HOW MY POLICY GOT IN THE WAY OF OUR SAFETY

(Case History)
Copyright Material IEEE
Paper No. ESW2017-31

Christopher J. Pavese, P.E.

Duke Energy
1262 Cox Road
Erlanger, KY 41018
USA
c.j.pavese@ieee.org

Abstract – A case history of how after a company had two or
more work place safety policies in use, accidents started to rise
and deaths started accumulating, a personal accountability tool
we called an individual safety plan was put in place! This paper
explains how we implemented human performance and change
management in our new Safe Work Practices Program to
achieve zero significant injuries or fatalities the very next year
and a reduction in our total incident case rate.
Index Terms — Electrical Safety, Conflicting Policy, Safety
Plans, Reduction in Workplace Injuries, Personal
Accountability, Human Performance and Change Management.
The incidence rate used to benchmark with other companies
is called the total incident case rate, or TICR. While some
companies use work hours to calculate the rate, what TICR
really expresses is how many injuries and work-related
illnesses, or incidences, occur for every 100 full-time employees
per year. The standard base rate for the calculation is based on
a rate of 200,000 labor hours. This number (200,000) equates
to 100 employees, who work 40 hours per week, and who work
50 weeks per year. [2] For the rate, utilities count only injuries
or illnesses that resulted in a worker being away from work,
having work restrictions or receiving medical treatment beyond
first aid.

I. INTRODUCTION For example, if a company has 100 employees and four

At the 2015 IEEE Electrical Safety Workshop, I was
encouraged by Joe Rachford after his presentation titled “Take
Something Home”, [1] to tell the following story. In early 2012, a
Large Utility was in the process of merging with Gigantic
Energy. Shortly thereafter, Gigantic Energy began noticing a
conflict in safety and management when it came to
implementing safe work practices. The problem: there were
separate, yet combined, workforces from each company
following the policies from their respective companies, and
accidents were steadily filling the gaps. This all came to a head
in early 2014 when Gigantic Energy started recording more
than one significant injuries or fatalities (SIF) per month and its
total incident case rate (TICR), year over year, was growing at
an exorbitant rate. A safety steering committee was brought
together to come up with a working solution to put safety first
into practice.
II. BACKGROUND
A. What Is TICR?
Measuring safety performance is an important element in
achieving a company’s safety vision of a healthy and injury-free
workplace. Many employers evaluate their injury and illness
records by calculating a total incident case rate and comparing
their rate to national averages. Utility companies compare their
incidence rate to that of other comparable utilities so they can
benchmark the current state and drive improvements to safety
performance.
incidences, its TICR is 4, or four incidences for every 100 full-
time employees. If a company has 1,000 employees and 40
incidences, its TICR is 4. Again, that’s four incidences for every
100 employees.
What is a "good" rate?
• Like a golf score, the lower the number, the better.
• The top 10 percent of Edison Electrical Institute (EEI)
“large” companies (greater than 7,000 employees)
comparable to Gigantic Energy had TICRs in 2011
that were 0.56 or better.
• As of August 2012, Gigantic Energy's TICR was 0.61.
• Gigantic Energy and Large Utility combined had a
2011 TICR of 0.70.
• The average TICR for all electric utilities in 2011 was
3.0.
So a <1.0 TICR compares very favorably to other utilities. But
safety professionals and conscientiously minded executives are
never satisfied as long as employees are being injured or
experience work-related illnesses in the workplace. When
Gigantic Utility realized in late 2012 that its TICR was on the
rise, it made a very public statement: “We will continue to focus
on improving our health and safety performance until we
achieve our vision of a healthy and injury-free workplace.” It
was early 2013 when the safety steering committee was
brought together.

978-1-5090-5099-4/17/$31.00 ©2017 IEEE

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B. My Policy!
When the safety steering committee first convened, its first
challenge was to identify the problem with safety by addressing
two questions:
1) What is it? The problem was that although the two
companies had merged workforces, each had brought its own
safe work practices.
2) How to enforce it? The managers and safety
professionals were uncertain of which safety policy to enforce
whenever there was ambiguity in either policy or a clear conflict
between the two policies.
The questions as they were presented to the committee
highlighted the obvious reasons for the increase in SIF’s and
TICR’s; no one knew what to enforce. In turn, no one was
performing safety observations and thus safety was not an
integral part of job planning.
III. OUR SAFETY
The first step the committee took was to commission a gap
analysis. It was within the analysis where the conflicts were
identified amongst the 152 safety policies between the two
companies. All but 15 conflicting policies were address through
EH&S directive in the launch of a new safety policy. Prior to our
work and the new safety policy, the following is a highlight of
the conflicts found between the two policies:
• Electrical Safety PPE Testing
• Electrical Safety Certification/ Qualification/ Training
Reqs
• Electrical Cord Testing and Intervals
• Electrical Worker Oversight Requirements
• Ergonomics
• Fall Protection and Walking and Working Surfaces
• Fire Protection and Prevention
• Hazard Awareness
• Hazard Communication
• Housekeeping
• General Safety Rules
• Motor Vehicle Operations
• Office Safety
• Pedestrian Safety
• Personal Protective Equipment
• Emergency Response
• Confined Space
• Lock-out/ Tag-out
The second step the committee took was to commission an
employee survey to identify the gaps witnessed by the
workforce. The results were shared with EH&S to address by
issuing policy where policy was silent previously. Both results
were combined by EH&S to contribute to a combined policy and
the release of the new safe work practices.
A policy by itself does not serve to reduce the number of SIFs
so the committee took its third and most contributable step in
formulating the Individual Safety Plan (ISP). The ISP was
conceived from the companies’ Individual Development Plan
(IDP), a human resources tool used by the employees and
management to clearly define the employees’ career goals and
the necessary training and activities needed to achieve those
2
goals. It was through the use of the IDP’s established process
that the ISP was to be deployed. Furthermore, management
provided full support for the ISP deployment by changing the
Annual Performance Plan (APP) breakdown to reflect a 35
percent contribution to implementation and completion of the
ISP. Within the IDP/ISP process, an employee and his/her
manager would finalize the plan before March 31 and then
review at midyear. All stated courses and activities were to be
completed by October 31 for an employee to be eligible for
his/her contribution incentive as part of his/her APP. This
incentivized both the employees and managers to make a
concerted effort at putting safety first.
IV. RESULTS
Within six months, a new safe work practice program was
implemented where each employee was responsible for
developing an ISP based on his/her job classification. Within
the ISP, the employee and his/her management identified the
risks and required training and then established due dates for
completion; furthermore, senior management tied 35 percent of
the employee annual performance rating into the employee’s
adherence to the ISP’s implementation and completion.
A new policy within itself wasn’t the key that inspired the
changes in the workplace. Rather, the support came from the
human factors around each individual’s safety and how they
were responsible for developing a plan. The ISP’s included:
need for continued education, approval to purchase PPE and
had the full support of upper management. Those three keys
brought forth through the ISP tool were to credit for inspiring the
changes in the workplace. As an additional benefit, they were
fundamental in serving not only to reduce the number of
accidents and injuries; but also for improved moral.
Gigantic Energy as a whole reported zero SIFs in 2015!
V. CONCLUSIONS
Key take-away Objectives:
• A safety policy serves no one if everyone is not on the
same page.
• Human performance has a significant benefit for
personal safety by: [3]
o Provides tools & techniques to minimize
errors and prevent harm
o Helps focus our mental approach for doing
safe work
• More Deliberate thought and
action
• Better Awareness of potential
consequences and Risks
• Improved recognition of error-
likely situations and error traps
o Enables us to get it done right, the first time,
safely doing quality work, that produces
reliable & timely results
 • Change management will be highly effective by
ensuring: [4]
o Senior management’s commitment and
leadership
o Management is involved and understands
the benefits
o That the cost benefit is clearly identified
• ISPs tied in to annual evaluations like IDP get support!

VI. ACKNOWLEDGMENTS

I would like to take this opportunity to thank the following:

Laura Price, marketing communications manager at Duke

Energy, for her service as editor and corporate communications
release.
Jarheer Jomma for his friendship and encouragement to
present at the next conference.
Joe Rachford for his motivational message to “Get involved”
and for his long-time friendship.

VII. REFERENCES

[1] Butch Collins and Joe Rachford, “Take Something Home,”

IEEE Electrical Safety Workshop 2015 ESW2015-08
[2] OSHA 1960.2(j) “The Term of Incident Rates,” United
States Department of Labor, Occupational Safety and
Health Administration, Washington DC: OSHA
[3] Bob Fitzgerald, “The Influence of Human Performance on
Safety,” TAUC Summer Summit 8-13-2015
[4] Terry Becker and Chris Davis, “Electrical Safety – A
Program Development Guide,” IEEE Electrical Safety
Workshop 2015 ESW2015-30

VIII. VITA

Christopher (Chris) J. Pavese, PE (S’06-M’07) is currently

serving as a contractor and project safety oversight coordinator
at Duke Energy. He received an electrician’s license in 1999,
an electrical engineering degree in 2004, a general engineering
degree in 2007, a Master’s degree in electrical power
transmission and distribution in 2009 from Gonzaga University,
and an MBA in 2010. Mr. Pavese brings more than 25 years of
design and management experience on industrial, commercial
and institutional electrical projects. His experience includes
conceptual studies for project viability, design improvement,
analytical studies, and compliance administration. He is a
member of the Standard working groups IEEE P1584 – Guild
for Performing Arc-Flash Hazard Calculations and P1458 –
Recommended Practice for the Selection, Field Testing, and
Life Expectancy of Molded Case Circuit Breakers for Industrial
Applications, a member of the ESW Occupational Safety and
Health subcommittee and a registered professional engineer in
the State of Kentucky.