WHITE PAPER · UTILITY & GAS SAFETY
The Exposure Gap
Utilities now score high-energy controls. Most of that scoring happens after the work. The exposure happens at the briefing. This paper explains EEI’s SCL and HECA framework in plain terms, shows where the record stops, names the gas hazard the icons miss, and gives you a crew card and a 20-JSA audit to close the gap.
WHAT IS HECA?
HECA, the High-Energy Control Assessment, is the share of high-energy hazards on a job that have a direct control: one that targets the energy, works when installed properly, and still works if someone makes a mistake. EEI's SCL model calls a hazard without one an Exposure.
Free white paper · Grounded in EEI, OSHA, BLS, INGAA and peer-reviewed research · For safety leaders at U.S. electric and gas utilities and their contractors.
of the hazards present before work were identified by crews in Hallowell’s field research across 12 construction trades.
range of baseline HECA scores across utility and construction companies in the 2026 Bayona study.
fatal injuries per 100,000 power-line installers and repairers in 2024 (BLS), against 3.3 for all U.S. workers.
WHERE THE RECORD STOPS
The Framework Is Sound.
The Gap Is Where It's Applied.
Southern California Edison runs HECA across all of its high-hazard work and reports it to the CPUC. INGAA added HECA to its contractor indicators in 2024. Very little of that scoring happens in the one conversation every crew already has before work starts.
01
THE BRIEFING
A Signed Briefing Isn't a Verified Control
OSHA 1910.269(c) requires the job briefing: hazards, procedures, precautions, energy source controls, and PPE. It doesn’t require proof that each energy source was paired with a control that works. “Electrical hazard, use PPE” is a statement, not a decision.
02
THE RECORD
Most Scoring Happens After the Work
EHS systems of record classify observations and incidents with the SCL model, and do it well. But that happens after the crew has finished the job, or after something went wrong.
03
THE SAMPLE
Observation Doesn't Scale by Walking
EEI’s guidance shows a business unit working 300,000 hours a month needs about 147 HECAs a month for a reliable estimate. That’s about five observations every working day, for one business unit.
THE LANGUAGE UTILITIES ALREADY USE
An Exposure Is a Serious Injury
Waiting for a Trigger.
EEI’s Safety Classification and Learning model asks whether high energy (more than 500 foot-pounds) was present and whether a direct control was in place. Before the model existed, 113 practitioners agreed on serious-injury potential 65% of the time. With it, agreement reached 95%.
| SCL classification | What it means |
|---|---|
| Success | High energy present, a direct control in place |
| Exposure | High energy present, no direct control, nobody hurt yet |
Four hazards observed, three with direct controls, scores 75%. The score doesn’t make the fourth one acceptable.
What Counts as a Direct Control
WHY CREWS MISS WHAT KILLS THEM
People Miss Hazards.
In Predictable Ways.
Hallowell’s field research across 4,800 worker-hours found crews identified about 45% of the hazards present before work. The misses split in two, and each half needs a different fix.
ABOUT 45%
Spotted Before Work
People spot gravity and motion instinctively: a swinging load, a moving truck.
ABOUT 35%
Missed Through Blind Spots
Energy that gives no warning: pressure, tension, chemical, temperature. The fix is better prompting at the briefing.
ABOUT 20%
Appeared as the Job Changed
Not reasonably visible before work began. The fix is rebriefing when conditions change. A form signed once at 6 a.m. handles neither.
These are construction findings, not a utility benchmark. A 2026 study of 31 utility and construction organizations found better pre-job briefs went with more direct controls, and more direct controls went with fewer later serious injuries. The results are correlational.
GAS AND CONTRACTORS
Explosion Is on the List.
The Pressure Behind It Isn't.
01
GAS CREWS
Pressure Isn't One of the 13 Icons
EEI’s 13 high-energy icons cover about 85% of the hazards in its original study. Pressure isn’t one of them; it goes through the energy calculation. A briefing that runs only on the icons can miss a pressurized service line, a regulator station, or a blowdown. Use the 13 as a floor, and add explicit pressure prompts on every gas job.
02
CONTRACTOR CREWS
Contractors Are in the Metric
The CPUC’s SIF reporting covers contractors, not just employees, and INGAA’s HECA guidance is built for contractor safety management. If contractor crews brief on paper while employees brief digitally, your Exposure data describes only part of the work.
THE EXPOSURE CHECK
A Crew Card for the Briefing.
A Question Mark Is Never a Yes.
The 13 EEI hazard prompts, plus pressure and stored energy. For each hazard present, the crew names the control and says whether it would still work if someone made a mistake. The full paper adds a reviewer sheet for the follow-up.
Run the 20-JSA Audit This Month
You can measure your own exposure gap with the paperwork you already have.
WHERE FIELD1ST FITS
Run the Briefing You Already Have. Better.
Crews speak the job instead of typing it. A missing-hazard check flags possible omissions before the brief is submitted, such as a gas task with no pressure prompt answered.
Contractor crews join by QR code without a paid seat, so their briefings land in the same record as your employees’. Briefings work offline and sync when signal returns.
What the AI suggested, what the crew confirmed, and what a qualified person verified. Only the last one is a direct control.
What this paper can’t prove. The 45% finding comes from construction trades. The Bayona study is correlational. And no study yet shows that any software, including ours, reduces serious injuries or fatalities. These are product capabilities, not evidence of detection accuracy or SIF reduction.
HECA QUESTIONS
Frequently Asked Questions.
What is a HECA score?
The percentage of observed high-energy hazards protected by a direct control: Successes divided by Successes plus Exposures. EEI publishes the method and rulebook.
What is a direct control?
A safeguard that targets the specific energy, works when properly installed and used, and stays effective if a worker makes an unintentional mistake. Training, signs, and most standard PPE don't qualify.
What is an Exposure in the SCL model?
A high-energy hazard present with no direct control, where nobody has been hurt yet.
What are EEI's 13 high-energy hazards?
Suspended load, fall from elevation, mobile equipment or traffic, motor vehicle, heavy rotating equipment, high temperature, steam, fire, explosion, excavation, electrical contact, arc flash, and toxic chemical or radiation. Pressure is handled separately.
Do better job briefings reduce serious injuries?
A 2026 study of 31 utility and construction organizations found better briefs went with more direct controls, and more direct controls went with fewer later serious injuries. The results are correlational.
Get the Full White Paper.
Find Your Exposure Gap.
The framework, the gas gap, the crew card, the reviewer sheet, and the 20-JSA audit.
Download the paper, or bring one current briefing form and 20 completed JSAs. We’ll run the audit with you and show where your records stop and the exposure starts. Twenty minutes. No slides, no prep, no pressure.
