line workers are considered to be first responders and often are called to restore power after major environmental events. Public safety is at stake when power is out and restoring it as quickly as possible is the focus. Too often this “get it done quickly” mentality can allow oversights in thoroughly planning a job or safely performing the plan resulting in an accidental contact. These social media sites, among others, unofficially collect and relay to subscribers reported events when they occur. A post uploaded to their site on July 20, 2017 (2) related that in 2015,
on average a serious incident occurs every 4 days with a fatality reported every 10 days. Nearly every day a line worker
receives a reportable injury. Of the approximately 116,000 linemen and linewomen performing this work, 26 lost their
lives in 2015. The distribution of reported events among union/non-union, contractor/utility and young/old was pretty
evenly split. The number one cause of all these incidents is taking shortcuts to known and accepted safe work practices.
In recent years the Utility Safety and Operational Leadership Network, or USOLN was founded to address the unique utility
installation and maintenance worker supervisory needs. USOLN introduced the CUSP, or Certified Utility Safety
Professional certification program in hopes of meeting this critical need. The CUSP program strives to enhance
supervisory awareness of the unique hazards encountered in utility-type work with a glimpse into the mind of a typical utility worker and how they perceive work assignments and consequences.
Both of these certifications are major steps forward in developing supervisors to manage effective safe and sustainable electrical safe work practices but alone cannot fully achieve the objective.
If we are ever to understand how highly skilled, trained, competent and qualified workers manage to get themselves hurt we must first understand what elements an effective electrical safety program must contain.
past the on-boarding process of these new employees consisted of high-level safety expectations mixed with pay, benefit and retirement information in one big meal. “Do this, don’t do that, sign here, now let’s get to work” was the common practice. Tracking and probing accident data in root cause analyses to discover the key missing pieces which allowed the incident to occur became an industry unto itself. Subject matter experts would be called in to assemble a snap shot of the company safety culture and recommend effective paths forward. The result was often a blind trust in recommended actions with little critical understanding by front line supervision of the day-to-day indictors they should observe and correct.
A 2015 Engineering Portal study reported in the internationally circulated electrical inspector’s IAEI magazine concluded that the number one cause of accidents is workers taking shortcuts to known and accepted safe work practices. (1)
In recent years new opportunities have emerged for those tasked with mitigating worker behaviors prior to an incident
occurrence. Certifications from at least two key players in the electrical industry have helped to raise awareness and hope
that incident free operations can be a sustainable reality. NFPA’s CESCP or Certified Electrical Safety Compliance professional program ensures those tasked with managing electrical workers have the tools, knowledge and resources
required to effectively direct activities around energized circuit conductors and parts. Although NFPA’s CESCP program is
focused on any energized work wherever it may be encountered, the primary application has been on conductors
and parts that are at ground level. The common understanding is on electrical systems covered in the companion NFPA 70, or National Electrical Code. These types of installations are primarily under the safe work practice governance of OSHA 29 CFR 1910.331 – 335 requirements. Overhead line work, commonly called “utility type” installations are more thoroughly covered under different documents targeting their unique safety issues. OSHA 29 CFR 1910.269 and IEEE C2, known as the National Electrical Safety Code (NESC) are better suited for these overhead, non-insulated and often-higher voltage types of conditions.
With accidents so prevalent and often fatal, these line workers have begun awareness campaigns on their own through
social media sites such as “Lineman Take a Stand for Safety”, “Power Lineman” and “LineJunk”. It is often thought that in the line industry the line workers are the most trained and most supervised than in any other sector of the electrical industry. And rightfully so, as their work is often done at heights and in electrical environments of greater exposure than others doing energized electrical work. Line workers are considered to be first responders and often are called to restore power after major environmental events. Public safety is at stake when power is out and restoring it as quickly as possible is the focus. Too often this “get it done quickly” mentality can allow oversights in thoroughly planning a job or safely performing the plan resulting in an accidental contact. These social media sites, among others, unofficially collect and relay to subscribers reported events when they occur. A post uploaded to their site on July 20, 2017 (2) related that in 2015,
on average a serious incident occurs every 4 days with a fatality reported every 10 days. Nearly every day a line worker
receives a reportable injury. Of the approximately 116,000 linemen and linewomen performing this work, 26 lost their
lives in 2015. The distribution of reported events among union/non-union, contractor/utility and young/old was pretty
evenly split. The number one cause of all these incidents is taking shortcuts to known and accepted safe work practices.
In recent years the Utility Safety and Operational Leadership Network, or USOLN was founded to address the unique utility
installation and maintenance worker supervisory needs. USOLN introduced the CUSP, or Certified Utility Safety
Professional certification program in hopes of meeting this critical need. The CUSP program strives to enhance
supervisory awareness of the unique hazards encountered in utility-type work with a glimpse into the mind of a typical utility worker and how they perceive work assignments and consequences.
Both of these certifications are major steps forward in developing supervisors to manage effective safe and sustainable electrical safe work practices but alone cannot fully achieve the objective.
If we are ever to understand how highly skilled, trained, competent and qualified workers manage to get themselves hurt we must first understand what elements an effective electrical safety program must contain.
II. KEY ELEMENTS AND FAILURES
“The two most important days in a person’s life are the day they are born and the day they find out why.” (3) Adapted for
this paper’s focus, “The two most important days in a safety professional’s life are the naïve’ day you accepted the challenge and the day your efforts finally become effective.”
An effective electrical safety program (ESP) must be detailed, address all expected company worker activities around energized and de-energized parts, and be thoroughly documented. As some companies have divisions that do both line work and non-line work, both aspects should be included and provide clear guidance on who may do each type of work. The training, demonstration of skills proficiency and unique tasks now authorized to be performed once a worker successfully achieves the qualifications must be clearly communicated. Too often workers have been needlessly exposed to injury or near misses trying to do the right thing but lacking the skills to either be aware of the hazard or appropriately mitigate its potential affect.
A 2015 NFPA document from The Fire Protection Research Foundation Report titled Occupational Injuries from Electrical Shock and Arc Flash Events (4) studied work related electrical incidents from 1993 through 2013. An encouraging trend emerged as fatality rates decreased over 51% dropping from an average the first 5 years of the study of 327 per year to 161 the last 5 years. The last year reported showed a total of 141 fatalities. Much of this advancement towards a safer work environment can be attributed to better electrical safety programs, worker training and availability and consistent use of personal protective equipment.
this paper’s focus, “The two most important days in a safety professional’s life are the naïve’ day you accepted the challenge and the day your efforts finally become effective.”
An effective electrical safety program (ESP) must be detailed, address all expected company worker activities around energized and de-energized parts, and be thoroughly documented. As some companies have divisions that do both line work and non-line work, both aspects should be included and provide clear guidance on who may do each type of work. The training, demonstration of skills proficiency and unique tasks now authorized to be performed once a worker successfully achieves the qualifications must be clearly communicated. Too often workers have been needlessly exposed to injury or near misses trying to do the right thing but lacking the skills to either be aware of the hazard or appropriately mitigate its potential affect.
A 2015 NFPA document from The Fire Protection Research Foundation Report titled Occupational Injuries from Electrical Shock and Arc Flash Events (4) studied work related electrical incidents from 1993 through 2013. An encouraging trend emerged as fatality rates decreased over 51% dropping from an average the first 5 years of the study of 327 per year to 161 the last 5 years. The last year reported showed a total of 141 fatalities. Much of this advancement towards a safer work environment can be attributed to better electrical safety programs, worker training and availability and consistent use of personal protective equipment.
Fig. 1 Fatal Electrical Related Work Injuries in the US 1993 – 2013
It was additionally noted in the NFPA Research Foundation report that some ethnic groups are disproportionality experiencing higher fatality rates than other groups. Sadly, among Hispanic workers the rates are on the rise. To arrive at
a workable solution employers must continue to dig deeper into the “why” a worker does what they do, not just the “how” a specific task must be done.
In the last 10 plus years, beginning with large and filtering down to the small, companies have begun to embrace NFPA 70E as their electrical safety program. “Just following 70E” is often stated as the entirety of the ESP. By doing so the needed direction and guidance is missed. NFPA 70E is not in itself an electrical safety program. 70E is an outline of what an effective ESP must at minimum contain. Simply following personal protective equipment rules completely misses the target of de-energizing more often than is done. Additional guidance, often in the form of graphics and pictures is provided in the explanatory document, Handbook for Electrical Safety in the Workplace. (5) See Fig 2
a workable solution employers must continue to dig deeper into the “why” a worker does what they do, not just the “how” a specific task must be done.
In the last 10 plus years, beginning with large and filtering down to the small, companies have begun to embrace NFPA 70E as their electrical safety program. “Just following 70E” is often stated as the entirety of the ESP. By doing so the needed direction and guidance is missed. NFPA 70E is not in itself an electrical safety program. 70E is an outline of what an effective ESP must at minimum contain. Simply following personal protective equipment rules completely misses the target of de-energizing more often than is done. Additional guidance, often in the form of graphics and pictures is provided in the explanatory document, Handbook for Electrical Safety in the Workplace. (5) See Fig 2
Fig 2. House of Electrical Safety
An electrical safety program, according to NFPA 70E, contains at minimum the following elements. (6)
1. Documented general guidance that directs activity appropriate to the risk associated with electrical hazards.
a. In layman’s terms, the ESP must determine what types of electrical equipment or systems a worker may be
exposed and thoroughly detail how work tasks on those types of equipment or systems will be accomplished. A
very common comment heard by this writer and a fellow colleague who both have worked with dozens of
electrical contractors and companies large and small is “We don’t do that type of work very often so it’s not
covered in our book”. More often it is related, “We’ve trained our workers to follow 70E so any additional guidance in an ESP makes it too prescriptive and possibly will confuse rather than be more clear.” The reality
these companies don’t yet grasp is that NFPA 70E is a standard that must be interpreted by the employer to be
applied appropriately by their workers.
2. Elements that consider conditions of maintenance of electrical equipment and systems
a. How a worker determines equipment and system condition prior to performing a task is a key element in their
risk assessment procedures. Applicable sections of 2016 NFPA 70B, Recommended Practice for Electrical System
Maintenance (7) must be included in worker training and field documentation such as Job Safety Analysis
forms to be effective.
3. Guidelines for Awareness and Self-Discipline
a. Most company policies and procedures include “Fit For Duty” criteria such as physical ability and drug and
alcohol abstinence testing but few include in their day-of-work forms these same criteria to ensure a worker’s
"Preparedness To Work”. Alertness is a key element to achieve this goal and properly addressed in 2015 NFPA
70E 130.6 (A)(2). Illness and fatigue commonly dull alertness but there is a basketful of “Other Reasons” that
should also be addressed in the ESP guidance.
4. ESP foundational principles
a. The ESP and field documentation should include checklists to include everything from appropriate pre-
performance evaluations, rules for when to deenergize, work practices to anticipate failures and guidance for
the worker to honestly assess their ability to perform the task “right here, right now”.
5. ESP effective controls
a. Examples of safe work practice controls can include training required to become initially qualified, analysis
techniques to be utilized, common examples of work tasks, when to deenergize to perform the work and risk
procedures to be applied when a worker determines if the work can be done at the present time.
6. ESP application procedures
a. The ESP must direct what a worker should reference in their assessment of the task hazards and readily
provide this information as they determine if the task can be performed. Many companies utilize Standard
Operating Procedures (SOP’s) also know as Safe Operating Procedures to ensure consistent application of the
ESP principles, controls and procedures.
7. Risk assessment procedures utilized prior to performing a task
a. Risk assessment is an employer responsibility and not a worker’s privilege. (8). Guidance on when a task may
or may not be performed cannot be assumed. It must be clearly detailed in the ESP. Skilled and qualified
workers naturally lean towards making work decisions based upon their convenience and comfort. Where clear
guidance is not given it is perceived by the employee as a de-facto consent by the employer. Plausible
deniability by the employer isn’t a good legal defense nor does it achieve safety objectives. Proactive and
detailed guidance from the employer is critical in the overall safety process.
8. Job briefing
a. Most workers seem to understand the importance of communication to ensure both their and co-worker safety.
What is often missed is important details on where the upstream overcurrent device is located and how will
work be stopped should that become necessary. Examples would be when a worker is acting outside the
planned task and when unexpected and or unauthorized persons arrive at a job site and are encroaching on
safe boundaries or the performance of safe work. Stop work authority, or SWA is a statement commonly
found in many ESPs. Sadly when it is used, many employees relate there has been some punishment or
embarrassment related to them. The overriding culture that is communicated is job production trumps
job safety. Company statements and policies must be supported by actions or the whole safety process is or
focus is perceived as “just another flavor of the month”.
9. Electrical safety auditing
a. Program auditing to ensure compliance to standards and regulations occurs at least every 3 years or when the
key industry standards and regulations change if sooner.
b. Field auditing to ensure applicability of work tasks being encountered and compliance to the ESP guidance
when work is being performed. Often we have encountered ESP’s where a company’s services have expanded
but their safe work practice guidelines (ESP) have not been updated to include direction on how a worker is to
safely perform the added tasks.
Too often ESP’s have been reviewed which are as sparse as the minimal “do’s and don’ts’s, now get to work” onboarding training of days past. The absence of guidance is always considered as consent.
The first key element to achieving sustainable safe work outcomes then is developing a work task specific ESP. Auditing the ESP effectiveness at least annually with a continual ear to relevant application to the work that is actually being done. Without this detailed and documented foundation of guidance and direction field supervisors and safety managers rely upon their own interpretation. All the while workers simply carry on as usual perceiving the guidance supervisors and managers to be suggestions rather than the expected rule.
In both line and non-line work the conclusions are consistent. When accidents occur, more often than not it is the result of workers taking a shortcut. Many companies do have a thorough, detailed and documented electrical safety program. More and more safety managers, front line supervisors and even lead workers are attaining industry certifications like NFPA CESCP and USOLN CUSP. As encouraging as this seems, documents and certifications alone cannot effectively advance an electrical safety culture.
1. Documented general guidance that directs activity appropriate to the risk associated with electrical hazards.
a. In layman’s terms, the ESP must determine what types of electrical equipment or systems a worker may be
exposed and thoroughly detail how work tasks on those types of equipment or systems will be accomplished. A
very common comment heard by this writer and a fellow colleague who both have worked with dozens of
electrical contractors and companies large and small is “We don’t do that type of work very often so it’s not
covered in our book”. More often it is related, “We’ve trained our workers to follow 70E so any additional guidance in an ESP makes it too prescriptive and possibly will confuse rather than be more clear.” The reality
these companies don’t yet grasp is that NFPA 70E is a standard that must be interpreted by the employer to be
applied appropriately by their workers.
2. Elements that consider conditions of maintenance of electrical equipment and systems
a. How a worker determines equipment and system condition prior to performing a task is a key element in their
risk assessment procedures. Applicable sections of 2016 NFPA 70B, Recommended Practice for Electrical System
Maintenance (7) must be included in worker training and field documentation such as Job Safety Analysis
forms to be effective.
3. Guidelines for Awareness and Self-Discipline
a. Most company policies and procedures include “Fit For Duty” criteria such as physical ability and drug and
alcohol abstinence testing but few include in their day-of-work forms these same criteria to ensure a worker’s
"Preparedness To Work”. Alertness is a key element to achieve this goal and properly addressed in 2015 NFPA
70E 130.6 (A)(2). Illness and fatigue commonly dull alertness but there is a basketful of “Other Reasons” that
should also be addressed in the ESP guidance.
4. ESP foundational principles
a. The ESP and field documentation should include checklists to include everything from appropriate pre-
performance evaluations, rules for when to deenergize, work practices to anticipate failures and guidance for
the worker to honestly assess their ability to perform the task “right here, right now”.
5. ESP effective controls
a. Examples of safe work practice controls can include training required to become initially qualified, analysis
techniques to be utilized, common examples of work tasks, when to deenergize to perform the work and risk
procedures to be applied when a worker determines if the work can be done at the present time.
6. ESP application procedures
a. The ESP must direct what a worker should reference in their assessment of the task hazards and readily
provide this information as they determine if the task can be performed. Many companies utilize Standard
Operating Procedures (SOP’s) also know as Safe Operating Procedures to ensure consistent application of the
ESP principles, controls and procedures.
7. Risk assessment procedures utilized prior to performing a task
a. Risk assessment is an employer responsibility and not a worker’s privilege. (8). Guidance on when a task may
or may not be performed cannot be assumed. It must be clearly detailed in the ESP. Skilled and qualified
workers naturally lean towards making work decisions based upon their convenience and comfort. Where clear
guidance is not given it is perceived by the employee as a de-facto consent by the employer. Plausible
deniability by the employer isn’t a good legal defense nor does it achieve safety objectives. Proactive and
detailed guidance from the employer is critical in the overall safety process.
8. Job briefing
a. Most workers seem to understand the importance of communication to ensure both their and co-worker safety.
What is often missed is important details on where the upstream overcurrent device is located and how will
work be stopped should that become necessary. Examples would be when a worker is acting outside the
planned task and when unexpected and or unauthorized persons arrive at a job site and are encroaching on
safe boundaries or the performance of safe work. Stop work authority, or SWA is a statement commonly
found in many ESPs. Sadly when it is used, many employees relate there has been some punishment or
embarrassment related to them. The overriding culture that is communicated is job production trumps
job safety. Company statements and policies must be supported by actions or the whole safety process is or
focus is perceived as “just another flavor of the month”.
9. Electrical safety auditing
a. Program auditing to ensure compliance to standards and regulations occurs at least every 3 years or when the
key industry standards and regulations change if sooner.
b. Field auditing to ensure applicability of work tasks being encountered and compliance to the ESP guidance
when work is being performed. Often we have encountered ESP’s where a company’s services have expanded
but their safe work practice guidelines (ESP) have not been updated to include direction on how a worker is to
safely perform the added tasks.
Too often ESP’s have been reviewed which are as sparse as the minimal “do’s and don’ts’s, now get to work” onboarding training of days past. The absence of guidance is always considered as consent.
The first key element to achieving sustainable safe work outcomes then is developing a work task specific ESP. Auditing the ESP effectiveness at least annually with a continual ear to relevant application to the work that is actually being done. Without this detailed and documented foundation of guidance and direction field supervisors and safety managers rely upon their own interpretation. All the while workers simply carry on as usual perceiving the guidance supervisors and managers to be suggestions rather than the expected rule.
In both line and non-line work the conclusions are consistent. When accidents occur, more often than not it is the result of workers taking a shortcut. Many companies do have a thorough, detailed and documented electrical safety program. More and more safety managers, front line supervisors and even lead workers are attaining industry certifications like NFPA CESCP and USOLN CUSP. As encouraging as this seems, documents and certifications alone cannot effectively advance an electrical safety culture.
III. POSITIONING FOR SUCCESS
“There are known knowns. These are things we know that we know. There are known unknowns. That is to say, there are things that we know we don’t know. But there are also unknown unknowns. There are things we don’t know we don’t know.” (9)
After an incident has occurred those delegated the task of establishing and managing the company’s safety culture often sigh, “I can’t believe that just happened”. In disbelief, they attempt to explain to their superiors that, “I guess I really don’t know what I thought I knew about our safety culture. I’m as surprised as you are that this could happen after all the efforts and resources we’ve put into this.” Waxing philosophical, as did Socrates when he reportedly said, “The only true wisdom is in knowing you know nothing” (9) denies all the current processes and knowledge we now understand about the human condition. It is not a hopeless battle when the message is appropriately delivered and consistently supported. In short, we don’t know what we don’t know.
Putting ourselves in that safety manager’s shoes, lets begin with what we think we know after putting employees through our “qualification process”. (10)
After an incident has occurred those delegated the task of establishing and managing the company’s safety culture often sigh, “I can’t believe that just happened”. In disbelief, they attempt to explain to their superiors that, “I guess I really don’t know what I thought I knew about our safety culture. I’m as surprised as you are that this could happen after all the efforts and resources we’ve put into this.” Waxing philosophical, as did Socrates when he reportedly said, “The only true wisdom is in knowing you know nothing” (9) denies all the current processes and knowledge we now understand about the human condition. It is not a hopeless battle when the message is appropriately delivered and consistently supported. In short, we don’t know what we don’t know.
Putting ourselves in that safety manager’s shoes, lets begin with what we think we know after putting employees through our “qualification process”. (10)
- Our safety program is up to date with current standards and regulations
- The safety policies and procedures are appropriately applicable to the work the employees will be assigned
- The electrical safe work practice (ESWP) field application document of the company’s overall electrical safety program (ESP) is assembled in such a way that regardless if an employee is preparing for line or non-line work they can easily find our company’s guidance
- The company ESWP has clear direction on deenergizing prior to entering specific shock or arc flash boundaries and provides even clearer direction on what procedures, permitting and permissions shall be followed when deenergizing is not possible
- All employees have received the appropriate level of training on using the ESWP to follow company ESP when performing assigned tasks
- All trained employees successfully passed a written test on our ESWP/ESP
- All trained employees successfully demonstrated their skills proficiency in compliance to companyelectrical safe work expectations including:
- Thoroughly describe the planned work steps in the JSA process with sufficient detail that simply reading the document conveys sufficient information. Review completed JSA’s pertaining to similar jobs but filled in by
different crews. The consistency of the hazard analysis and risk assessment procedures will determine the
effectiveness of the company processes.
- Appropriately performing LOTO and/or deenergizing/grounding of overhead lines following company approved
SOP
- Employees have been issued PPE appropriate for their perspective assignments and/or given responsibility for PPE used collectively to ensure proper day-of-use inspection, testing, use, maintenance, replacement and storage
- Unique field guides have been developed to allow following ESWP/ESP expectations
Formal ESP auditing is mandated at least every 3 years and annual review of applicability and compliance is required. (5) These time frames are too far apart to discover any potential gaps, which may then allow an incident to occur. How is a company to have more timely review? Without adding additional personnel, how are companies, especially smaller firms, to accomplish more timely review?
Most employees, especially ones with certifications, licenses or years of experience that still have all their fingers and toes are assumed to be safe workers. This may not entirely be the case. Without some observations, Q&A or demonstration of skills we don’t really know what we don’t yet know. The ESP should provide ways to both examine technical and safety knowledge and experience then provide guidance, or rules under which work will be accomplished. Workers approach a task using a mix of their knowledge of the task, skills and experience doing the task following company-delegated rules for performing the task. Like the familiar fire triangle, when air, fuel and heat are in the proper balance predictably a fire will result. Fig 3.
Fig 3. Fire Triangle
In the same way, when knowledge, skills and rules are in the proper balance safe work outcomes will result. Fig 4. When any of the 3 is out of balance, only bad things can occur.
Fig 4. Safety Triangle
The ESP should provide guidance on what training shall take place prior to a specific task assignment ensuring the worker has demonstrated their skills proficiency to do the work and they have knowledge of the policies, procedures and PPE to perform the task safely. Mitigating the hazard is much more than just donning PPE. Mitigating a hazard in the planning process and job safety analysis (JSA) should always follow the Hierarchy of Controls (11) and consider appropriate mix of PPE, administrative controls, barriers and engineering controls when available. Simply donning PPE and moving forward without thought of deenergizing, grounding, use of remote devices and similar equipment is not acceptable. Neither is it acceptable to wear only the comfortable part of the PPE ensemble due to extreme heat and other issues. Workers should be instructed to alter their work practices, not their PPE.
Once a worker has received the initial training with demonstration feedback of their understanding and skills proficiency, NFPA 70E states the following about retraining cycles and requirements. (12)
“Retraining in safety-related work practices and applicable changes in this standard shall be performed at intervals not to exceed 3 years. An employee shall receive additional training (or retraining) if any of the following conditions exist:
(1) The supervision of annual inspections indicate that the employee is not complying with the safety-related work practices.
(2) New technology, new types of equipment, or changes in procedures necessitate the use of safety related work practices that are
different from those that the employee would normally use.
(3) The employee needs to review tasks that are performed less often than once per year.
(4) The employee needs to review safety-related work practices that are not normally used by the employee during regular job duties.
(5) The employee’s job duties change.”
The prospect of annual worker compliance inspections can be an overwhelming task if not met with an effective process. Who performs the worker assessment and how it is presented are directly related to the process’s success. Although the workers are personally being assessed what is actually being ascertained is the effectiveness of the company ESWP/ESP in appropriately preparing their workers to analyze and mitigate a hazard prior to work performance. The results of the worker assessments are a snapshot of the company and not so much the individual worker. Each worker receives an assessment to ensure no gaps exist in their understanding and application of company expectations. The data collected is then collectively viewed as gaps in the company safety process, policies and procedures. Changes are then made in the ESWP/ESP and any subsequent documents to reflect the needed change. Where an individual may have gaps in their understanding and application, immediate coaching from the assessors closes the gap. Resources such as field guides to have readily at hand, inspection, test and procedural steps ensure consistent compliance.
Many companies that have been encountered by this author state that assessing 100% of their workers is not possible, practical or realistic given the number of workers they employ. This is usually followed by a comment such as, “We can’t hire someone just to do that job”. Sadly, they are missing the point. The answer is implementing a process, not so much adding more people. Once implemented, a process that can be implemented into the daily work tasks with a review of data collected and appropriately timed action has time and again shown to be very successful.
When positioning a company for sustainable safety success, at minimum the following should be considered.
annual assessments. In this way, the training assessment becomes the baseline and any gaps seen in subsequent
assessments reveal the individual worker compliance as well as deficiencies in anchoring the content from the
training event.
momentary and only during times while being observed. Lasting change is driven from within. Within the
organization as well as from within the individual. In every work group there are those that are looked up to for
their knowledge and expertise as well as their ability to connect with others in the group. Natural leaders are
born but many go underutilized until they are discovered. Develop work group safety champions and teach
them the safety assessment process. Empower them to coach and monitor when the front line supervisor is
occupied with other duties. It is common to place this task onto the supervisor’s shoulders but they may not be
the best person to sustain the progress. Release the leaders to enhance the work team. When given clear
expectations as well as providing means to comply workers succeed where managers and supervisors often fail.
As time progresses it is very likely others from within the work group will emerge with interest and skill to
observe ESWP in progress. Where a tool exists to capture the information, action can be taken. It is extremely
important that the assessment process be viewed as a process known for its advocacy and not any adversarial
outcomes.
training event; include key concepts in safety meetings and toolbox talks. Field guides are developed from the
assessment findings to target common gaps discovered. Assess the worker’s ability to apply the resource
and tools provided and not so much their ability to memorize what they have learned. Those that simply follow
rote rules from a written guide become transparent in their lack of proficiency. It becomes painfully evident
those that are just performing for the assessment from those that do it on a regular basis
b. Secondly the assessments should be measurable. Assign point values to the assessment content criteria. In this
way action plans are automatically implemented based upon scores achieved. Reassess workers a short time
after receiving coaching or retraining to ensure understanding.
the hazard and task, any gaps discovered should be immediately addressed. Based upon the score achieved
coaching, retraining or reassignment of allowed tasks could be the safest path forward for that worker.
performance. Electrical safety assessments are a process. Evergreen and always on going. Whenever electrical
assessments are treated as or perceived as an event the data collected is not an accurate picture of the safety
culture. It becomes simply another obstacle to overcome and get back to work practices as usual. Supervisors
should integrate safety observations into their daily tasks. When given the tools to capture the data most of the
annual assessment duties are covered in everyday activities. When a gap is uncovered in knowledge,
understanding or misapplication of a rule, it’s not a negative mark on the worker but a positive indicator that
the assessment process works and likely a near miss, incident or fatality has been averted because of it. In all
likelihood if one worker has that gap others do as well. Communicate among the assessors to have common
talking points. Put the info in a conversation. Don’t identify the worker. Add it in all work group’s daily toolbox
talk to “remember to…whatever the gap that was found”. Put in place an assessment program to assess the
overall consistency of the program. Have assessors quietly assess another’s workers or two and compare the
data. Bring in a 3rd party to spot check assessments. In this way, the effectiveness of the process is assessed.
Once a worker has received the initial training with demonstration feedback of their understanding and skills proficiency, NFPA 70E states the following about retraining cycles and requirements. (12)
“Retraining in safety-related work practices and applicable changes in this standard shall be performed at intervals not to exceed 3 years. An employee shall receive additional training (or retraining) if any of the following conditions exist:
(1) The supervision of annual inspections indicate that the employee is not complying with the safety-related work practices.
(2) New technology, new types of equipment, or changes in procedures necessitate the use of safety related work practices that are
different from those that the employee would normally use.
(3) The employee needs to review tasks that are performed less often than once per year.
(4) The employee needs to review safety-related work practices that are not normally used by the employee during regular job duties.
(5) The employee’s job duties change.”
The prospect of annual worker compliance inspections can be an overwhelming task if not met with an effective process. Who performs the worker assessment and how it is presented are directly related to the process’s success. Although the workers are personally being assessed what is actually being ascertained is the effectiveness of the company ESWP/ESP in appropriately preparing their workers to analyze and mitigate a hazard prior to work performance. The results of the worker assessments are a snapshot of the company and not so much the individual worker. Each worker receives an assessment to ensure no gaps exist in their understanding and application of company expectations. The data collected is then collectively viewed as gaps in the company safety process, policies and procedures. Changes are then made in the ESWP/ESP and any subsequent documents to reflect the needed change. Where an individual may have gaps in their understanding and application, immediate coaching from the assessors closes the gap. Resources such as field guides to have readily at hand, inspection, test and procedural steps ensure consistent compliance.
Many companies that have been encountered by this author state that assessing 100% of their workers is not possible, practical or realistic given the number of workers they employ. This is usually followed by a comment such as, “We can’t hire someone just to do that job”. Sadly, they are missing the point. The answer is implementing a process, not so much adding more people. Once implemented, a process that can be implemented into the daily work tasks with a review of data collected and appropriately timed action has time and again shown to be very successful.
When positioning a company for sustainable safety success, at minimum the following should be considered.
- 1. Ensure the assessment content and expectations have been anchored in the training event.
annual assessments. In this way, the training assessment becomes the baseline and any gaps seen in subsequent
assessments reveal the individual worker compliance as well as deficiencies in anchoring the content from the
training event.
- 2. Develop champions from within that are committed to working the process.
momentary and only during times while being observed. Lasting change is driven from within. Within the
organization as well as from within the individual. In every work group there are those that are looked up to for
their knowledge and expertise as well as their ability to connect with others in the group. Natural leaders are
born but many go underutilized until they are discovered. Develop work group safety champions and teach
them the safety assessment process. Empower them to coach and monitor when the front line supervisor is
occupied with other duties. It is common to place this task onto the supervisor’s shoulders but they may not be
the best person to sustain the progress. Release the leaders to enhance the work team. When given clear
expectations as well as providing means to comply workers succeed where managers and supervisors often fail.
As time progresses it is very likely others from within the work group will emerge with interest and skill to
observe ESWP in progress. Where a tool exists to capture the information, action can be taken. It is extremely
important that the assessment process be viewed as a process known for its advocacy and not any adversarial
outcomes.
- 3. Cultivate acceptance first through positive reinforcement and encouragement. Use stronger words and means only when this fails to produce the changes required.
training event; include key concepts in safety meetings and toolbox talks. Field guides are developed from the
assessment findings to target common gaps discovered. Assess the worker’s ability to apply the resource
and tools provided and not so much their ability to memorize what they have learned. Those that simply follow
rote rules from a written guide become transparent in their lack of proficiency. It becomes painfully evident
those that are just performing for the assessment from those that do it on a regular basis
b. Secondly the assessments should be measurable. Assign point values to the assessment content criteria. In this
way action plans are automatically implemented based upon scores achieved. Reassess workers a short time
after receiving coaching or retraining to ensure understanding.
- 4. Have immediate and long-term action plans ready to deploy as soon as assessments reveal deficiencies
the hazard and task, any gaps discovered should be immediately addressed. Based upon the score achieved
coaching, retraining or reassignment of allowed tasks could be the safest path forward for that worker.
- 5. The electrical assessment process should be done on a continual basis and not one collective time in the year.
performance. Electrical safety assessments are a process. Evergreen and always on going. Whenever electrical
assessments are treated as or perceived as an event the data collected is not an accurate picture of the safety
culture. It becomes simply another obstacle to overcome and get back to work practices as usual. Supervisors
should integrate safety observations into their daily tasks. When given the tools to capture the data most of the
annual assessment duties are covered in everyday activities. When a gap is uncovered in knowledge,
understanding or misapplication of a rule, it’s not a negative mark on the worker but a positive indicator that
the assessment process works and likely a near miss, incident or fatality has been averted because of it. In all
likelihood if one worker has that gap others do as well. Communicate among the assessors to have common
talking points. Put the info in a conversation. Don’t identify the worker. Add it in all work group’s daily toolbox
talk to “remember to…whatever the gap that was found”. Put in place an assessment program to assess the
overall consistency of the program. Have assessors quietly assess another’s workers or two and compare the
data. Bring in a 3rd party to spot check assessments. In this way, the effectiveness of the process is assessed.
IV. CONCLUSION
Safety comes in a can, I can, You can, We can be safe. (13)
It’s not really complicated but it is complex. Arriving at a working solution is not an elusive destination. Work habits and work practices are only changed as the work culture changes. Workers must be given everything required to achieve safe outcomes.
1. Task specific training
2. Appropriate tools, equipment and PPE
3. Field applicable documents based upon the company ESP/ESWP to guide their actions
4. Responsibility to take corrective actions when required
5. Accountability to others in the work group and company
In the same way, the company must provide itself the resources and personnel to:
1. Ensure technical competencies for the worker task assignments
2. Compete, thorough and well indexed ESP
3. ESWP guidance for any electrical work that will be accomplished under company oversight
4. An electrical assessment process to gauge compliance and uncover any gaps
5. Commitment to put in place any action plans required achieving the highest level of electrical safe work
practice compliance.
Changing a culture takes time, stay the course. The outcome is worth the effort.
1. Task specific training
2. Appropriate tools, equipment and PPE
3. Field applicable documents based upon the company ESP/ESWP to guide their actions
4. Responsibility to take corrective actions when required
5. Accountability to others in the work group and company
In the same way, the company must provide itself the resources and personnel to:
1. Ensure technical competencies for the worker task assignments
2. Compete, thorough and well indexed ESP
3. ESWP guidance for any electrical work that will be accomplished under company oversight
4. An electrical assessment process to gauge compliance and uncover any gaps
5. Commitment to put in place any action plans required achieving the highest level of electrical safe work
practice compliance.
Changing a culture takes time, stay the course. The outcome is worth the effort.
V. ACKNOWLEDGEMENTS
The author wishes to thank Mr. Tim McCoy, Chevron N.A. SJVBU, Electrical Inspection Supervisor and Mr. Jeffrey A. Grovom, Electrical Services and Training, LLC for their guidance, input and review of this work.
VI. REFERENCES
(1) LeRoy, Robert S., “Enhancing Electrical Safety Without Touching a Tool”, IEEE-ESW paper, ESW2016-2, 2016, page 2
(2) Social media, Facebook, https://www.facebook.com/LinemenTakeAStandforSafet y/ reposting July 20, 2017 from https://www.facebook.com/Linejunk/
(3) Attributed to Mark Twain (Samuel Langhorne Clemens 1835 - 1910), actual author unknown. https://quoteinvestigator.com/2016/06/22/why/
(4) Campbell and Dini, et al, Occupational Injuries From Electrical Shock and Arc Flash Events, The Fire Protection Research Foundation, One Batterymarch Park, Quincy, Massachusetts, 2015, page 12
(5) Fontaine, Coache, Moniz, Handbook for Electrical Safety in the Workplace, 4th Edition, page 55, Fig 110.1, 2015
(6) 2018 NFPA 70E, Standard for Electrical Safety in the Workplace, National Fire Protection Agency, 1 Battery March Park, Quincy, MA 02269-9101, Article 110,
(7) 2016 NFPA 70B, Recommended Practice for Electrical Equipment Maintenance,
(8) Wallis, David, “Hazards of Risk Assessment”, IEEE ESW2016-13, paper and presentation, 2016
(9) Donald Rumsfeld. (n.d.). BrainyQuote.com. Retrieved July 25, 2017, from BrainyQuote.com Web site: https://www.brainyquote.com/quotes/quotes/d/donaldru ms148142.html
(10) Socrates. (n.d.). BrainyQuote.com. Retrieved July 25, 2017, from BrainyQuote.com Web site: https://www.brainyquote.com/quotes/quotes/s/socrates1 01212.html
(11) 29 CFR 1910.339, OSHA definition of “qualified person”
(12) ANSI Z10, Hierarchy of Controls
(13) 2018 NFPA 70E, Standard for Electrical Safety in the Workplace, National Fire Protection Agency, 1 Battery March Park, Quincy, MA 02269-9101, Article 110.1 (K)(1)(2)
(14) Social media, Facebook, facebook.com/LinemenTakeAStandforSafety/ reposting August 12, 2015
(2) Social media, Facebook, https://www.facebook.com/LinemenTakeAStandforSafet y/ reposting July 20, 2017 from https://www.facebook.com/Linejunk/
(3) Attributed to Mark Twain (Samuel Langhorne Clemens 1835 - 1910), actual author unknown. https://quoteinvestigator.com/2016/06/22/why/
(4) Campbell and Dini, et al, Occupational Injuries From Electrical Shock and Arc Flash Events, The Fire Protection Research Foundation, One Batterymarch Park, Quincy, Massachusetts, 2015, page 12
(5) Fontaine, Coache, Moniz, Handbook for Electrical Safety in the Workplace, 4th Edition, page 55, Fig 110.1, 2015
(6) 2018 NFPA 70E, Standard for Electrical Safety in the Workplace, National Fire Protection Agency, 1 Battery March Park, Quincy, MA 02269-9101, Article 110,
(7) 2016 NFPA 70B, Recommended Practice for Electrical Equipment Maintenance,
(8) Wallis, David, “Hazards of Risk Assessment”, IEEE ESW2016-13, paper and presentation, 2016
(9) Donald Rumsfeld. (n.d.). BrainyQuote.com. Retrieved July 25, 2017, from BrainyQuote.com Web site: https://www.brainyquote.com/quotes/quotes/d/donaldru ms148142.html
(10) Socrates. (n.d.). BrainyQuote.com. Retrieved July 25, 2017, from BrainyQuote.com Web site: https://www.brainyquote.com/quotes/quotes/s/socrates1 01212.html
(11) 29 CFR 1910.339, OSHA definition of “qualified person”
(12) ANSI Z10, Hierarchy of Controls
(13) 2018 NFPA 70E, Standard for Electrical Safety in the Workplace, National Fire Protection Agency, 1 Battery March Park, Quincy, MA 02269-9101, Article 110.1 (K)(1)(2)
(14) Social media, Facebook, facebook.com/LinemenTakeAStandforSafety/ reposting August 12, 2015
VII. VITAE
Robert S. LeRoy, CESCP, CUSP is the president/CEO of LeRoy Electrical Enterprizes, Inc. He has over 46 years experience in the utility, industrial and commercial electrical systems and equipment. He has conducted over 700 classes in NEC, NFPA 70E, NFPA 70B/NETA, 1910.269, NESC, Grounding and Bonding and Hazardous Locations to thousands of students in 19 countries worldwide.
Mr. LeRoy is a master electrician, IAEI NCPCCI-2B Certified Electrical Inspector, NFPA Certified Electrical Safety Compliance Professional and Certified Utility Safety Professional. He has conducted accident reports and forensic installation and work practice studies to global clients in the utility, oil and gas and mining sectors.
He can be reached at:
Robert S LeRoy
rleroy01@gmail.com
Mr. LeRoy is a master electrician, IAEI NCPCCI-2B Certified Electrical Inspector, NFPA Certified Electrical Safety Compliance Professional and Certified Utility Safety Professional. He has conducted accident reports and forensic installation and work practice studies to global clients in the utility, oil and gas and mining sectors.
He can be reached at:
Robert S LeRoy
rleroy01@gmail.com
