Regulations, Rules and Resistance: Trends in PPE
Originally published January-February 2013
There is no shortage of rules and regulations for personal protective equipment (PPE), yet the challenge for many utilities isn’t always just making sense of all the regulations but getting employees to buy into their necessity.
“It can be difficult to change work habits that have been in existence for decades,” said Jon Beasley, superintendent, training and safety, for Electric Cities of Georgia. “In addition,
some employees don’t wear the required PPE because they lack the knowledge of the requirements and haven’t had the proper training.”
To ensure that employees wear the proper PPE at the proper times, utilities often need a strategy, Beasley said.
“First, proper PPE use begins with introductory training and apprenticeship,” he said. This should be supplemented by discussions of PPE at monthly safety meetings. According to Beasley, it can be effective to have outside people come in to speak at these meetings, such as safety consultants or representatives from state associations.
“Without this outside interaction, there is a risk that the same habits and beliefs will continue to be passed down year after year in the utility,” he said. “For example, there are still some utilities out there that are allowing linemen to work secondary voltage without rubber gloves. This is an old work procedure that they have never realized needs to be updated.”
It is also a good idea to look at past accidents and near misses to determine what kind of PPE should be worn for each job. Another tool is to introduce hazard assessments. “Even though Electric Cities of Georgia doesn’t fall under OSHA’s jurisdiction, we still use OSHA as an industry standard,” he said. “OSHA requires a job hazard analysis, which we call a hazard assessment. We encourage all utilities to look at the potential hazards on each job.”
An important supplement to this is a well thought out and up-to-date safety manual that covers PPE. “A lot of utilities have their own safety manuals,” he said. “We used to have our own, but we now use the APPA Safety Manual.”
Beasley recommended that utilities discuss PPE during job briefings before each job. A key strategy is to place the responsibility on crew leaders to make sure employees wear the proper PPE at all times. According to Beasley, some utilities hire a “cop on the block,” which is a safety person who is expected to go around to all the crews and make sure they are wearing their PPE. The problem is this approach is that the safety guy can’t be with every crew all day long.
Regardless of what steps are taken, one of the most important strategies for ensuring that employees wear the proper PPE is to have the directive come from senior management, and work its way down through the organization.
Proactive enforcement as an effective tool—”Although it’s not popular in some utilities, I am a strong proponent of enforcement,” said Beasley. Proactive enforcement entails taking disciplinary actions on employees for not wearing PPE before an accident occurs, such as coaching, followed by verbal warnings, followed by written warnings. He has found that some utilities utilize enforcement, but it is reactive enforcement, taking disciplinary steps after an accident has occurred.
“They tell the employee, ‘You should have been wearing this and that.’ However, they have been allowing him to not wear the PPE for years,” said Beasley. “So, as far as the employee is concerned, there was nothing wrong with him not wearing the proper PPE, because no one had ever enforced the requirement.” Beasley added that reactive enforcement can be part of an enforcement program, but needs to be coupled with proactive enforcement.
Ultimately, according to Beasley, the key to success in getting employees to wear PPE is consistency. Require it at all times, and come down on people who don’t wear it.
While getting employees to wear PPE in response to rules and regulations that have been in effect for a period of time can be a challenge, an even more significant challenge is getting them to wear PPE in response to new rules and regulations, a topic with which Mike Hyland, APPA senior vice president of engineering services, is well-versed. As of January 2012, the National Electrical Safety Code (NESC) for protective clothing changed. Hyland was the chair of that code process.
“There has always been the idea that you should wear [flame retardant] clothing,” said Hyland. The NESC is updated every five years. However, the 2007 code only addressed worker clothing at 1,000 volts and above. At the time, the window of opportunity to do a lot of the work on the question of 1,000 volts and below couldn’t be completed in time to get it into the code. So, a small working group was created to review 1,000 volts and below.
Before the 2012 code, according to Hyland, utilities felt that they didn’t need FR clothing for voltage under 1000 volts, or they tried to use the National Electrical Code (NEC). “The problem with using the NEC is that it is meant for inside work, not outside work,” said Hyland. “If you tried to apply the NEC to outside work, you found yourself working things dead a lot.”
After looking at data, running different scenarios, and using different measurements, the NESC working group came up with a clothing system table for voltages from 50 to 1000. This new table is in the 2012 code. All of the testing that looked at how clothing reacts to arc flashes at 277/480, which is universally considered to be a “nasty voltage,” was actually captured in the testing. “Voltage of 277/480 not only sustains an arc, but the length and severity of the flashes are incredible,” he said. “It is by far the nastiest voltage out there that utilities have to deal with when it comes to sustaining an arc
and the flash that can be created.”
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Not following rules are at times a human reaction. If we knew there were no police on the streets in the morning, we'd all speed on our way to work even though we know its dangerous.
Enforce the rules! If an employee doesn't know the rules, train him. If he won't follow the rules by choice; come down hard on him. Get rid of him if it's needed. He's a liability you can't afford. Fair, consistant enforcement of rules is the best thing a company can do for it's employees and the company as a whole.
Another problem with reactive enforcement is the adoption of broader rules to try to make even those who won't follow the rules safer. Problem is, those new rules won't be followed either.
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