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Equipment Control Processes Used for
Electrical Safe Work Practice Compliance
Copyright Material IEEE
Paper Number ESW2017- 15
Robert S. LeRoy, CESCP, CUSP
LeRoy Electrical Enterprizes, Inc.
PO Box 6025
Lakeland, Florida 338
USA
Bob@leeinc.org
Jeffrey A. Grovom
Electrical Services and Training, LLC
PO Box 1140
Helena, MT 59624
USA
jagrovom@msn.com
Abstract – World-class organizations use sophisticated
control processes to ensure their success. These companies
may use a combination of feedback and feedforward
technologies to be either reactive or proactive to disturbances
destined to upset their carefully designed systems.
One of the hardest company processes to control has proven
to be worker compliance to established safe work practices.
Recently much has been done in the way of research to
discover keys that counteract unwanted behaviors. Programs
such as “Behavioral Based Safety” and “Human Performance
Methodology” have emerged to take their rightful place in
becoming the new trend in controlling unwanted outcomes.
Unfortunately gauging the return in investment on a process
that only has a return when something bad doesn’t happen is
difficult at best.
This paper will explore the analogy and challenges of
feedback, feedforward and cascade control strategies as
applied to electrical safety. Workers that rarely encounter
energized work, such as construction and some maintenance
workers, may have gaps in understanding or other
disturbances that can impede an expected “Safe Work
Practice” in their daily routine. The same combination of
technologies that ensure plant equipment reliability and long
life can be used to produce similar results with the greatest
asset a company has, the worker.
Index Terms – Behavioral based safety, OSHA, NFPA 70E,
ANSI Z10, NFPA Research Foundation, electrical safety
management, CESCP, CUSP
I. INTRODUCTION
Perhaps the most negative word in the English language.
From the first time a young child surprisingly hears the word
“no” erupt out of their loving parents heart, a disdain for
anything that resembles control has been born. “Who better
knows the needs, wants and our true purpose than
ourselves”, we reason, and “Who are they to get in their way”?
Our needs always seem important, our wants reasonable and
our purpose so noble. “The only restraint,” we argue, “should
be measured by the outcome”. And as we settle into the
comfortable methodology of “the end justifies the means”
mentality [1], the needs go unfulfilled, the wants ignored and
most importantly, our noble purposes misunderstood.
In a production environment, loss of control may mean loss of
product. Likewise, loss of safety control in the safety process,
through noted deviation of our “controlled Process Variable”,
level of understanding and expected safe work practices, may
mean loss of life. Can this same methodology be applied to
people? Safe work practices, whether in construction or
maintenance activities involve people. People are part of a
process too.
How do organizations apply control methodology to the
people side of safe work execution? This is the challenge to
those responsible to develop and manage safety programs.
Results are too often measured with acronyms. Lost Time
Incidents (LTI), Days Away From Work (DAFW), or Total
Recordable Incident Rate (TRIR) and many other created
words are all considered effective indicators of the success or
failure of a safety program. If the goal is zero incidents, then
anything less must be considered a failure. Modifications to
our efforts and programs are introduced as a new measuring
cycle which begins in hopes to move the results in a more
positive direction. These “after the event” indicators are
acquired by feedback and may have application in some
processes. Unfortunately for the individuals who experienced
an incident and lifted the results from the zero rate expected,
the modifications to the safety process were “reactive” and
came too late.
All processes must employ elements of decision-making or
control. Our place in the process will determine the direct or
indirect nature of our activity.
For example, there is a distinct desired process setpoint in
place if the goal of a company is to produce “X” number of
widgets.
1. Directors/company owners determine the goal based
upon cost/benefit ratios,
2. Managers ensure the goal is met,
3. Lead workers watch the process details and
4. Front Line workers, those most in touch and most
physically affected by the process, produce the
results.
978-1-5090-5099-4/17/$31.00 ©2017 IEEE
2
In any well-planned process the unexpected will always occur.
Usually at the most inopportune of times. These are called
disturbances in the process and will affect the outcome if
timely adjustments are not made. Lack of knowledge or
training is just a few of the many potential disturbances
leading to undesirable results.
Who then in this process is expected to adjust their efforts
should a disturbance occur?
1. Will directors increase expenditures based upon a
single decrease in the results?
2. Are managers aware of the anomaly in a timely
manner to allow adjustments to be made?
3. Do lead workers have the observational skills and
tools required to deal with the immediate concerns?
4. Are line workers empowered to speak up and bring
attention to the disturbance prior to having any major
affect on the results?
When the goals are not met because of some disturbance in
the process, an undesired deviation in our expected outcomes
emerges. The blame game is without equal. Ineffective
without predictive methodology and measures to discover any
disturbance before it can upset the processes.
Lets take a look at process control methods commonly used
to manage production goals and see if these same process
control strategies can be applied to safety management and
expected outcomes.
II. Process Control Methodology
For what is imagined to be realized, a set of action steps must
be developed. This path to an end is called a process [2].
Taking raw materials and creating a desired product can
involve many process variables that must be controlled to
produce a cost-effective product that will sustain our business.
There are many terms that are used to describe specific
control elements and processes.
A simple definition of control [3] is to direct behaviors, or
variables to cause a person or thing to do what you want.
There may be many differing variables affecting the overall
success or outcome of the process. These are known as
process variables [2] and must be considered based upon
desired outcomes. A process variable is anything that can be
“measured”, “monitored” “manipulated” or “controlled”.
Common examples of these may be, pressure, flow,
temperature, level and as this paper will emphasize, level of
understanding and performance of expected “Safe Work
Practices” of the “Qualified Electrical Worker”. The “controlled”
process variable is the variable under control and the variable
with a specific setpoint or desired level assigned to it. Let’s
consider our desired outcome or process goal is to maintain a
specific level of water in a tank. The “controlled” process
variable in this example would be level.
As stated in this first example, if there is no need to “monitor”
or “measure” the “controlled” process variable during its
operation, the “final control element” (valve and actuator) can
be set to a predetermined state and left unattended, this is
called Open Loop [2] control. The common term of “manual”
operation is usually applied. An example might be to set the
position of the valve to 50% open and leave it unattended.
Based upon this processes specific history and known
conditions, this may be an acceptable level of control. Any
overflow is easily cleaned up and does not negatively affect
other parts of the overall process. Over time however, open
loop processes have shown to be both costly and ineffective
causing waste of product or time. [Fig 1]
Fig. 1 Open Loop Control has no Feedback
A Closed Loop process [2] incorporates receiving information,
“measuring”, the condition of the “controlled” process variable
(level) and correcting for any found deviation from desired
level, also known as the setpoint. In our valve example,
information on the “measured” level being too high at a given
moment of time would cause closing of the valve to some
degree to avoid a spill. This could be accomplished by simply
reacting to the deviation and is called feedback [6] control. A
feedback loop measures the “controlled” process variable
directly, sends the measurement to a control element (PLC)
for comparison to predetermined set point and initiates an
action to maintain the desired “controlled” process variable, or
level value, in this case. [Fig 2]
Fig 2. Closed Loop Control with Feedback
Feedback is reactive and as such must wait until a deviation
from desired level (setpoint) is noted before actions are
3
initiated. This result contains a penalty of sorts and is known
as a “feedback penalty”. Because of this “feedback penalty”,
time and product is potentially wasted when feedback alone is
employed in a control strategy.
Another control strategy often used to prevent this “feedback
penalty” “monitors” and “measures” process disturbances that
have an impact on the “controlled” process variable (level).
This strategy, known as feedforward [2] control provides a
proactive and predictive response and will signal the feedback
control element (PLC) to act before these disturbances cause
a deviation in the “controlled” process variable (level). An
example might be monitoring the outgoing flow rates in a
storage tank that can be used to adjust the input valve setting
to maintain a desired level of product in the tank. Feed
forward alone is not efficient control, as the overall results of
the “controlled” process variable are not measured. The most
effective control strategies contain both feedforward
(proactive, monitors disturbances) and feedback (reactive,
monitors the “controlled” process variable directly) elements.
Monitoring need as well as measuring the disturbances
produces greatest desirable results. [Fig 3]
Fig 3. Feedback and Feedforward Process Control
Most control processes are not as simple as our tank level
example. Many feedback and feed forward elements might be
required to gain the best results. Some elements may directly
affect the overall process whereas others affecting smaller
portions of the process are nonetheless important to the
overall objective. Higher levels of monitoring and control are
achieved by utilizing this type of control loop known as
cascade control [2]. In other words, some control elements
direct the entire process where as others simply manage a
smaller portion. All must work together with the same focus
and goal for successful control to be established and
maintained.
Process control designers utilize this type of control loop to
obtain timely information about many aspects of the process
and are able to adjust to even the smallest of disturbances.
Using cascade control, small changes in any of the process
variables have a large affect on the overall outcome of the
process. The challenge when using cascade control is in
tuning the process to cooperate with all the other control
elements. Some elements may have a lag (time-delay) effect
and their adjustments are not immediately seen. This can be
known as “step change” where small adjustments are made
which eventually have expected results to affect the process
as a whole. Designers must account for these expected
delays in their tuning process. In human terms this is called
patience. Another of those most dreaded words.
An easily identified example of this time delay would be the
act of taking a shower as compared to enjoying a bath. Both
require the water to be maintained at a specified temperature.
To minimize discomfort and the accompanying disparaging
comments, it is important to plan for the inevitable lag in
balancing the hot and cold-water variables.
Adjusting the hot or cold-water valve (variable) while taking a
shower typically results in a quick response to overall faucet
temperature. [Fig. 4]
Fig. 4 Shower water temperature quickly adjusted by
changing one variable.
When choosing a bath the overall water temperature of a
large volume must be changed where the desired temperature
is not encountered. Adding more hot or cold water will take
time to effect the entire volume of the tub. Time and patience
are required before the optimal temperature is reached. [Fig.5]
Fig. 5 Lag is encountered when variables are changed
Sophisticated and technologically advanced control processes
are now available that can provide excellent levels of
automatic control. All control processes must be appropriately
maintained or they will drift away from their intended result.
Calibration activities must be performed or the entire process
4
will fail. In other words, the success of automatic processes is
directly related to their level of attention and maintenance.
When controlling production, elements are employed that are
physically placed into the system and are easily monitored
and adjusted. Controlling the production process has a direct
impact on the product produced. A valve left in a manual
position lacks feedback to control the flow. In the same way,
workers left in a static unmonitored condition lack feedback to
control their compliance to safe work practices.
III. Process Control Applied to Safety Management
The process to enhance desired human performance has
been a bit like hitting a fast moving target. Company safety
management systems run the gamut of effectiveness. Some
are non-existent for companies that either do not know how to
begin or have not yet been caught by regulating agencies and
forced into some level of compliance. Others are proactive,
well run and maintained proving their success. Effective
safety management systems employ involvement from the top
to the bottom of the organization. Like a cascade control
process loop, each person has responsibilities and the impact
of their actions may be immediate or delayed in result. All are
crucial to the overall success. Lives and livelihoods are at
stake and nothing less than complete success is expected.
From the mid-1900’s, governing bodies began to see the need
to set higher goals for achieving acceptable levels of safety in
the workplace. Every US state had their own set of safety
rules and regulations and the results were less than desired.
One set of minimum expectations was needed and in 1971,
the US OSHA Act was passed. As long as states were as
effective in meeting the minimum goals they could retain their
own set of rules. One-half of the states opted for that
provision.
Fig 4. US Workplace Fatality data 1933 – 1999
In the years prior to the passage of the Williams-Steiger bi-
partisan Occupational Safety and Health Act in 1970,
workplace fatalities from all causes ranged from a high of
38/100,000 workers in 1937 to 18/100,000 in 1969. Along the
way new safety laws and the establishment of a federal
agency to track accidents and fatalities called the Bureau of
Labor Statistics, or BLS for short addressed small segments
of the workplace high-risk activities. [Fig 4.] [4]
With the OSH Act in place the US workplace took a giant leap
forward towards providing greater levels of safety for all
workers. Unfortunately the process to achieve those lofty
goals, “provide a workplace free from injury from the hazards
that may exist” [5] was not well realized. How an employer
would comply with that directive was left up to their own
devices. The first element to be implemented was the OSHA
Training Institute to “train compliance officers and
stakeholders on safety and health topics”. [4] The electrical
hazards proved especially difficult to both recognize then
develop appropriate protective means, as no general
directives were available. A consensus standard was needed.
Very soon OSHA approached the group that produced the
most standards utilized by the electrical industry to develop a
consensus standard for Electrical Safety Requirements for
Employee Workplaces. In 1976, the NFPA 70E was born to
provide both a guide of ideas for employers and workers alike
to follow as well as regulators to use as a compliance-
measuring tool. [6]
At the same time it was very apparent that a multi-faceted
problem could not be met with a single point of attack. It was
also recognized that this was not just a US workplace
problem. Much international input resulted in the development
of a set of Hierarchy of Controls [7] that could be applied at
many levels to eliminate, mitigate or provide appropriate
protection using products, procedures and as yet
undeveloped personal protective equipment called PPE.
Very soon key supervisors and managers from a wide cross
section of many industries began to network and share
lessons learned. Many were members of the original NFPA
70E committee or other NFPA standards committees and had
privately communicated through the years. These leading
men and women were representing either large industries or
organizations and were afforded both the time and budget to
participate in the process. As new accident reporting
techniques were being developed a slight progression
towards safety was being seen. Unfortunately to reach a
greater number of employers to affect a greater number of
workers a medium to provide an open forum to freely share
successes and failures became necessary. It was recognized
that to have the greatest impact the mission of this
organization should affect all areas of the electrical hazard
awareness and mitigation. It was long known that electrical
safety begins with innovative designs and since the IEEE [8]
was the recognized existing international organization of
which these new safety leaders were already members it was
decided to align with the IEEE-IAS [9] in formation of an
electrical safety initiative to become known as the IEEE-IAS
Electrical Safety Committee. The plan was to meet annually in
an open forum and invite stakeholders to meet and participate
in sharing new technologies, lessons learned and creative
ideas in an effort to positively change the electrical safety
culture. The first meeting of the IEEE-IAS ESW Electrical
Safety Workshop was held in Dallas, TX in 1992 with only a
handful of these visionaries present. Very soon its annual
attendance grew to hundreds of electrical engineers, safety
professionals and electrical employers representing much of
the industrialized world markets.
5
In this same time period, OSHA released newly completed
regulations for electrical workers in their construction (CFR
29-1926) and maintenance (CFR 29-1910) standards. These
standards were updated in 2007 and 2014 respectively to be
in alignment across all electrical workplace activities to lessen
any confusion of appropriate application. Today members and
participants are having positive efforts in affecting the global
electrical safety culture. Many are in leadership or decision-
making roles in key electrical standards, guides and
recommended practices such as ASTM [10], IEEE and NFPA
[11] as well as many other organizations too numerous to
mention.
To view from a high level the history of this activity over the
past 30 or 40 years it begins to take on the shape and feel of
many common industrial control processes. Visionary
designers recognized a need for a specific product, elements
such as training and standards development to provide
control, and annual meetings to determine any needed
calibration to the control elements through sharing of lessons
learned and new technologies developed from greater
understanding of the hazards. If the purpose and vision of the
IEEE-IAS ESW is to make positive changes in electrical safety
culture, what then is the real measure of its over all success?
To measure the success of any process design at least three
(3) specific indicators must be considered.
1. Did the design meet the stated goal? When
measuring the success of the ESW, are there any
indicators that progress is being made in changing
the electrical safety culture?
2. Is there reason to believe continued success can be
expected? In other words are there indications the
process success can be sustained?
3. What elements in the process were discovered that
might require greater levels of monitoring and
calibration than the others? In other words, what are
known or common disturbances to the process that
can be foreseen and mitigated prior to having any
significant affect on the process outcome?
The first measured indicator consists of declining accident and
fatality rates as reported in current statistics. OSHA and BLS
statistics indicate a reduction in overall fatality rates from
18/100,000 in 1970 to just north of 3/100,000 in 2007. [Fig.5]
Fig. 5
The Fire Protection Research Foundation of the NFPA
released a comprehensive report in March of 2015 reviewing
current electrical accident data and root cause indicators. This
report was presented by one of its authors at the IEEE-ESW
2016 conference in Jacksonville, FL. [12] [Fig 6] Data
referencing workplace fatalities specific to electrical hazards
from 1993 through 2014 shows a decline of 41%. Zero
incidents are attainable if the reasons for the fatalities that did
occur can be understood and mitigated from occurring again.
Fig 6 from ESW2016-30 presentation [12]
The first step that OSHA implemented from its inception was
to set up a training protocol for all involved. Training for
electrical workers is a key component of being considered
qualified to do the task. One of the root causes discovered in
the reviewed accidents was lack of appropriate levels of
training prior to attempting the work task. The authors of this
paper would like to suggest a deeper cause might exist.
The lack of appropriate detail in a company electrical safety
program and the absence of procedural processes, such as
criteria in the job safety analysis (JSA) and work planning
documentation, allowed the workers the freedom to proceed
unchecked, or in some cases fear of reprisal if they did raise a
question about their lack of training.
The second cause of the incidents as reported in the NFPA
Research Foundation report is a lack of or improper use of
personal protective equipment (PPE). As was suggested in
Enhancing Electrical Safety Without Touching a Tool, a
presentation at the 2016 ESW [13], PPE must be understood
as more than the clothes a worker may wear. PPE should be
considered a process more than a simple piece of equipment.
A new definition of the acronym can be utilized to illustrate this
process.
PPE
tm
(Planning – Prepare – Execute) first involves thorough
job scope definition and planning followed by appropriate
procedures for preparing the equipment, tools and clothing
required. Only after appropriate levels of planning and
preparation have been completed should the worker move
forward to execute their plan.
6
The PPE
tm
process of Planning, Preparation and Execution,
along with the company electrical safety program must give
clear guidance in this workflow process providing appropriate
procedural documentation for each step.
The third major cause involved workers performing electrical
tasks while the circuits remained energized. Workers tend to
determine their level of acceptable risk by mentally reviewing
their past experience, confidence and comfort to do the task.
“If I successfully did it before then surely it must be OK to do it
again,” they reason. Along with these conditions a worker will
also factor in additional elements such as peer pressure and
fear of speaking up which may lead to employer reprisal.
The company electrical safety program must provide clear
and detailed definitions of energized work, including examples
of common work tasks encountered. Examples of acceptable
energized work, such as diagnostic tasks and unacceptable
energized work, such as repair or adjustment tasks should be
considered. Simple statements in the electrical safety program
indicating “we don’t do energized work” is both confusing an
inaccurate. The expectation that all work is be done in an
electrically safe work condition should be the goal but the
reality is that cannot always be achieved. What a worker is to
do when encountering a task and the equipment to be worked
on, or equipment in adjacent areas remains energized should
be clearly directed and understood.
Other root cause indicators, or disturbances to the overall goal
of electrical safety can be gleaned from reviewing the NFPA
Research Foundation Report and referenced OSHA citations
as well. It appears that most if not all of those listed involve
some level of deficiency in company control elements such as
incomplete or inadequate electrical safety programs and lack
of monitoring processes to discover and recalibrate any lack
of understanding and compliance.
Overall the report of a 41% decline in fatalities is a very
positive result of the hard work done to date.
Is there reason to believe this success can be sustained or
even advanced? The answer is a resounding “YES, IF …”.
Control processes involve both a look back and a look forward
at the overall end product and within the process itself. These
are the feedback and feed forward control elements, which
are designed to work together. Some have immediate effect
whereas others have a built-in time delay as they cascade
their effectiveness upon each other and the end result.
Feedback comes too late to help those at the greatest risk
while feed forward assists in identifying the risky behaviors
implementing a course correction prior to any incident
occurrence.
Both OSHA and NFPA 70E address aspects of this feed
forward control process. Predicting what a worker may do, via
collected data acquired by feedback processes, in a given
situation depends solely on their personal work safety culture.
We all have one. Its what we are willing to do on that mid-
night shift when no one else is watching. Simply looking at the
results of a work task rather than the process utilized to get it
done will only reveal half the story. Some large work crews
consist of a field lead or foreman/supervisor whose role is to
watch the whole crew while work is being performed. An
example would be an overhead line crew operation. OSHA
has long required an annual assessment of those workers in
the CFR 29 -1910.269 standard to ensure the work task can
be completed appropriately. This type of oversight is
successful only when the supervision has been trained to look
for the right things in their observations. Most often in this type
of work the supervision has worked their way up through the
ranks. Their level of expertise and knowledge is typically very
high having been there and done that many times before.
There can be no subjectivity in the process here. All key
aspects of the assessment must be objectively seen or heard.
In this assessment process a worker’s safety memory is
conditioned to doing it the right way every time. Predicting
their actions at any given time or task is acceptably accurate
under this scenario.
Unfortunately this type of ongoing oversight is not practical
with smaller companies or crew sizes. In those scenarios it is
all hands on deck to get the job done as effectively and
efficiently as possible. 2015 NFPA 70E speaks to this
feedback and feedforward control process when considering
retraining of a qualified person is necessary. [14]
1. The supervision or annual inspections indicate that
the employee is not complying with the safety-related
work practices (feedback)
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 must employ safety-related work
practices that are not normally used during his or her
regular job duties.
Annual worker auditing to assess their level of safe work
practice compliance and skills to safely perform tasks is not
an option. This is a key “look back” feedback strategy (how
well did we teach them? Did they get it?) in the overall safety
control process. Unfortunately though, the authors have found
in their audits of many large and small electrical firms it is
rarely being done. Often times when it is being done, it is
being done incorrectly using mechanisms leaning more to the
subjective than objective criteria. “I don’t have the staff for
that” or “I hire competent workers that are highly qualified to
begin with” are common retorts. In over 1500 worker field
assessments done by the authors in the last 4 years, the
reality is much less positive. Many simply do not know or
remember the key elements of PPE daily field inspections or
required testing. Of a more critical nature are those who feel
daily testing to be either mundane or a waste of time.
Training alone with no follow up assessment (feedback)
creates an “open loop” condition lacking the needed feedback
to gauge actual desired level or setpoint, understanding, and
compliance to the expected safe work practices”.
Competency and qualification are not synonymous terms.
One means of counteracting this attitude of indifference is by
the development of checklist procedures incorporated into the
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JSA, or preparation step of the overall work process. In this
way workers are reminded of the importance supervision
places on these activities as well as documenting their
compliance to it. When an employer additionally incorporates
a process of JSA and work plan review, anomalies are seen
and patterns emerge that can be calibrated with real-time
training or coaching. The challenge is to ensure compliance is
not just routine activity with no real thought or oversight.
Simply checking a box for the sake of checking a box, a
process commonly known as “pencil whipping” has never
proven to be an activity that produces any sort of safety
compliance.
Can the success seen over the past 30 years be sustained?
Only when the employer has in place clear direction in the
form of written expectations listed in their overall safety
program. Procedural documentation, capturing data along
with assessment processes (feedback), can be used to
calibrate any misunderstanding, or non-compliance in a timely
manner (feedforward). This feedback, and feed forward
element in the control process may come as close to getting
into the head of the worker and discovering what drives their
actions than any other control process developed to date.
Working this and other new feedback and feedforward
procedures seamlessly into the existing daily routine requires
a collective creative effort by all involved. Those directing the
safety processes must embrace the expectation. Field
supervisors must objectively gather data and workers have
input into the development of documentation. In many cases
the required annual assessment activities may already be
taking place. But without the appropriate documentation that
automatically provides the needed adjustment to any
deficiencies noted its nothing more than a check in the box.
Where documentation and action plans are in place the safety
culture is moving in the right direction.
The third element to measuring our success thus far is
recognizing there are natural forces, some out of our control
working against it. In the same way that awareness training of
the electrical hazards has succeeded in convincing the
electrical worker of the consequences of their misguided
thinking, potential disturbances to the safety processes must
be foreseen and mitigated.
Workers recognize that in economically challenging times
safety and training are the first to be cut. At least that is what
they think. In reality any company process that costs money
and is not showing an acceptable rate of return should be
reviewed. And there is the rub. How does one measure the
return on a process where the only information that is
considered is simple feedback?
A comparison of the rate of decline in the fatality and accident
rates to the leading economic indicators at the time may lead
one to conclude there is some truth in this workforce
assumption. A report of one segment of the oil field accident
rate in 2014 and 2015 showed that as the economic stresses
reduced the workforce numbers and field oversight, fatality
rates went up dramatically by nearly 45%. [15] The authors
would suggest that when processes are in place, the
processes survive when manpower is changed. Company
safety champions are required to drive success but solely
relying on a champion is risky. What happens when that
champion moves on? Too often the successes are reversed.
A champion guiding established and accepted processes
sustains success beyond the time of their attendance.
As stated earlier, it is a one-sided picture to look only at the
accident or incident rate. It very well may be that the safety
culture has produced such low numbers. On the other hand it
could also be just dumb luck. By placing feedback and feed
forward control elements into the process, such as timely field
assessments (feedback) of worker’s compliance to safe work
practices driven by peer champions, a clearer picture of
disturbances and what drives the worker’s actions will emerge
(feedforward).
Other disturbances to the success of the safety process
include absence of a commitment or attention to details from
the top of an organization to its lowest level of worker
designation.
A 2013 symposium on workplace safety culture and climate
that was organized by NIOSH and the Center to Protect
Workers’ Rights identified several components that were seen
to be particularly instrumental in establishing a positive
organizational safety culture. [12]
1. Management commitment.
2. Aligning and integrating safety as an organizational
value.
3. Ensuring accountability at all levels.
4. Improve supervisory leadership.
5. Employee involvement.
6. Improving communication.
7. Training at all levels.
8. Encouraging owner and client involvement.
The quickest way to derail any initiative occurs when it is
perceived as just the “flavor of the month”. Lack of
management commitment to follow-through sets the stage for
inevitable failure. Worse yet the stage is set for failure of the
next initiative before it even starts. The cost of follow-through
may be high, especially in hard economic times. The cost of
failure is much higher.
All company processes must align with the company vision
and mission. When company gatherings include both safety
directives as well as production goals workers are left with a
mixed message. Add in a dash of economic forecasts and it’s
a recipe for disaster. Safety has to be foremost, period. When
balancing the need to share other company information in
creative and positive ways, always ice the cake at any
company meeting with a double layer of the safety message.
In this analogy of the product control process applied to safety
several elements must be designed into the system.
1. Understanding of the goal. Zero incident rates are a
desired outcome (setpoint), not just a lofty statement.
2. The hardware so to speak, or the electrical safety
program must be thorough, inclusive and endorsed
at all levels.
8
3. Feedback reactive strategies such as “gap” finding
objective and measurable assessments of worker
understanding and compliance are consistently and
fairly implemented.
4. Feedforward proactive strategies discover potential
disturbances prior to affecting the process. Such
disturbances impact a workers level of learning and
can lead to unwanted “gaps” or deviations, causing
incident rates to rise, is utilized to calibrate the feed
forward processes. Data collected in the
assessments of the worker provide valuable
feedforward information for needed adjustment or
calibration of the overall process (what caused the
found gaps?)
5. Close the Loop. Control elements (vital components
working together to achieve the desired outcomes)
are typically interconnected through some central
point to effectively communicate. Safety committees
must be empowered to affect any changes required
in the process to ensure process success.
6. Cascade strategies Change takes time. Control
processes by design are meant to function without
human interaction. Understand the time-delay affect
between different control elements and the need for
manual control or adjustment as necessary.
IV. Conclusion: From the “C-Suite to C-Street”
The first step in incorporating process control methodology
into a safety management system is acknowledging what
process control engineers have known from the beginning.
Process control is a cost of doing business. In safety
processes the immediate return is hard to ascertain. The
positive value of a company’s bottom line can be wiped out by
just one incident. Feedforward processes can be used to
predict potential worker actions based on known disturbances
discovered from collected data when applied with objective
measures.
For any safety process to be a sustainable success it must be
mentored and modeled at every level with a company
organization. Electrical safety isn’t just applied on the plant
floor. It applies in the CEO suite, the offices, the production
line all the way to the plant gate leading to the local streets. A
company safety program must direct all activities for everyone
when exposure to electrical hazards is present. Successful
safety programs involve a team effort at all levels.
TEAM
tm
1. Teach
a. Training appropriate at all levels with
documentation of understanding and
demonstration of skills proficiency
2. Embrace
a. The electrical safety program must be
endorsed at all levels and embraced as
possible
3. Assess
a. Develop objective and measurable tools
that can be implemented into the daily work
process to obtain predictive information
4. Measure
a. Maintenance of any process element
requires occasional calibration. Measure
what is seen today against the affect it may
have on others.
Organizations such as the IEEE-IAS Electrical Safety
Committee through the electrical safety workshops have
provided valuable tools to advance changing the electrical
culture. Insight into safety program development and
integration, electrical hazard understanding and mitigation by
implementing advanced technological design, work practice
changes and the appropriate use of available protective
equipment is showing a positive result. Hearing presenters
fight back the tears openly sharing where their control process
failed in hopes that it will never happen again. Networking and
building relationships with peers comprising this global
community is enhancing communication among the entire
industry. The IEEE-ESW is an example of a control process in
itself.
Implementing effective safety cultures and work practices take
time and patience. By adherence to meticulous planning,
consistent training, accurate measurement of compliance and
continual follow up the safety culture can be changed. Zero
incidents are attainable when organizational DNA reveals
accountability and compliance to a commitment to always
follow safe work practice processes from the C-Suite to C-
Street and beyond.
V. Acknowledgements
The authors would like to acknowledge and thank Mr. Tim
McCoy, Electrical Inspection Supervisor and Chevron N.A.,
San Joaquin Valley Business Unit in California for his
proactive approach to electrical safety. Mr. McCoy’s support
and vision guided the author’s development of electrical safety
control processes resulting in valuable data and resources
including monitoring and process calibration tools. A robust
electrical safety culture within his organizational control has
become the basis for this paper and previous presentations.
VI. REFERENCES
[1] Common Quote, origin unknown
[2] Theodore G. Dimon, Automation Systems and
Instrumentation Dictionary, Forth Edition,
International Society of Automation 2002
[3] http://www.websters-online-dictionary.org
[4] https://www.osha.gov/history
[5] Paraphrased OSHA General Duty Clause, OSH Act
of 1970, Sec.5, Duties
[6] 2015 NFPA 70E, Electrical Safety in the Workplace,
page 1
[7] ANSI Z-10 Hierarchy of controls, ANSI 2012
[8] IEEE, Institute of Electrical and Electronic Engineers
[9] IEEE-IAS, Institute of Electrical and Electronic
Engineers – Industry Application Society
[10] ASTM, American Society for Testing and Materials
[11] NFPA, National Fire Protection Agency
9
[12] ESW 2016-30, Electric Shock and Arc Flash Events,
Understanding Factors and Identifying Trends, David
Dini, Paul Brazis Jr., and Richard Campbell, page 73
“Occupational Injuries from Electric Shock and Arc
Flash Events” is available from the Fire Protection
Research Foundation: www.nfpa.org/Foundation
[13] ESW2016-02, Enhancing Electrical Safety Without
Touching a Tool, Robert LeRoy, CESCP
[14] 2015 NFPA 70E, 110.2 (D)(3)
[15]	 http://www.wsj.com/articles/oil-deaths-rise-as-
bakken-boom-fades-1426187062
VII. VITAE
Robert S. LeRoy, CESCP, CUSP is the CEO of LeRoy
Electrical Enterprizes, Inc. He is an independent electrical
safety and code compliance consultant. He has 44 years
experience in the utility, industrial and commercial electrical
systems and equipment. During his nearly 20 years with a
utility generating facility Mr. LeRoy was an active member and
leader of the utility’s voluntary emergency response team as
first response to chemical, fire and medical emergencies.
Responding to countless emergency situations has given him
a passion for safety and perspective on the role of human
behavior in averting these events.
Mr. LeRoy is a master electrician, IAEI NCPCCI-2B Certified
Electrical Inspector, NFPA Certified Electrical Safety
Compliance Professional, Certified Utility Safety Professional
and a member of NFPA, IAEI, ASSE, USOLN and IEEE. He
has worked with several international clients to adapt US
based NFPA electrical standards (NEC, 70B electrical
maintenance practices and 70E electrical safe work practices)
in melding them with local country regulations. Mr. LeRoy has
conducted accident reports and forensic installation and work
practice studies to assist clients in identifying any deficiencies
and develop processes and procedures to remediate any
gaps to establishing a safer work environment.
Jeffrey (Jeff) A. Grovom, master electrician and owner of
Electrical Services and Training, LLC, provides electrical and
instrumentation support for global clients. He has over 37
years in the electrical trade with 20 years providing training,
consultation services to clients worldwide. He has served two
state sponsored apprenticeships (Industrial Electrical and
instrumentation). Mr. Grovom was the Electrical and
Instrumentation Sup. of mining operations for Mt. Tunnels
Mining and an active voluntary member of the mine
emergency response team, providing first response to
chemical, fire and medical emergencies. Other duties included
being a member of the National Ski Patrol. Mr. Grovom
worked as the Electrical Apprenticeship Instructor at the
Montana Electrical JATC (IBEW/NECA) teaching each of the
five years of the curriculum. He also taught Electrical and
Instrumentation at Southern Alberta Institute of Technology
(SAIT) McPhail school of Energy in Calgary, Alberta.
Mr. Grovom is Senior Lead Electrical Instructor/Consultant at
National Technology Transfer (NTT Training), Inc (20 yrs.). He
is a part time instructor for the Lawrence Berkeley National
Lab in Berkeley, CA. teaching the Qualified Electrical Worker
(QEW) program. He is a recognized electrical and
instrumentation subject matter expert with a global client base
and a member of NFPA and IEEE.
Mr. Grovom is working with co-author Robert LeRoy in
providing electrical safety program development and electrical
safety field assessment processes to gauge worker
compliance to global clients. Both authors have developed
classes and curriculum and conducted several hundred
classes in NEC, NFPA 70E, NFPA 70B/NETA, 1910.269,
NESC, Grounding and Bonding and Hazardous Locations to
thousands of students worldwide.
.

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ESW2017-15 - 2016-11-04

  • 1. Equipment Control Processes Used for Electrical Safe Work Practice Compliance Copyright Material IEEE Paper Number ESW2017- 15 Robert S. LeRoy, CESCP, CUSP LeRoy Electrical Enterprizes, Inc. PO Box 6025 Lakeland, Florida 338 USA Bob@leeinc.org Jeffrey A. Grovom Electrical Services and Training, LLC PO Box 1140 Helena, MT 59624 USA jagrovom@msn.com Abstract – World-class organizations use sophisticated control processes to ensure their success. These companies may use a combination of feedback and feedforward technologies to be either reactive or proactive to disturbances destined to upset their carefully designed systems. One of the hardest company processes to control has proven to be worker compliance to established safe work practices. Recently much has been done in the way of research to discover keys that counteract unwanted behaviors. Programs such as “Behavioral Based Safety” and “Human Performance Methodology” have emerged to take their rightful place in becoming the new trend in controlling unwanted outcomes. Unfortunately gauging the return in investment on a process that only has a return when something bad doesn’t happen is difficult at best. This paper will explore the analogy and challenges of feedback, feedforward and cascade control strategies as applied to electrical safety. Workers that rarely encounter energized work, such as construction and some maintenance workers, may have gaps in understanding or other disturbances that can impede an expected “Safe Work Practice” in their daily routine. The same combination of technologies that ensure plant equipment reliability and long life can be used to produce similar results with the greatest asset a company has, the worker. Index Terms – Behavioral based safety, OSHA, NFPA 70E, ANSI Z10, NFPA Research Foundation, electrical safety management, CESCP, CUSP I. INTRODUCTION Perhaps the most negative word in the English language. From the first time a young child surprisingly hears the word “no” erupt out of their loving parents heart, a disdain for anything that resembles control has been born. “Who better knows the needs, wants and our true purpose than ourselves”, we reason, and “Who are they to get in their way”? Our needs always seem important, our wants reasonable and our purpose so noble. “The only restraint,” we argue, “should be measured by the outcome”. And as we settle into the comfortable methodology of “the end justifies the means” mentality [1], the needs go unfulfilled, the wants ignored and most importantly, our noble purposes misunderstood. In a production environment, loss of control may mean loss of product. Likewise, loss of safety control in the safety process, through noted deviation of our “controlled Process Variable”, level of understanding and expected safe work practices, may mean loss of life. Can this same methodology be applied to people? Safe work practices, whether in construction or maintenance activities involve people. People are part of a process too. How do organizations apply control methodology to the people side of safe work execution? This is the challenge to those responsible to develop and manage safety programs. Results are too often measured with acronyms. Lost Time Incidents (LTI), Days Away From Work (DAFW), or Total Recordable Incident Rate (TRIR) and many other created words are all considered effective indicators of the success or failure of a safety program. If the goal is zero incidents, then anything less must be considered a failure. Modifications to our efforts and programs are introduced as a new measuring cycle which begins in hopes to move the results in a more positive direction. These “after the event” indicators are acquired by feedback and may have application in some processes. Unfortunately for the individuals who experienced an incident and lifted the results from the zero rate expected, the modifications to the safety process were “reactive” and came too late. All processes must employ elements of decision-making or control. Our place in the process will determine the direct or indirect nature of our activity. For example, there is a distinct desired process setpoint in place if the goal of a company is to produce “X” number of widgets. 1. Directors/company owners determine the goal based upon cost/benefit ratios, 2. Managers ensure the goal is met, 3. Lead workers watch the process details and 4. Front Line workers, those most in touch and most physically affected by the process, produce the results. 978-1-5090-5099-4/17/$31.00 ©2017 IEEE
  • 2. 2 In any well-planned process the unexpected will always occur. Usually at the most inopportune of times. These are called disturbances in the process and will affect the outcome if timely adjustments are not made. Lack of knowledge or training is just a few of the many potential disturbances leading to undesirable results. Who then in this process is expected to adjust their efforts should a disturbance occur? 1. Will directors increase expenditures based upon a single decrease in the results? 2. Are managers aware of the anomaly in a timely manner to allow adjustments to be made? 3. Do lead workers have the observational skills and tools required to deal with the immediate concerns? 4. Are line workers empowered to speak up and bring attention to the disturbance prior to having any major affect on the results? When the goals are not met because of some disturbance in the process, an undesired deviation in our expected outcomes emerges. The blame game is without equal. Ineffective without predictive methodology and measures to discover any disturbance before it can upset the processes. Lets take a look at process control methods commonly used to manage production goals and see if these same process control strategies can be applied to safety management and expected outcomes. II. Process Control Methodology For what is imagined to be realized, a set of action steps must be developed. This path to an end is called a process [2]. Taking raw materials and creating a desired product can involve many process variables that must be controlled to produce a cost-effective product that will sustain our business. There are many terms that are used to describe specific control elements and processes. A simple definition of control [3] is to direct behaviors, or variables to cause a person or thing to do what you want. There may be many differing variables affecting the overall success or outcome of the process. These are known as process variables [2] and must be considered based upon desired outcomes. A process variable is anything that can be “measured”, “monitored” “manipulated” or “controlled”. Common examples of these may be, pressure, flow, temperature, level and as this paper will emphasize, level of understanding and performance of expected “Safe Work Practices” of the “Qualified Electrical Worker”. The “controlled” process variable is the variable under control and the variable with a specific setpoint or desired level assigned to it. Let’s consider our desired outcome or process goal is to maintain a specific level of water in a tank. The “controlled” process variable in this example would be level. As stated in this first example, if there is no need to “monitor” or “measure” the “controlled” process variable during its operation, the “final control element” (valve and actuator) can be set to a predetermined state and left unattended, this is called Open Loop [2] control. The common term of “manual” operation is usually applied. An example might be to set the position of the valve to 50% open and leave it unattended. Based upon this processes specific history and known conditions, this may be an acceptable level of control. Any overflow is easily cleaned up and does not negatively affect other parts of the overall process. Over time however, open loop processes have shown to be both costly and ineffective causing waste of product or time. [Fig 1] Fig. 1 Open Loop Control has no Feedback A Closed Loop process [2] incorporates receiving information, “measuring”, the condition of the “controlled” process variable (level) and correcting for any found deviation from desired level, also known as the setpoint. In our valve example, information on the “measured” level being too high at a given moment of time would cause closing of the valve to some degree to avoid a spill. This could be accomplished by simply reacting to the deviation and is called feedback [6] control. A feedback loop measures the “controlled” process variable directly, sends the measurement to a control element (PLC) for comparison to predetermined set point and initiates an action to maintain the desired “controlled” process variable, or level value, in this case. [Fig 2] Fig 2. Closed Loop Control with Feedback Feedback is reactive and as such must wait until a deviation from desired level (setpoint) is noted before actions are
  • 3. 3 initiated. This result contains a penalty of sorts and is known as a “feedback penalty”. Because of this “feedback penalty”, time and product is potentially wasted when feedback alone is employed in a control strategy. Another control strategy often used to prevent this “feedback penalty” “monitors” and “measures” process disturbances that have an impact on the “controlled” process variable (level). This strategy, known as feedforward [2] control provides a proactive and predictive response and will signal the feedback control element (PLC) to act before these disturbances cause a deviation in the “controlled” process variable (level). An example might be monitoring the outgoing flow rates in a storage tank that can be used to adjust the input valve setting to maintain a desired level of product in the tank. Feed forward alone is not efficient control, as the overall results of the “controlled” process variable are not measured. The most effective control strategies contain both feedforward (proactive, monitors disturbances) and feedback (reactive, monitors the “controlled” process variable directly) elements. Monitoring need as well as measuring the disturbances produces greatest desirable results. [Fig 3] Fig 3. Feedback and Feedforward Process Control Most control processes are not as simple as our tank level example. Many feedback and feed forward elements might be required to gain the best results. Some elements may directly affect the overall process whereas others affecting smaller portions of the process are nonetheless important to the overall objective. Higher levels of monitoring and control are achieved by utilizing this type of control loop known as cascade control [2]. In other words, some control elements direct the entire process where as others simply manage a smaller portion. All must work together with the same focus and goal for successful control to be established and maintained. Process control designers utilize this type of control loop to obtain timely information about many aspects of the process and are able to adjust to even the smallest of disturbances. Using cascade control, small changes in any of the process variables have a large affect on the overall outcome of the process. The challenge when using cascade control is in tuning the process to cooperate with all the other control elements. Some elements may have a lag (time-delay) effect and their adjustments are not immediately seen. This can be known as “step change” where small adjustments are made which eventually have expected results to affect the process as a whole. Designers must account for these expected delays in their tuning process. In human terms this is called patience. Another of those most dreaded words. An easily identified example of this time delay would be the act of taking a shower as compared to enjoying a bath. Both require the water to be maintained at a specified temperature. To minimize discomfort and the accompanying disparaging comments, it is important to plan for the inevitable lag in balancing the hot and cold-water variables. Adjusting the hot or cold-water valve (variable) while taking a shower typically results in a quick response to overall faucet temperature. [Fig. 4] Fig. 4 Shower water temperature quickly adjusted by changing one variable. When choosing a bath the overall water temperature of a large volume must be changed where the desired temperature is not encountered. Adding more hot or cold water will take time to effect the entire volume of the tub. Time and patience are required before the optimal temperature is reached. [Fig.5] Fig. 5 Lag is encountered when variables are changed Sophisticated and technologically advanced control processes are now available that can provide excellent levels of automatic control. All control processes must be appropriately maintained or they will drift away from their intended result. Calibration activities must be performed or the entire process
  • 4. 4 will fail. In other words, the success of automatic processes is directly related to their level of attention and maintenance. When controlling production, elements are employed that are physically placed into the system and are easily monitored and adjusted. Controlling the production process has a direct impact on the product produced. A valve left in a manual position lacks feedback to control the flow. In the same way, workers left in a static unmonitored condition lack feedback to control their compliance to safe work practices. III. Process Control Applied to Safety Management The process to enhance desired human performance has been a bit like hitting a fast moving target. Company safety management systems run the gamut of effectiveness. Some are non-existent for companies that either do not know how to begin or have not yet been caught by regulating agencies and forced into some level of compliance. Others are proactive, well run and maintained proving their success. Effective safety management systems employ involvement from the top to the bottom of the organization. Like a cascade control process loop, each person has responsibilities and the impact of their actions may be immediate or delayed in result. All are crucial to the overall success. Lives and livelihoods are at stake and nothing less than complete success is expected. From the mid-1900’s, governing bodies began to see the need to set higher goals for achieving acceptable levels of safety in the workplace. Every US state had their own set of safety rules and regulations and the results were less than desired. One set of minimum expectations was needed and in 1971, the US OSHA Act was passed. As long as states were as effective in meeting the minimum goals they could retain their own set of rules. One-half of the states opted for that provision. Fig 4. US Workplace Fatality data 1933 – 1999 In the years prior to the passage of the Williams-Steiger bi- partisan Occupational Safety and Health Act in 1970, workplace fatalities from all causes ranged from a high of 38/100,000 workers in 1937 to 18/100,000 in 1969. Along the way new safety laws and the establishment of a federal agency to track accidents and fatalities called the Bureau of Labor Statistics, or BLS for short addressed small segments of the workplace high-risk activities. [Fig 4.] [4] With the OSH Act in place the US workplace took a giant leap forward towards providing greater levels of safety for all workers. Unfortunately the process to achieve those lofty goals, “provide a workplace free from injury from the hazards that may exist” [5] was not well realized. How an employer would comply with that directive was left up to their own devices. The first element to be implemented was the OSHA Training Institute to “train compliance officers and stakeholders on safety and health topics”. [4] The electrical hazards proved especially difficult to both recognize then develop appropriate protective means, as no general directives were available. A consensus standard was needed. Very soon OSHA approached the group that produced the most standards utilized by the electrical industry to develop a consensus standard for Electrical Safety Requirements for Employee Workplaces. In 1976, the NFPA 70E was born to provide both a guide of ideas for employers and workers alike to follow as well as regulators to use as a compliance- measuring tool. [6] At the same time it was very apparent that a multi-faceted problem could not be met with a single point of attack. It was also recognized that this was not just a US workplace problem. Much international input resulted in the development of a set of Hierarchy of Controls [7] that could be applied at many levels to eliminate, mitigate or provide appropriate protection using products, procedures and as yet undeveloped personal protective equipment called PPE. Very soon key supervisors and managers from a wide cross section of many industries began to network and share lessons learned. Many were members of the original NFPA 70E committee or other NFPA standards committees and had privately communicated through the years. These leading men and women were representing either large industries or organizations and were afforded both the time and budget to participate in the process. As new accident reporting techniques were being developed a slight progression towards safety was being seen. Unfortunately to reach a greater number of employers to affect a greater number of workers a medium to provide an open forum to freely share successes and failures became necessary. It was recognized that to have the greatest impact the mission of this organization should affect all areas of the electrical hazard awareness and mitigation. It was long known that electrical safety begins with innovative designs and since the IEEE [8] was the recognized existing international organization of which these new safety leaders were already members it was decided to align with the IEEE-IAS [9] in formation of an electrical safety initiative to become known as the IEEE-IAS Electrical Safety Committee. The plan was to meet annually in an open forum and invite stakeholders to meet and participate in sharing new technologies, lessons learned and creative ideas in an effort to positively change the electrical safety culture. The first meeting of the IEEE-IAS ESW Electrical Safety Workshop was held in Dallas, TX in 1992 with only a handful of these visionaries present. Very soon its annual attendance grew to hundreds of electrical engineers, safety professionals and electrical employers representing much of the industrialized world markets.
  • 5. 5 In this same time period, OSHA released newly completed regulations for electrical workers in their construction (CFR 29-1926) and maintenance (CFR 29-1910) standards. These standards were updated in 2007 and 2014 respectively to be in alignment across all electrical workplace activities to lessen any confusion of appropriate application. Today members and participants are having positive efforts in affecting the global electrical safety culture. Many are in leadership or decision- making roles in key electrical standards, guides and recommended practices such as ASTM [10], IEEE and NFPA [11] as well as many other organizations too numerous to mention. To view from a high level the history of this activity over the past 30 or 40 years it begins to take on the shape and feel of many common industrial control processes. Visionary designers recognized a need for a specific product, elements such as training and standards development to provide control, and annual meetings to determine any needed calibration to the control elements through sharing of lessons learned and new technologies developed from greater understanding of the hazards. If the purpose and vision of the IEEE-IAS ESW is to make positive changes in electrical safety culture, what then is the real measure of its over all success? To measure the success of any process design at least three (3) specific indicators must be considered. 1. Did the design meet the stated goal? When measuring the success of the ESW, are there any indicators that progress is being made in changing the electrical safety culture? 2. Is there reason to believe continued success can be expected? In other words are there indications the process success can be sustained? 3. What elements in the process were discovered that might require greater levels of monitoring and calibration than the others? In other words, what are known or common disturbances to the process that can be foreseen and mitigated prior to having any significant affect on the process outcome? The first measured indicator consists of declining accident and fatality rates as reported in current statistics. OSHA and BLS statistics indicate a reduction in overall fatality rates from 18/100,000 in 1970 to just north of 3/100,000 in 2007. [Fig.5] Fig. 5 The Fire Protection Research Foundation of the NFPA released a comprehensive report in March of 2015 reviewing current electrical accident data and root cause indicators. This report was presented by one of its authors at the IEEE-ESW 2016 conference in Jacksonville, FL. [12] [Fig 6] Data referencing workplace fatalities specific to electrical hazards from 1993 through 2014 shows a decline of 41%. Zero incidents are attainable if the reasons for the fatalities that did occur can be understood and mitigated from occurring again. Fig 6 from ESW2016-30 presentation [12] The first step that OSHA implemented from its inception was to set up a training protocol for all involved. Training for electrical workers is a key component of being considered qualified to do the task. One of the root causes discovered in the reviewed accidents was lack of appropriate levels of training prior to attempting the work task. The authors of this paper would like to suggest a deeper cause might exist. The lack of appropriate detail in a company electrical safety program and the absence of procedural processes, such as criteria in the job safety analysis (JSA) and work planning documentation, allowed the workers the freedom to proceed unchecked, or in some cases fear of reprisal if they did raise a question about their lack of training. The second cause of the incidents as reported in the NFPA Research Foundation report is a lack of or improper use of personal protective equipment (PPE). As was suggested in Enhancing Electrical Safety Without Touching a Tool, a presentation at the 2016 ESW [13], PPE must be understood as more than the clothes a worker may wear. PPE should be considered a process more than a simple piece of equipment. A new definition of the acronym can be utilized to illustrate this process. PPE tm (Planning – Prepare – Execute) first involves thorough job scope definition and planning followed by appropriate procedures for preparing the equipment, tools and clothing required. Only after appropriate levels of planning and preparation have been completed should the worker move forward to execute their plan.
  • 6. 6 The PPE tm process of Planning, Preparation and Execution, along with the company electrical safety program must give clear guidance in this workflow process providing appropriate procedural documentation for each step. The third major cause involved workers performing electrical tasks while the circuits remained energized. Workers tend to determine their level of acceptable risk by mentally reviewing their past experience, confidence and comfort to do the task. “If I successfully did it before then surely it must be OK to do it again,” they reason. Along with these conditions a worker will also factor in additional elements such as peer pressure and fear of speaking up which may lead to employer reprisal. The company electrical safety program must provide clear and detailed definitions of energized work, including examples of common work tasks encountered. Examples of acceptable energized work, such as diagnostic tasks and unacceptable energized work, such as repair or adjustment tasks should be considered. Simple statements in the electrical safety program indicating “we don’t do energized work” is both confusing an inaccurate. The expectation that all work is be done in an electrically safe work condition should be the goal but the reality is that cannot always be achieved. What a worker is to do when encountering a task and the equipment to be worked on, or equipment in adjacent areas remains energized should be clearly directed and understood. Other root cause indicators, or disturbances to the overall goal of electrical safety can be gleaned from reviewing the NFPA Research Foundation Report and referenced OSHA citations as well. It appears that most if not all of those listed involve some level of deficiency in company control elements such as incomplete or inadequate electrical safety programs and lack of monitoring processes to discover and recalibrate any lack of understanding and compliance. Overall the report of a 41% decline in fatalities is a very positive result of the hard work done to date. Is there reason to believe this success can be sustained or even advanced? The answer is a resounding “YES, IF …”. Control processes involve both a look back and a look forward at the overall end product and within the process itself. These are the feedback and feed forward control elements, which are designed to work together. Some have immediate effect whereas others have a built-in time delay as they cascade their effectiveness upon each other and the end result. Feedback comes too late to help those at the greatest risk while feed forward assists in identifying the risky behaviors implementing a course correction prior to any incident occurrence. Both OSHA and NFPA 70E address aspects of this feed forward control process. Predicting what a worker may do, via collected data acquired by feedback processes, in a given situation depends solely on their personal work safety culture. We all have one. Its what we are willing to do on that mid- night shift when no one else is watching. Simply looking at the results of a work task rather than the process utilized to get it done will only reveal half the story. Some large work crews consist of a field lead or foreman/supervisor whose role is to watch the whole crew while work is being performed. An example would be an overhead line crew operation. OSHA has long required an annual assessment of those workers in the CFR 29 -1910.269 standard to ensure the work task can be completed appropriately. This type of oversight is successful only when the supervision has been trained to look for the right things in their observations. Most often in this type of work the supervision has worked their way up through the ranks. Their level of expertise and knowledge is typically very high having been there and done that many times before. There can be no subjectivity in the process here. All key aspects of the assessment must be objectively seen or heard. In this assessment process a worker’s safety memory is conditioned to doing it the right way every time. Predicting their actions at any given time or task is acceptably accurate under this scenario. Unfortunately this type of ongoing oversight is not practical with smaller companies or crew sizes. In those scenarios it is all hands on deck to get the job done as effectively and efficiently as possible. 2015 NFPA 70E speaks to this feedback and feedforward control process when considering retraining of a qualified person is necessary. [14] 1. The supervision or annual inspections indicate that the employee is not complying with the safety-related work practices (feedback) 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 must employ safety-related work practices that are not normally used during his or her regular job duties. Annual worker auditing to assess their level of safe work practice compliance and skills to safely perform tasks is not an option. This is a key “look back” feedback strategy (how well did we teach them? Did they get it?) in the overall safety control process. Unfortunately though, the authors have found in their audits of many large and small electrical firms it is rarely being done. Often times when it is being done, it is being done incorrectly using mechanisms leaning more to the subjective than objective criteria. “I don’t have the staff for that” or “I hire competent workers that are highly qualified to begin with” are common retorts. In over 1500 worker field assessments done by the authors in the last 4 years, the reality is much less positive. Many simply do not know or remember the key elements of PPE daily field inspections or required testing. Of a more critical nature are those who feel daily testing to be either mundane or a waste of time. Training alone with no follow up assessment (feedback) creates an “open loop” condition lacking the needed feedback to gauge actual desired level or setpoint, understanding, and compliance to the expected safe work practices”. Competency and qualification are not synonymous terms. One means of counteracting this attitude of indifference is by the development of checklist procedures incorporated into the
  • 7. 7 JSA, or preparation step of the overall work process. In this way workers are reminded of the importance supervision places on these activities as well as documenting their compliance to it. When an employer additionally incorporates a process of JSA and work plan review, anomalies are seen and patterns emerge that can be calibrated with real-time training or coaching. The challenge is to ensure compliance is not just routine activity with no real thought or oversight. Simply checking a box for the sake of checking a box, a process commonly known as “pencil whipping” has never proven to be an activity that produces any sort of safety compliance. Can the success seen over the past 30 years be sustained? Only when the employer has in place clear direction in the form of written expectations listed in their overall safety program. Procedural documentation, capturing data along with assessment processes (feedback), can be used to calibrate any misunderstanding, or non-compliance in a timely manner (feedforward). This feedback, and feed forward element in the control process may come as close to getting into the head of the worker and discovering what drives their actions than any other control process developed to date. Working this and other new feedback and feedforward procedures seamlessly into the existing daily routine requires a collective creative effort by all involved. Those directing the safety processes must embrace the expectation. Field supervisors must objectively gather data and workers have input into the development of documentation. In many cases the required annual assessment activities may already be taking place. But without the appropriate documentation that automatically provides the needed adjustment to any deficiencies noted its nothing more than a check in the box. Where documentation and action plans are in place the safety culture is moving in the right direction. The third element to measuring our success thus far is recognizing there are natural forces, some out of our control working against it. In the same way that awareness training of the electrical hazards has succeeded in convincing the electrical worker of the consequences of their misguided thinking, potential disturbances to the safety processes must be foreseen and mitigated. Workers recognize that in economically challenging times safety and training are the first to be cut. At least that is what they think. In reality any company process that costs money and is not showing an acceptable rate of return should be reviewed. And there is the rub. How does one measure the return on a process where the only information that is considered is simple feedback? A comparison of the rate of decline in the fatality and accident rates to the leading economic indicators at the time may lead one to conclude there is some truth in this workforce assumption. A report of one segment of the oil field accident rate in 2014 and 2015 showed that as the economic stresses reduced the workforce numbers and field oversight, fatality rates went up dramatically by nearly 45%. [15] The authors would suggest that when processes are in place, the processes survive when manpower is changed. Company safety champions are required to drive success but solely relying on a champion is risky. What happens when that champion moves on? Too often the successes are reversed. A champion guiding established and accepted processes sustains success beyond the time of their attendance. As stated earlier, it is a one-sided picture to look only at the accident or incident rate. It very well may be that the safety culture has produced such low numbers. On the other hand it could also be just dumb luck. By placing feedback and feed forward control elements into the process, such as timely field assessments (feedback) of worker’s compliance to safe work practices driven by peer champions, a clearer picture of disturbances and what drives the worker’s actions will emerge (feedforward). Other disturbances to the success of the safety process include absence of a commitment or attention to details from the top of an organization to its lowest level of worker designation. A 2013 symposium on workplace safety culture and climate that was organized by NIOSH and the Center to Protect Workers’ Rights identified several components that were seen to be particularly instrumental in establishing a positive organizational safety culture. [12] 1. Management commitment. 2. Aligning and integrating safety as an organizational value. 3. Ensuring accountability at all levels. 4. Improve supervisory leadership. 5. Employee involvement. 6. Improving communication. 7. Training at all levels. 8. Encouraging owner and client involvement. The quickest way to derail any initiative occurs when it is perceived as just the “flavor of the month”. Lack of management commitment to follow-through sets the stage for inevitable failure. Worse yet the stage is set for failure of the next initiative before it even starts. The cost of follow-through may be high, especially in hard economic times. The cost of failure is much higher. All company processes must align with the company vision and mission. When company gatherings include both safety directives as well as production goals workers are left with a mixed message. Add in a dash of economic forecasts and it’s a recipe for disaster. Safety has to be foremost, period. When balancing the need to share other company information in creative and positive ways, always ice the cake at any company meeting with a double layer of the safety message. In this analogy of the product control process applied to safety several elements must be designed into the system. 1. Understanding of the goal. Zero incident rates are a desired outcome (setpoint), not just a lofty statement. 2. The hardware so to speak, or the electrical safety program must be thorough, inclusive and endorsed at all levels.
  • 8. 8 3. Feedback reactive strategies such as “gap” finding objective and measurable assessments of worker understanding and compliance are consistently and fairly implemented. 4. Feedforward proactive strategies discover potential disturbances prior to affecting the process. Such disturbances impact a workers level of learning and can lead to unwanted “gaps” or deviations, causing incident rates to rise, is utilized to calibrate the feed forward processes. Data collected in the assessments of the worker provide valuable feedforward information for needed adjustment or calibration of the overall process (what caused the found gaps?) 5. Close the Loop. Control elements (vital components working together to achieve the desired outcomes) are typically interconnected through some central point to effectively communicate. Safety committees must be empowered to affect any changes required in the process to ensure process success. 6. Cascade strategies Change takes time. Control processes by design are meant to function without human interaction. Understand the time-delay affect between different control elements and the need for manual control or adjustment as necessary. IV. Conclusion: From the “C-Suite to C-Street” The first step in incorporating process control methodology into a safety management system is acknowledging what process control engineers have known from the beginning. Process control is a cost of doing business. In safety processes the immediate return is hard to ascertain. The positive value of a company’s bottom line can be wiped out by just one incident. Feedforward processes can be used to predict potential worker actions based on known disturbances discovered from collected data when applied with objective measures. For any safety process to be a sustainable success it must be mentored and modeled at every level with a company organization. Electrical safety isn’t just applied on the plant floor. It applies in the CEO suite, the offices, the production line all the way to the plant gate leading to the local streets. A company safety program must direct all activities for everyone when exposure to electrical hazards is present. Successful safety programs involve a team effort at all levels. TEAM tm 1. Teach a. Training appropriate at all levels with documentation of understanding and demonstration of skills proficiency 2. Embrace a. The electrical safety program must be endorsed at all levels and embraced as possible 3. Assess a. Develop objective and measurable tools that can be implemented into the daily work process to obtain predictive information 4. Measure a. Maintenance of any process element requires occasional calibration. Measure what is seen today against the affect it may have on others. Organizations such as the IEEE-IAS Electrical Safety Committee through the electrical safety workshops have provided valuable tools to advance changing the electrical culture. Insight into safety program development and integration, electrical hazard understanding and mitigation by implementing advanced technological design, work practice changes and the appropriate use of available protective equipment is showing a positive result. Hearing presenters fight back the tears openly sharing where their control process failed in hopes that it will never happen again. Networking and building relationships with peers comprising this global community is enhancing communication among the entire industry. The IEEE-ESW is an example of a control process in itself. Implementing effective safety cultures and work practices take time and patience. By adherence to meticulous planning, consistent training, accurate measurement of compliance and continual follow up the safety culture can be changed. Zero incidents are attainable when organizational DNA reveals accountability and compliance to a commitment to always follow safe work practice processes from the C-Suite to C- Street and beyond. V. Acknowledgements The authors would like to acknowledge and thank Mr. Tim McCoy, Electrical Inspection Supervisor and Chevron N.A., San Joaquin Valley Business Unit in California for his proactive approach to electrical safety. Mr. McCoy’s support and vision guided the author’s development of electrical safety control processes resulting in valuable data and resources including monitoring and process calibration tools. A robust electrical safety culture within his organizational control has become the basis for this paper and previous presentations. VI. REFERENCES [1] Common Quote, origin unknown [2] Theodore G. Dimon, Automation Systems and Instrumentation Dictionary, Forth Edition, International Society of Automation 2002 [3] http://www.websters-online-dictionary.org [4] https://www.osha.gov/history [5] Paraphrased OSHA General Duty Clause, OSH Act of 1970, Sec.5, Duties [6] 2015 NFPA 70E, Electrical Safety in the Workplace, page 1 [7] ANSI Z-10 Hierarchy of controls, ANSI 2012 [8] IEEE, Institute of Electrical and Electronic Engineers [9] IEEE-IAS, Institute of Electrical and Electronic Engineers – Industry Application Society [10] ASTM, American Society for Testing and Materials [11] NFPA, National Fire Protection Agency
  • 9. 9 [12] ESW 2016-30, Electric Shock and Arc Flash Events, Understanding Factors and Identifying Trends, David Dini, Paul Brazis Jr., and Richard Campbell, page 73 “Occupational Injuries from Electric Shock and Arc Flash Events” is available from the Fire Protection Research Foundation: www.nfpa.org/Foundation [13] ESW2016-02, Enhancing Electrical Safety Without Touching a Tool, Robert LeRoy, CESCP [14] 2015 NFPA 70E, 110.2 (D)(3) [15] http://www.wsj.com/articles/oil-deaths-rise-as- bakken-boom-fades-1426187062 VII. VITAE Robert S. LeRoy, CESCP, CUSP is the CEO of LeRoy Electrical Enterprizes, Inc. He is an independent electrical safety and code compliance consultant. He has 44 years experience in the utility, industrial and commercial electrical systems and equipment. During his nearly 20 years with a utility generating facility Mr. LeRoy was an active member and leader of the utility’s voluntary emergency response team as first response to chemical, fire and medical emergencies. Responding to countless emergency situations has given him a passion for safety and perspective on the role of human behavior in averting these events. Mr. LeRoy is a master electrician, IAEI NCPCCI-2B Certified Electrical Inspector, NFPA Certified Electrical Safety Compliance Professional, Certified Utility Safety Professional and a member of NFPA, IAEI, ASSE, USOLN and IEEE. He has worked with several international clients to adapt US based NFPA electrical standards (NEC, 70B electrical maintenance practices and 70E electrical safe work practices) in melding them with local country regulations. Mr. LeRoy has conducted accident reports and forensic installation and work practice studies to assist clients in identifying any deficiencies and develop processes and procedures to remediate any gaps to establishing a safer work environment. Jeffrey (Jeff) A. Grovom, master electrician and owner of Electrical Services and Training, LLC, provides electrical and instrumentation support for global clients. He has over 37 years in the electrical trade with 20 years providing training, consultation services to clients worldwide. He has served two state sponsored apprenticeships (Industrial Electrical and instrumentation). Mr. Grovom was the Electrical and Instrumentation Sup. of mining operations for Mt. Tunnels Mining and an active voluntary member of the mine emergency response team, providing first response to chemical, fire and medical emergencies. Other duties included being a member of the National Ski Patrol. Mr. Grovom worked as the Electrical Apprenticeship Instructor at the Montana Electrical JATC (IBEW/NECA) teaching each of the five years of the curriculum. He also taught Electrical and Instrumentation at Southern Alberta Institute of Technology (SAIT) McPhail school of Energy in Calgary, Alberta. Mr. Grovom is Senior Lead Electrical Instructor/Consultant at National Technology Transfer (NTT Training), Inc (20 yrs.). He is a part time instructor for the Lawrence Berkeley National Lab in Berkeley, CA. teaching the Qualified Electrical Worker (QEW) program. He is a recognized electrical and instrumentation subject matter expert with a global client base and a member of NFPA and IEEE. Mr. Grovom is working with co-author Robert LeRoy in providing electrical safety program development and electrical safety field assessment processes to gauge worker compliance to global clients. Both authors have developed classes and curriculum and conducted several hundred classes in NEC, NFPA 70E, NFPA 70B/NETA, 1910.269, NESC, Grounding and Bonding and Hazardous Locations to thousands of students worldwide. .