Looking Beyond PPE for Crew Safety

Job hazard analysis can be the best guide to put crews on the safest path

Looking Beyond PPE for Crew Safety

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For many utilities, safety means throwing personal protective equipment at employees and setting them loose — but a little planning before the job is much more effective in ensuring employees’ protection.

“We’re always going to provide PPE to our employees, but we don’t want that to be the first line of defense for hazards, because a lot more can go wrong,” says Mike Fisher, executive vice president of service and risk for Therma. “You just open yourself up to more risk if you’re relying solely on PPE.”

Therma has a robust safety program that uses job hazard and job safety analyses — the golden standard of hazard mitigation. A job hazard analysis, in short, is a step-by-step breakdown of any given job or task, with the goal of identifying potential dangers and mitigating them.

“Identify the hazards of each step — what can potentially go wrong, what are the possible consequences, how could it happen?” Fisher says. “Then a big part of the JHA is looking at any potential contributing factors that could occur.”

Some people use job safety analysis interchangeably, but Therma differentiates the two, using JSAs for every job and JHAs for specific high-risk tasks like confined space or working from heights.

“A JSA is done anytime anybody goes out and performs any kind of work. It’s going to be the job itself, and the JHA would apply to the hazardous task,” Fisher says.

Crew members have to go through a kind of checklist. Does it involve confined space? Does it involve anything unusual in terms of fall protection? If it doesn’t, then they continue on and complete their JSA: Identify the steps involved in the work, specific hazards that need to be addressed, such as traffic control and protecting the public, and those types of general terms. Then the crews will list out what the mitigation measures are. If, during the course of their evaluation, they say they do have to enter a confined space or a dangerous situation, then a specific JHA would be written for that part of the work.

Just good practice

OSHA does not require JHAs, but says in its JHA guidance literature, “One of the best ways to determine and establish proper work procedures is to conduct a job hazard analysis. A JHA is one component of the larger commitment of a safety and health management system.”

A guide from OSHA recommends JHAs be conducted for jobs with high injury or illness rates; with potential for severe or disabling injury or illness, even without a history of accidents; where human error could lead to accident or injury; jobs new to employees or that fall under new procedures; and complex jobs requiring written instruction.

Many sources agree that including employees in the process — specifically those employees who will be physically providing the labor — is essential to successful job hazard analysis and mitigation.

It’s a sentiment that is reflected in Therma’s JHA form: “A copy of this JHA will be kept at the work site available for review upon request. This JHA will be reviewed by all workers prior to the start of activities. Should conditions change, all work is to stop until those conditions are addressed in the JHA.”

“That’s one of the things they’re trained to do — one of the main things about our JHA process is anytime there’s any kind of change in conditions, whether it’s equipment or whatever it might be, they have to stop and redo the JHA. That’s one of our policies,” Fisher says. “And it’s more than just redoing the JHA: They have to then sit down and review the changes with the workers who are involved.”

Included in typical JSA/JHA forms are tables with three columns: the operation, potential hazards and mitigation actions.

“It’s a step-by-step planning process, so essentially we walk through the tasks that are involved for that part of the work,” Fisher says. “For example, if it’s a confined-space entry where we’re going into a manhole, we have to include air monitoring, confined-space entry process, ventilation, hazards of the actual space itself, and making sure the appropriate, trained people are on standby and proper notification has been taken, in terms of notifying your rescue services and the office itself.”

Utilities have to look at all those parts and pieces, and then lastly, how likely is it that an actual hazard could occur? Look at the personnel involved — the training and experience level — along with the environment they are working in.

“That’s where you’re relying on the experience of the supervisor, collaborating with the safety professionals, and that’s how you’re going to determine the likelihood that a hazard would occur,” Fisher says.

A company of 900 employees, Therma has its own safety department, with seven safety specialists working under Fisher. They are involved in all safety planning, especially with hazardous tasks.

“The safety department needs to be involved in the planning. Specifically, when we talk about confined space, the safety department has to be involved and actually present at entry; they supervise the work,” Fisher says. “It’s kind of like a ‘go/no-go’ checklist: Have you identified the safety department; have you done your proper notifications for our policy and procedure?”

Outside of JSAs and JHAs, like many other large contractors, Therma requires reporting of accidents and near-miss incidents. These reports are then consulted and referenced in JSAs/JHAs for similar job conditions.

Breaking it down

Fisher says the first thing to analyze is if there is a safer way to perform that particular work step. If a piece of pipe needs to be cut, what tool is being used? Are you using a power tool, or can you use a hand cutter for cutting copper instead of a reciprocating saw?

“That would be an example of identifying a safer way to do something,” Fisher says. “Do you really need to go into this space at all? If you need to visualize something, can you drop one of our robotic cameras down there and do the inspection rather than putting somebody in the space?”

Beyond simply avoiding the hazard, there are three categories of hazard mitigation: engineering, administrative and equipment.

“We always look at other ways to control those hazards that don’t involve just adding PPE,” Fisher says.

For example, if there is an atmospheric hazard, one way of controlling it would be putting a crew member in a respirator. Fisher, however, says the company doesn’t take that approach.

“We look at any engineering controls we can apply first, because they are going to be the most reliable,” he says. “Like providing ventilation of that space, so you engineered the hazard out of it. If you can’t use an engineering control, then we look at an administrative control.”

OSHA identifies the following administrative controls:

  • Written operating procedures, work permits and safe work practices
  • Exposure time limitations (used most commonly to control temperature extremes and ergonomic hazards)
  • Monitoring the use of highly hazardous materials
  • Alarms, signs and warnings
  • Buddy system
  • Training

“Can we maybe schedule the work for where that hazard isn’t present when we perform the work? That would be kind of the administrative control when it comes to scheduling,” Fisher says. “And then lastly would be PPE.”

Putting all these steps to paper may seem like just another bureaucratic hassle, but utilities have an obligation to ensure workers make it home after every job, and a little due diligence is a small price to pay for peace of mind.


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