10 Steps to a Better Safety Program

About 350 electrical-related fatalities occur each year, and one of every five workplace fatalities involves a construction worker, according to the Occupational Safety and Health Administration (OSHA). To protect their most valuable asset — their employees — more electrical contracting firms are starting to invest in comprehensive electrical safety programs. Stewart Burkhammer, director of the office of construction services for OSHA, says electrical contractors need to provide their electricians with the proper protective equipment, offer task-specific training, and ensure proper supervision on the construction site. Only then will the construction industry see a drop in the fatality rate.

“Electrical work is one of the most hazardous jobs in construction because you are working around energized equipment,” says Burkhammer, who previously served for 13 years as the safety director for Bechtel Corp., a San Francisco-based global engineering and construction firm. “One slip could cause a serious problem. Contractors need to be very careful, train their employees properly in the work being performed, and not assume that their workers know what they are doing.”

So how do you ensure you're doing everything possible to help improve safety at your company? You must first provide a training program for all of your employees — from the new electrical apprentices to the veteran journeyman electricians. By making safety a priority rather than an afterthought, you can protect your employees, lower your insurance rates, and comply with OSHA regulations on a construction site. These 10 steps should set you on the proper course.

1. Change your company's culture. In a challenging economy, it's easy for firms to focus on the bottom line rather than emphasizing jobsite safety. Steve Thorwegen, vice president of Fisk Electric, a Houston-based electrical contracting firm, says Fisk had a productivity, rather than a safety, culture before 1988.

   “We were more concerned about getting the job done than performing the work safely,” Thorwegen says. “We had to change the structure within the company to place the emphasis first on safety and then on productivity.”

   The company decided to formalize its safety program after its experience modification ratio (EMR) skyrocketed to 1.32. A rating of 1.0 is considered borderline, and anything above this value means a contracting firm can't work in most places. Fisk's insurance company had two options — drop Fisk or charge the firm such a hefty premium that it would drive it out of business. The company advised Fisk to start a safety program, write a safety manual, and hire a safety officer or deal with the consequences.

   To lower its EMR and avoid a surge in insurance rates, Fisk turned to a program called Supervisor Training and Accident Reduction Techniques (START). The four-part series of videos and worksheets helped the firm to identify its productivity culture and start changing to a safety culture. Everyone in the company — from the management team to the electrical apprentices — participated in the program and learned how to identify hazards on the jobsite.

   By having a formalized safety program, Fisk was able to lower its EMR to 0.27 over the course of a decade, decrease the number of citations issued by OSHA, and drop its OSHA recordable incident rate from 8.04 in 1996 to 3.21 in 2000. While the company managed to cut down on the number of accidents and citations, the transformation from a productivity to a safety culture accomplished an even more important goal — protecting the lives and well being of the electricians, Thorwegen says.

   “You get to know the electricians personally, and the last thing you want to see is anyone get injured or have their personal life affected,” he says.

2. Develop a written safety plan. OSHA doesn't require contractors to have a written safety plan, but for the benefit of the company and the workers, the company's safety program should be detailed in writing, Burkhammer says. The safety policy must concentrate on the following three areas — keep your employees safe, comply with OSHA regulations, and set levels of responsibility and authorization for different tasks. The policy should also discuss safety training, record keeping, accident investigation, and disciplinary warnings.

   To keep up with new technology and changes in safety rules and regulations, a company must regularly update its written safety plan. To make it easy to modify, a company can place its safety plan in a three-ring binder so pages can be slipped in and out easily, and save it as a Word document on their computer. Some of these plans may be one page or hundreds of pages, depending on the size and specialties of the firm. Rather than developing one safety plan that's implemented company-wide, some firms are also tailoring their policies to each individual jobsite. Burkhammer says each of Bechtel's projects he worked on had a separate safety program that addressed the work to be done on that project.

   “We didn't just have a canned program that sat on the shelf and gathered dust,” he says. “Every project had a living, breathing program that changed as the job changed.”

3. Agree on a procedure for handling an OSHA inspection. One of the worst ways to handle an OSHA inspection is to make it up as you go along, says Brooke Stauffer, executive director of standards and safety for NECA.

   “The OSHA inspector arriving on your jobsite should be seen as a normal business process,” Stauffer says. “It should not be a surprise. You should be prepared for it by having a policy in place.”

   A contractor should include a policy for handling OSHA inspections in its safety manual. The section should discuss who will be responsible for accompanying the compliance officer on an inspection, whether or not to request the inspector to get a warrant, and how an employee should behave during an inspection (see SIDEBAR below). For example, rather than allowing compliance officers to wander around by themselves, you should escort them around the jobsite. Your safety director or foreman should also carefully document the inspection with notes, photographs, or videos. If an OSHA inspector is snapping a photograph, your employee should be taking the same photo with his or her camera.

4. Educate your employees on the OSHA standards for electrical work. Fall protection, scaffolding, and ladders top the list of the 25 most cited OSHA violations in the construction industry. OSHA estimates that 2.3 million construction workers, or 65% of the construction industry, frequently work on scaffolding, and protecting these workers would prevent 4,500 injuries and 50 deaths per year. Rex Martin, general superintendent for Fisk, considers falling from ladders and scaffolding as the number two danger on a jobsite next to working on energized circuits.

   Fisk educates its electricians quarterly about ladder protection, and all of the employees must complete an orientation on ladder safety before they work in the field. Many of the weekly safety talks are also focused on fall protection. After the electricians attend the meetings, the paperwork is sent to the main office, collected on a quarterly basis, and put into binders to validate that the firm provided adequate or redundant training.

   To reduce the number of OSHA citations, firms should also focus on some of the frequently violated OSHA standards in their meetings. Burkhammer says electrical contractors need to educate their employees on how to comply with the following four standards that apply to electrical work: 1926.405, wiring methods; 1926.404, wiring design and protection (grounding and reverse polarity); 1926.403, electrical general requirements (splices, worker clearances, and marking); and 1926.416, protection of employees and working spaces (working inside an enclosed electrical cabinet and terminations). By teaching your electricians about these OSHA standards in addition to fall protection, you can lower your number of OSHA citations and protect your employees.

5. Invest in personal protective equipment. One of the key steps to building a successful safety program is to provide the necessary personal protective equipment (PPE) to your workers. For example, Fisk provides its electricians with hard hats, safety glasses, gloves, insulated tools, footwear, and outerwear so they can safely perform the job.

   To protect its electricians when they work on energized circuits, Fisk also invested about $60,000 in fire-retardant clothing and specialized face shields. The contracting firm decided to buy the new PPE after discovering that the equipment that the electricians were using wasn't rated for work on energized circuits. The electricians were wearing clear, polycarbonate, bulletproof face shields that could catch on fire and melt to the face. The fire-retardant clothing also didn't provide the appropriate level of protection. By investing in the right PPE, Fisk has been able to ensure the safety of its workers and attract clientele.

6. Carefully document when your electricians work on live circuits. One of the major hazards electricians face on a jobsite is working on energized circuits. To help firms decide when to work on live circuits, the National Fire Protection Association (NFPA) issued standard 70E, which states that all work must be performed deenergized unless a live work permit is filled out. Certain customers, however, may not be willing to turn off a circuit to allow an electrician to work deenergized. In this scenario, the electrician has three options — go ahead and work on a live circuit, wait until after office hours to turn off the electricity, or present a live work permit to the customer. By making the client authorize the live work by signing the permit, it often changes the situation.

   “A lot of what people consider major disruption in the business world is just major inconvenience,” Thorwegen says. “We're not talking about cutting off someone's life support equipment. Instead, we're talking about disrupting productivity for an hour. I'm in favor of not electrocuting people, so I'm in favor of the inconvenience.“

   To protect its electricians, Fisk enforces the method of procedure (MOP) program. Before working hot, an electrician must evaluate why the project is being done while it's energized. The individual must complete a checklist showing that he or she has notified the owner and safety manager that the team is doing the project “hot,” have all of its PPE in place, make sure its crew is trained on how to handle emergencies, and use insulated tools (Photo).

7. Hire a safety director or appoint a foreman to oversee the safety program. Burkhammer estimates that about 95% of the electrical contracting firms with 1,000 or more employees have a full-time safety professional. This safety director is responsible for overseeing and enforcing the company's safety procedures on all the company's jobsites, interfacing with governmental agencies like OSHA, updating the safety policy, educating clients about the firm's safety program, developing the training program, and handling the recordkeeping responsibilities. In addition to having a company-wide safety officer, Fisk also has a safety manager in each of its six locations. Once a month, the safety officer meets in a one-hour teleconference call with all the safety managers to discuss what is and isn't working in the safety program.

   “It keeps everyone on the same page and all of our divisions focused on safety,” Thorwegen says.

   Contractors with 250 to 1,000 employees typically have an individual who splits his or her responsibilities between safety and health and human resources, labor relations, and contract administration. Smaller companies most likely don't have the resources for a full-time safety professional, but they designate a superintendent or project manager as a safety manager on a particular project. For example, Schaeffer Electric, a St. Louis-based contractor with a total of 60 employees, appoints a general foreman to deliver daily safety talks on the construction site. These meetings cover such topics as ladder safety, open trenches, and dealing with cold weather. If the crew of electricians will be working on a task that they don't do everyday, Schaeffer asks the NECA Safety Van to visit the jobsite and offer a safety talk to the crew of three to six electricians. The van is equipped with video and sound equipment and allows contractors to select from more than 150 safety training video modules. The “classroom on wheels” is part of the St. Louis NECA chapter's Project Safety, which was developed in 1992 to provide health and safety training to contracting firms at their jobsite locations.

8. Plan weekly safety meetings. A safety meeting may only take a few minutes at the start of a workday, but it could save electricians' lives or protect them from serious injury on a construction site. Many companies often schedule weekly Tool Box Talks for Monday or Wednesday mornings. These meetings last for about five to 10 minutes, depending on the content, and can be site-specific or work task-specific. Martin says Fisk's safety officer provides each division with a Tool Box Talk for the week, and then the foreman educates the crew on such topics as fall protection and heat stress. On certain projects, the subcontractors take turns educating the construction team on different topics.

   Rather than scheduling a broad topic for each week, more companies are beginning to make their safety meetings specific to the construction project. For example, Bechtel not only has weekly Tool Box meetings for 15 minutes each Monday morning, but it also holds daily Start Card meetings in which the foreman sits down with his crew and outlines every work task for that day.

   “It's an interaction between the company and the company employees,” Burkhammer says. “Just a general topic that would apply to everyone might not catch certain problems in a certain trade, where if you do site-specific training, you're going to pick up on those specific issues that relate to that particular worker or crew of workers.”

9. Allow your employees to play an active role in developing your safety program. To implement a successful safety program, a company's management team can't write the policy, hand it out to the employees, and then store it on the shelf. The most powerful programs are ones that actively involve the employees, Burkhammer says.

   All the employees should be knowledgeable about a company's safety program and be aware of their record-keeping responsibilities. Along with making them feel like they're an active part of the program, educating employees about a company's safety policy will also be beneficial in the event of an OSHA inspection. If a compliance officer visits a site and interviews one of the electricians, he or she will then be aware of the company's safety rules and procedures and be able to answer the inspector's questions.

   Companies can also encourage participation in their safety program by asking their field employees to test out personal protective equipment. For example, Bechtel asked its workers to help design a personal fall arrest system for a construction project in Florida and try on different types of eye protection.

   “It was not just management dictating to the workers,” Burkhammer says. “It was workers and management together coming up with the best practices that everyone would use in the company.”

10. Don't be afraid to ask for help. The electrical contracting firms with the lowest number of OSHA citations and injuries didn't build their safety programs overnight. For many firms, it takes years to develop a safety culture within a company, hire a safety professional, and implement a successful training program.

To help contractors comply with the rules and regulations, OSHA has developed partnerships with Independent Electrical Contractors and NECA. OSHA will also work individually with contracting firms to help them identify workplace hazards and set up a safety and health program. Companies can also purchase safety software, read publications like the Electrical Safety Program Book published by the NFPA, or turn to local organizations that can provide support. Whatever approach they take to their safety program, firms should make safety a daily priority, Burkhammer says.

“Safety is not a hit and miss thing,” he says. “It's a culture that emulates throughout the company and through every jobsite.”

SIDEBAR: Handling an OSHA Inspection

Electrical contracting firms should be prepared, rather than surprised, by an OSHA inspection. Here's how Fisk Electric deals with an OSHA inspector who comes on the jobsite.

1. Be polite, respectful, and cooperative.

2. Ask to see the inspector's credentials and request a business card.

3. Request a copy of the citation or inspection.

4. Ask the inspector to wait while you notify the main office.

5. Attend the pre-investigative conference.

6. Remember that you have a right to a reasonable inspection. The compliance officer should conduct his or her investigation to avoid any undue disruption on the jobsite.

7. Accompany the compliance officer on the inspection.

8. Take notes throughout the inspection.

9. Attend the post-inspection conference.

SIDEBAR: Safety Tips for Electrical Contracting Firms

• Conduct spot checks of the jobsite to ensure that all the workers are performing their tasks in a safe manner.
• Get support for the safety program from the top down. If apprentices see the company president walking around the jobsite wearing a hard hat, they'll be more likely to follow by example.
• Take a few minutes at the start of each day for safety meetings. Make sure you carefully document these training sessions in the event of an OSHA inspection.
• Although it may be a significant upfront investment, purchase the necessary personal protective equipment for your employees.
• Put your safety plan in writing. Although this isn't an OSHA requirement, it can help you to formalize your safety program.