Energy Policy Act Poses Workforce Training Issues

By Drew Robb

One small part of the Energy Policy Act could send power industry firms scrambling to get their houses in order. Among the 500 ponderous pages of the Act sits the innocuous-sounding Section 1103, “Training Guidelines for Non-Nuclear Electric Energy Industry Personnel.” This section calls for the development of model personnel training guidelines to support the reliability and safety of the non-nuclear electric system. It sets requirements as to who is to be trained and demands that training pay off in terms of improved competency. Further, competency has to be demonstrated according to pre-designed metrics.

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“When you review most companies against the Act, you find that their training programs fail to measure up,” said Brad Kamph, president of Interliance Consulting, a workforce and training consultancy based in Santa Ana, CA. “If the right workforce qualification program is in place, power producers will not only avoid falling foul of the authorities with regard to Energy Policy Act Section 1103 compliance, they will actually boost employee performance and impact the bottom line.”

Unlike the rest of the Act, Section 1103 is short and sweet:

a. In General – The Secretary of Labor, in consultation with the Secretary [of Energy] and in conjunction with the electric industry and recognized employee representatives, shall develop model personnel training guidelines to support the reliability and safety of the non-nuclear electric system.

b. Requirements – The training guidelines under subsection (a) shall, at a minimum-

(1) include training requirements for workers engaged in the construction, operation, inspection, or maintenance of non-nuclear electric generation, transmission, or distribution systems, including requirements relation to-

a. competency;

b. certification; and

c. assessment, including-

(i) initial and continuous evaluation of workers;

(ii) recertification procedures; and

(iii) methods for examining or testing the qualification of an individual who performs a covered task; and

(2) consolidate training guidelines in existence on the date on which the guidelines under subsection (a) are developed relating to the construction, operation, maintenance, and inspection of non-nuclear electric generation, transmission, and distribution facilities, such as guidelines established by the National Electric Safety Code and other industry consensus standards.

One obvious point is that power producers need to adopt some kind of standardized program for personnel training. The Act notes that the National Electric Safety Code and other industry bodies can help companies with their training guidelines. The point here is not to wait for the department of Labor, Energy or anyone else to issue guidelines, but to get to work on it now.

“The last thing you want is to be called to the carpet after a blackout or brownout is traced to operator error,” said Kamph. “When an investigation reveals lack of mandated training and qualification procedures, penalties could be severe.”

Training Time vs. Quality

Another point to consider here is time in training.

Some believe that time in training equates with competence, said Kamph. This is simply not true. “Training programs should be geared to results, not merely towards the completion of a set number of hours in a classroom,” he said.

Clause B1a of the Energy Policy Act introduces the concept of competency without defining it in any way. Competency does not mean that you hold a certain diploma or have passed a particular test. Nor can it be characterized in terms of longevity. Kamph said that employee competency should show up in overall efficiency, return on investment and profitability. Competent people control their plant environments while incompetent people don’t.

“The problem with competence is that it’s a word that comes in for a lot of lip service,” he said. “But if it truly becomes the focus of any training program, it can make a big difference to organizational viability.”

The cause of competency is greatly assisted by breaking it down into the fine details; that is, defining exactly what constitutes a task, a skill and so on. Far from making a broad determination as to whether a person is competent, it is better to break that person’s position down into a series of skills and tasks and then evaluate each one. That eliminates much of the opinion from the issue and usually results in the correct conclusion.

Competency, too, should be tied to the Act’s provisions with regard to certification. Unfortunately, this is a major gripe in the modern business world: the engineer or business degree holder who excelled at college yet can’t function in a work environment. But examples are just as available in other areas of the industry. For instance, some workforce qualification periods result in 100 percent of employees being passed as qualified. If that is the case, then something is badly wrong. You end up with a minority of problematic employees who now have tenure. Realistically, about 80 percent should pass for the system to be considered valid.

“When it comes to recertification and certification in general, the most effective system is to tie certification into competence and reward employees for its demonstration,” said Kamph. “In the companies where we have instituted pay-for-performance systems, it has been a uniform success as employee production has soared.”

First Energy Ahead of the Game

Qualification is another of the key aspects of Section 1103 compliance. Unfortunately, this concept isn’t defined within the Energy Policy Act.

“Qualification means to objectively determine the capability of the worker to perform the identified skill at the required performance level,” said Kamph. “It makes sense to qualify each employee to conduct specific skills and tasks. Such qualification is best done based on a combination of classroom study and on-the-job demonstration.”

Take the case of FirstEnergy Corp. of Akron, Ohio. The company comprises various utilities stretching from New Jersey to Ohio. FirstEnergy brought in Interliance Consulting to assist with workforce development and training. The company is well ahead of the game with regards to Section 1103 of the Energy Policy Act.

The Fossil Group at FirstEnergy has created a manual for standardized workforce development. This includes employee development strategies, employee skill definitions, standardized roles and responsibilities, measures of success and building a common culture of how employees are developed.

“We worked closely with Interliance to develop a post-hire training process using a structured on-the-job training approach,” said Brian Wilkins, staff generation specialist at FirstEnergy. “As we tailored it to each job classification at each plant, it fits like a glove.”

FirstEnergy only accepts staff with a two-year degree in the applied science of their line of production, or equivalent. For example, someone who has served in a propulsion division within the Navy would meet the qualifications for consideration.

New arrivals go through a structured on-the-job training regime based on well-defined modules, within two years or less. The modules were developed by subject matter experts and customized for each plant. Incentives exist for completing the required modules ahead of schedule.

“We had two employees who finished the Operations modules in about 14 months,” said Wilkins. “There is a clear incentive to complete the modules based on pay hikes linked to training progress.”

He said, however, that Section 1103 of the Energy Policy Act does not specify how frequently requalification is to be done. FirstEnergy decided to do it every five years. Employees won’t have to go through all the modules again. Instead, they complete a program which is about one fifth the size of entry training.

“This mainly consists of carrying out specific tasks under the observation of a supervisor who verifies every step is done correctly,” said Wilkins. “We begin qualifying the first 20 percent of our workforce next year, starting with those with least seniority. It doesn’t make sense to subject soon-to-be retirees to requalification.”

A case can be made that quality training translates to quality operation. When FirstEnergy investigates trips for example, if a case of operator error is determined it can receive special focus to be incorporated into the associated module as part of ongoing training.

“The goal is continuous improvement,” said Wilkins, “and we believe training and qualification plays a vital role and that they can strongly influence plant performance.”

Compliance Exercise vs. ROI

One possible response to Section 1103 requirements is to treat them as yet another compliance exercise and do the minimum necessary to satisfy the terms of the Act. Take the case of the Sarbanes Oxley Act. Companies have ended up spending a fortune in compliance. But in many cases, this investment has not resulted in any efficiency or profitability gain. Similarly, implementation of the operator qualification aspects of the Pipeline Act, in some cases, has resulted in a compliance expense which doesn’t translate into heightened employee performance.

The winning approach is to embrace the workforce provisions of the Energy Policy Act as an opportunity to improve performance across the boards. Instead of a generalized “train the workers more,” or “adopt computer-based training” it has to be broken down into many different job classification categories and equipment types, systems and/or skills for each job.

“There is no substitute for training that familiarizes employees with how to perform actions on the ground and results in heightened competence,” said Kamph. “This training should be monitored based on how effective it is against such metrics as error rates and other efficiency statistics. That’s the only way to make the investment in training achieve a measurable ROI.”

Author: Drew Robb is a Los Angeles- based freelance writer who contributes frequently to Power Engineering magazine.