Peer To Peer Safety Campaigns
There are currently three separate peer-to-peer work groups and all three are in different stages. Plans are being made to have a safety summit this summer with all three of these work groups involved in the planning and running of this event. The focus here should be on what is working and what is not–stories from yards that have developed a good safety culture and how they did it and ways this could work in other areas. More details on this as it moves forward.
“Hold the Pull” HTP Lineman Peer to Peer
The “Hold the Pull” Advisory Committee was established and had their first meeting in November to discuss and plan future efforts. This committee met again in January and is working out plans for 2012, as well as reviewing efforts in 2011.
Eight members of the Hold the Pull Committee met in 24 meetings with hundreds of linemen from as far as Eureka and Redding to Bakersfield and Santa Maria. They met with groups as small as 8 and as large as 140 to present the HTP message.
- Held the first HTP safety steward training summit at the hall in Vacaville.
- Responded to “Hold the Pull” calls from members who needed lineman to lineman intervention.
- Launched HTP Facebook page for advisory committee and safety stewards.
- Formed HTP Advisory Committee and added two new members.
- Met with PG&E Pre-Apprentices at Livermore Training Center
Plans for 2012 include: the safety summit as mentioned above, discussions on re-visiting areas that were visited in 2011 in an effort to support the safety stewards and promote an open dialogue with this committee; and continued meetings with pre-apprentices in Livermore to get this message to new workers when they come on board.
“Control the Pressure” Gas Peer to Peer
The CTP committee has met several times in 2011 and has put together a program that they plan on taking out to the membership. They gave their first presentation at NV Energy on Nov. 28, 2011 and it was well received. This committee has worked hard and has put together a very aggressive schedule to start presentations around the PG&E system. Beginning Feb. 7 and going through the end of March this committee is planning on doing 24 presentations to the membership all across the PG&E system. This committee will also be asked to participate and help plan the safety summit this summer. Updates on their progress will be forthcoming.
Tree Trimmers Peer to Peer Meeting
On Dec. 15 the first meeting with Line Clearance Tree Trimming group met in Vacaville to discuss safety issues in that industry. Much like the other work groups the line clearance tree group identified issues that are specific to their industry, such as the perceived need to take short cuts due to the pressures put on them with the way the work is bid. A smaller workgroup has been established from this meeting and has met once already in Vacaville and is laying out the ground work on how a Peer to Peer safety campaign will work in this industry. There are unique challenges here and it appears that their message will be given at unit meetings.
First Annual Pacific Coast Safety Fest
Local Union 1245 will participate in the first annual Pacific Coast Safety Fest to take place in Dublin Ca. at Camp Parks. This will be a week-long free safety training event that will begin on Feb. 27 and run through March 2. Local 1245 will have a booth there and will be looking at kicking off some first responder training that targets police and fire and the dangers they face being the first on the scene of a utility type incident. We intend to use this forum to kick off this new safety effort entitled “Protecting those who protect us.” There will be more to come as we are still working to put this together not only for the safety fest but how this first responder training will be offered and work moving forward.
Local 1245 will also be sponsoring a trainer to put on a 4-hour training session on the NFPA 70e standard for Fire Resistant clothing. This individual is Hugh Hoagland, who is known throughout the industry for his work on the NFPA 70e standards committee.
Safety fests have been held annually in other areas and have been a huge success. It is sponsored by several groups such as OSHA, CalOSHA, US Department of Labor’s Mine Safety and Health Administration and many more. Local 1245 will be considered a Founding Sponsor for this event and will be given a place to set up a booth. It is a tremendous opportunity for our local union to be actively involved with these organizations in making this a success and possibly provide some valuable training to our community. PG&E and SMUD have also joined in on this and are active participants like Local 1245. Visit the website for this event and see what is being offered at //www.safetyfest-pacificcoast.org/index.php
Regulatory Discrepancies
We are at odds on a couple of issues regarding how the different OSHA standards are interpreted and applied by PG&E. Some of these issues if they can’t get resolved through a joint effort may require OSHA’s involvement for resolution. These issues are listed below with a brief explanation.
Qualified Persons
We have two separate issues pertaining to the term Qualified Persons (QP) and their application to work in the field.
The first involves the use of the telecomm group to service the smart meter collector units mounted on various structures, apparatuses and underground facilities throughout the system. PG&E safety contends that this work can be performed by this group using the telecomm standard and not requiring the use of any of any other standard such as the High Voltage Electrical Safety Order (HVESO), Low Voltage Electrical Safety Order (LVESO) or any other safety standard which would also include the confined space orders as well by their train of thought. They provided a portion of the standard which outlined the MADs these employees could work up to as well as other safe work practices for this work group.
In this standard which is Subchapter 21. Telecommunication Safety Orders, Article 1. Telecommunications, 8600, application it states:
(a) This article sets forth safety and health standards that apply to the work conditions, practices, means, methods, operations, installations and processes performed at telecommunications centers and at telecommunications field installations, which are located outdoors or in building spaces used for such field installations. “Center” work includes the installation, operation, maintenance, rearrangement, and removal of communications equipment and other associated equipment in telecommunications switching centers. “Field” work includes the installation, operation, maintenance, rearrangement, and removal of conductors and other equipment used for telecommunications service, and of their supporting or containing structures, overhead or underground, on public or private rights of way, including buildings or other structures.
(b) Operations or conditions not specifically covered by this Article are subject to all the applicable orders contained in the other Safety Orders, including but not limited to the following: General Industry, Construction and Electrical Safety Orders.
It is our position that by the highlighted section above that if this standard does not specifically address safety issues the electrical safety orders shall apply. At stake is when these workers are working within a MAD on a piece of equipment such as transformer there is a requirement for two workers as well as training in first aid and CPR along with other requirements. The same safety rules the electrical worker must follow when working in the same environment. The company said they would ask CalOSHA on their interpretation of this, which I encourage. We are waiting on CalOSHA’s response to this.
The second issue pertains to the use of QP’s in the power plants such as Operators. The union is in agreement that an operator can be called a QP for the purpose of working up the the MAD for QEW’s; however the company feels it is OK for these workers to violate that MAD for specific tasks. We are in complete disagreement in this position and that only workers trained in working on energized equipment shall be allowed to violate MAD provided all the applicable safety requirements are followed per the CalOSHA standard 2940 of the HVESO or 2320.2 of the LVESO. We are hopeful we can get this issue resolved quickly without the need to go to CalOSHA for clarification but have not ruled the option out if needed.
Lock Out Tag Out
The union and the company are also at somewhat of a disagreement which may require a push to change the current Lock Out/Tag Out regulations in the CalOSHA standard. According to Fed OSHA a state can have their own OSHA program; however, their standard must provide the same level of protection or greater than the fed standard. The issue at hand involves a Tag Out system only. Some refer this to the Tag plus system which is not included in the state plan under 3314.
Below are the applicable means under the federal regulation for Tag-Out only devices in the LOTO standard. There are only 2 types of control for hazardous energy that I am aware of, one of which is covered under cfr 1910.269(d)(2) which covers the electric power and generation industry and basically mirrors the general industry requirement of cfr1910.147.
The section that we feel is not being complied with is covered under .147(c)(3) Full employee protection .147(c)(3)(ii) which I provided below and can also be found in identical text under .269(d)(2)(ii)(B)(1). The employer must ensure that the tag out only would provide the same level of protection as a lock. What is taking place is a tag out system for everything with no additional safety measures in place to ensure full employee protection.
General –
1910.147(c)(1)
Energy control program. The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.
1910.147(c)(2)
Lockout/tagout.
1910.147(c)(2)(i)
If an energy isolating device is not capable of being locked out, the employer’s energy control program under paragraph (c)(1) of this section shall utilize a tagout system.
1910.147(c)(2)(ii)
If an energy isolating device is capable of being locked out, the employer’s energy control program under paragraph (c)(1) of this section shall utilize lockout, unless the employer can demonstrate that the utilization of a tagout system will provide full employee protection as set forth in paragraph (c)(3) of this section.
1910.147(c)(2)(iii)
After January 2, 1990, whenever replacement or major repair, renovation or modification of a machine or equipment is performed, and whenever new machines or equipment are installed, energy isolating devices for such machine or equipment shall be designed to accept a lockout device.
1910.147(c)(3)
Full employee protection.
1910.147(c)(3)(i)
When a tagout device is used on an energy isolating device which is capable of being locked out, the tagout device shall be attached at the same location that the lockout device would have been attached, and the employer shall demonstrate that the tagout program will provide a level of safety equivalent to that obtained by using a lockout program.
1910.147(c)(3)(ii)
In demonstrating that a level of safety is achieved in the tagout program which is equivalent to the level of safety obtained by using a lockout program, the employer shall demonstrate full compliance with all tagout-related provisions of this standard together with such additional elements as are necessary to provide the equivalent safety available from the use of a lockout device. Additional means to be considered as part of the demonstration of full employee protection shall include the implementation of additional safety measures such as the removal of an isolating circuit element, blocking of a controlling switch, opening of an extra disconnecting device, or the removal of a valve handle to reduce the likelihood of inadvertent energization.
There should be more on this issue hopefully in the coming months.
Accident Reporting
Forms and guidelines are on the website. Units should use them as part of their unit meeting and submit them to the Local 1245 Safety Committee whether or not there are accidents or concerns. This should be a standard reporting practice at every unit meeting every month. This is our best resource to share the information with the rest of the membership. We are continuing to see an increase in the number of these forms being turned in and want to thank everyone who is doing this.
Serious Accident, Fall from Pole accident report findings
The serious injury incident report involving lineman which occurred in West Sacramento on Sept. 20, 2011 has been completed. There are several things here that we can all learn from and can be seen in the findings below. This incident occurred when the injured employee inadvertently drilled through his flip line while drilling a hole for the new brace bolt, and fell approximately 25 feet to the ground as a result. This incident was determined to be preventable and is a reminder to everyone that no task is routine.
Key Findings:
1. The injured employee lost his situational awareness and drilled through his flip line. In this case, the employee failed to ensure the path of the drill bit or that the exit point was unobstructed and cleared prior to drilling. While performing job duties, employees should maintain situational awareness at all times.
2. The injured employee and his pole partner were not communicating effectively or talking through the task when the incident occurred. Prior to drilling, the injured employee and his pole partner should have discussed the bit’s exit point to ensure that there were no obstructions. It is important to communicate with your pole partner and to look out for each other. Be your “Brother’s Keeper.”
3. Work Procedures, Bulletins and Tailboards are important tools for conveying expectations. Although the double-belted work procedure did not restrict employees from working in their flip lines, there was misalignment within the Company about whether or not it was appropriate. To avoid misalignment, Leadership must maintain consistency and clarity in all communications.
4. This incident, along with ATS testing, showed that the flip line will fail when drilled through under the tension of human body weight. When tested in a similar scenario, the work positioning strap maintained integrity up to 4,800 pounds before failing (see figures 2 & 3 below). Based on these results, the work positioning strap must always be used in the working position and employees should not perform any work while in the flip line.
Corrective Actions:
1. A clarification bulletin has been developed and posted in the Technical Information Library to set clear expectations surrounding the use of the work positioning strap and flip line. This bulletin is now in effect and clearly states the following: The work positioning strap must always be used between the ground and the lowest obstacle, and must always be used when in the working position.
2. As part of the next revision, further clarification will be added to the Code of Safe Practice Rule 414 (B) “Working in Elevated Positions.”
3. Include video demonstration of a good tailboard and how to use the proper HP/Error Prevention tools as part of the 2012 Tailboard
Near Miss
The Safety Committee is encouraging everyone to report all near misses to the committee through our IBEW1245 Safety Matters web page. Anyone with a near miss should sanitize the report to omit names and companies as the intent of reporting a near miss is to provide others with information about potential hazards that members find in the field in order to make others aware of these hazards.
Submitted by,
Ralph Armstrong