Supervising Safety’s Success in Your Workplace

Under the Occupational Safety and Health law, all employers have a duty to “provide a safe workplace free from serious hazards.” But what happens when your workplace is hazardous by its very nature and those hazards cannot be eliminated?

Utility line workers face arc-flash hazards, electrocution hazards, fall hazards, crushing hazards, and heat and cold hazards; it’s a long list. Although these hazards are present and deadly, OSHA requires that employees be provided with and trained in protective measures.

In 2015, when the 1910.269 and 1926 Subpart V standards were updated, significant changes were made that increased employee safety by spelling out provisions for safe operating procedures and specific training requirements. 

• All employees covered under 1910.269 and 1926 Subpart V must be trained in and familiar with safety-related work practices, safety procedures, and other safety requirements that pertain to his or her job assignments [1910.269(a)(2)(i)(A)].
  
  
• Each employee shall also be trained in and familiar with any other safety practices, including any other applicable emergency procedures (such as pole-top and manhole rescue), that are not specifically addressed by this section but are related to his or her work and are necessary for his or her safety [1910.269(a)(2)(i)(B)].
  
  
• OSHA’s intent for these standards are that training must be provided in areas not covered by .269 but are related to their work and are necessary for employee safety. This wording remains the same under the training subsections of 1910.269, Power Generation, Transmission & Distribution and 1926 Subpart V, Power Transmission & Distribution.
  
  
• OSHA also made changes to paragraph 1910.269(a)(2)(viii), which states that the “employer shall ensure that each employee has demonstrated proficiency in the work practices involved before that employee is considered as having completed the training required by paragraph (a)(2) of this section.”
  
  
• De-energizing equipment or lines for protection; proper use, inspection, and maintenance of electrical personal protective equipment, rubber goods and insulating tools; minimum approach distances to energized lines or parts; and working in enclosed spaces are all included in both 1910.269 and 1926.950’s listed safety-related work practices. OSHA does not consider an employee to be qualified unless there is documentation of his or her demonstrated task proficiency. Also, to certify the training and qualify the employee, it’s extremely important to document information about the instructor or the method by which the employee received the training.

Both 1910.269(a)(2)(iv) and 1926.950(b)(3) state that “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.” (Italics and bold added for emphasis.) Understanding and complying with the regular supervision requirement is easy but what about the annual required employer inspection? This regulation ensures that:

• You, the employer, have the proper and adequate safeguards for employee protection.
  
  
• An employee understands the relevant safeguards, including safety-related work practices.

Safety-related work practices start with documented job briefings conducted at the jobsite, with the input of each person at that site, and by discussing the hazards of that particular job, that particular site, and our particular working group. Inspections conducted means just that – go to the jobsite and see what is happening. Talk to supervisors and employees; have frank conversations about safety, hazards, and what could be done better to make sure everyone is working to his or her potential.

In an “employer annual oversight conversation” with a couple of highly respected electrical guru-types, much wisdom and advice was shared. The end to the conversation went like this: “Margret, if a manager is indifferent when it comes to safety, typically employees will follow the safety rules that are easy and convenient and generally have the attitude of ‘just make sure we don’t get caught not following the safety rules.’” To determine whether or not a manager supports safety ask the following questions:

1. Do you attend all safety meetings?
   
   
2. Do you plan and participate in safety training classes?
   
   
3. Do you regularly observe crews on the jobsite?
   
   
4. Have you developed an annual safety meeting schedule?

If they can’t answer “yes” to all of the questions, then not only do they not have a bonafide safety culture, they’re on the path of someone getting hurt.

Can YOU answer YES to each question?