Electricity is a powerful force that can cause serious injury and death. When it comes to electrical job tasks, it only takes an instant to turn a momentary mistake into a life-altering event or even fatality. Therefore, qualified electrical workers must understand the hazards presented by exposed energized parts and know how to protect themselves using safe electrical work practices.
NFPA 70E® and OSHA 29 CFR 1910.332 define and state the requirements for determining whether an individual is a “qualified person” who has the training necessary to work on exposed energized electrical circuits or parts.
So how do you know whether your workers are qualified? Which workers are unqualified? Who requires training?
This article reviews electrical safety training practices, worker assessments, and requirements for training.
Employers must evaluate the workplace for known hazards or hazards that are inherent in the work performed. For this discussion, we will focus on electrical hazards. This has long been an OSHA requirement. Most companies are familiar with possible shock hazards and are also aware that OSHA requires their qualified workers to be properly trained to work on or near exposed energized electrical circuits or parts. Many companies, however, are unaware that it is also an OSHA requirement to train unqualified electrical personnel on how to recognize and avoid electrical hazards. Unqualified electrical workers — which may include maintenance personnel, painters, cleanup crews, laborers, mechanics, etc. — who are not expected to work on exposed energized circuits or parts must still receive sufficient training to ensure their safety and the safety of others in the workplace.
The same requirements also apply to the use of outside contractors to work on energized electrical systems. Although contractors may state that their personnel are qualified to work on electrical systems, they may not be qualified from OSHA’s standpoint. Simply being an electrician is not enough. The person must receive the proper training in electrical theory, electrical safety, and training in the construction and operation of electrical equipment and installations along with the hazards involved.
When companies ignore these requirements, they do so at their own peril. Failure to comply with OSHA requirements puts workers at risk and can result in fines and exposure to multimillion-dollar lawsuits. Worse yet, they risk the health and safety of their employees by putting them in situations that are beyond their skill level or by exposing them to hazards they are not prepared to handle.
WHOS IS QUALIFIED? WHO IS UNQUALIFIED?
OSHA defines a qualified person as:
…one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his/her ability to solve or resolve problems relating to the subject matter, the work, or the project.
As we can see, a qualified worker is simply someone who is trained and knowledgeable about the tasks he/she will be performing. A qualified worker must be able to identify and protect oneself from all the hazards associated with the task and be able to demonstrate proficiency.
When the hazard relates to electricity, NFPA 70E, Standard for Electrical Safety in the Workplace, expands this definition to:
…one who has demonstrated skills and knowledge related to the construction and operation of electrical equipment and installations and has received safety training to identify the hazards and reduce the associated risk.
The key points of this definition are how knowledgeable workers are about the equipment and whether they have received safety training. In addition to helping to prevent accidents, both items are critical to designate a person as qualified and to avoid difficulties if OSHA performs an inspection.
Qualified persons have training in avoiding the electrical hazards of working on or near exposed energized parts, whereas unqualified persons have little or no training. Training requirements for qualified persons and unqualified persons are contained in OSHA Section 1910.332 Training.
NFPA 70E defines an unqualified person as simply “a person who is not a qualified person.”
There are two kinds of unqualified persons:
- An electrician who does not know the equipment or has not received safety training on the potential hazards involved
- A non-electrician, such as a general maintenance worker or mechanic, who is not expected to work on live electrical equipment
These definitions may be straightforward, but they provide only minimal guidance. Companies can get into trouble if they interpret the definitions to mean that they only need to train electricians who work on live circuits. Reviewing NFPA 70E Article 110 General Requirements for Electrical Safety-Related Work Practices helps clarify who needs to be trained and to what level. This section covers the general requirements for electrical safety in a plant, and it applies to all workers, qualified as well as unqualified.
Article 110 outlines electrical safety-related work practices and procedures for people working on or near exposed, energized electrical equipment. The article states that it is the employer’s responsibility to issue safety-related work practices and train employees to implement them.
Work practices set the policy and direct employee activity in broad terms. They can be incorporated into an employer’s overall occupational health and safety management system. Work practices should address planning all tasks and protecting employees from hazards. They should also incorporate the electrical safety program, which explains how to put practices to use. For example, work procedures might detail how an employee can maintain electrical equipment or use a specific test instrument.
Principles of work practices should include the following:
- Establishing an electrically safe work condition
- Identifying the hazards and minimizing the risks
- Protecting employees
- Planning all the tasks
- Anticipating unexpected events
- Ensuring employee qualifications and abilities
- Inspecting and maintaining electrical equipment
- Using the correct tools
Paragraph 110.6 outlines training requirements for qualified persons (110.6(A)(1)) and unqualified persons (110.6(A)(2)). Let’s first look at the requirements for qualified persons.
Training for Qualified Persons
By default, a qualified person (defined earlier) must be competent. The general definition of “competent” is having sufficient skills, knowledge, or experience for a specific purpose. A worker could be competent to install a light fixture but not qualified under NFPA 70E to troubleshoot that fixture while it is energized.
NFPA 70E Article 350 is the only place where the term competent is used. That definition, which uses qualified person as its basis, includes responsibilities for all work activities or safety procedures related to custom or special equipment and is only applicable to Article 350.
To be considered qualified for a particular task or work assignment, an employee must have internalized the requisite knowledge regarding the electrical system involved as well as the required procedures. The employee must also have received the safety training identified in paragraph 110.6. Exhibit 110.4 in NFPA 70E, Handbook for Electrical Safety in the Workplace, which aids the employer and employees in understanding some of the traits necessary to be considered a minimally qualified person under NFPA 70E, depending on the requirements of the specific tasks, for example responding to medical emergencies.
A person might be qualified to perform a specific task on specific equipment while being unqualified to perform another task on the same piece of equipment. Qualification also does not necessarily carry over to a similar piece of equipment nor to an identical task on a different piece of equipment. Work practices, procedures, and hazards can vary by the task and the equipment. Qualification is not necessarily based on title, licensure, and so forth. For example, a licensed electrician might not be qualified to work on medium-voltage switchgear. To be qualified, the person must have knowledge and demonstrated skills concerning specific hazards, work practices, and procedural requirements.
Now let’s look at NFPA 70E training requirements for unqualified persons.
Training for Unqualified Persons
Employees not considered qualified persons must have the knowledge and skills necessary for their safety when interacting with electrical equipment, including during normal operation of the equipment. Following are some of the situations unqualified persons might encounter and must be aware of:
- General potential hazards. Understand and recognize potential hazards, including the relationship between exposure to potential electrical hazards and possible bodily injury.
- Attachment plugs. Understand how to properly remove an attachment plug from a receptacle.
- Receptacle plug/caps. Do not remove attachment plugs (caps) from receptacles when the combination is not load-break rated.
- Damaged equipment. Do not use damaged electrical equipment (fixed or portable), receptacles, or damaged cables, cords, or connectors.
- Impending failure of equipment. Be aware of the signs of impending failure of electrical equipment, and do not remain around electrical equipment when there is evidence of impending failure.
- Tripped circuit breakers. Do not reset a circuit breaker after an automatic trip. Always notify a qualified person to determine the cause.
- Flammable materials. Do not use flammable materials near electrical equipment that can create a spark.
- Overhead power lines. Be aware of the proper approach distance from overhead power lines.
- Alerting techniques. Be aware of alerting techniques such as safety signs and tags, barricades, and warning attendants. Remain outside the shock protection or arc flash protection boundaries when energized work is being performed.
- Limited approach shock boundary. Do not cross the limited approach shock boundary unless advised and continuously escorted by a qualified person.
- Restricted approach boundary. Never cross the restricted approach boundary.
All employees should be provided some basic, common-sense rules for avoiding electrical accidents and injuries. These rules might include the following:
- Do not overload circuits, such as by running multiple appliances from a single outlet.
- Never plug in equipment with a damaged electrical cord or use an extension cord that has damaged insulation.
- Never use electrical equipment, such as a power tool or appliance, if it is sparking, smoking, or otherwise seems to be malfunctioning.
- Keep metal objects, large and small, away from electrical equipment.
OSHA Training Requirements
What does OSHA say about training? OSHA Standard 29 CFR 1910.332 clarifies the training requirements for all workers, stating that they apply to workers who face a risk of electric shock that is not reduced to a safe level. OSHA requires the following workers to be trained in electrical safety because they face a higher-than-normal risk of electrical accident:
- Blue-collar supervisors
- Electrical and electronic engineers
- Electrical and electronic equipment assemblers
- Electrical and electronic technicians
- Industrial machine operators
- Material handling equipment operators
- Mechanics and repairers
- Riggers and roustabouts
- Stationary engineers
Standard 29 CFR 1910 also calls for the following minimal training for qualified workers:
- Skills and techniques necessary to distinguish exposed live parts from other parts of electric equipment
- Skills and techniques necessary to determine the nominal voltage of exposed live parts
- Clearance distances and corresponding voltages to which they will be exposed
Training can be in the classroom or on the job, with the degree of training being determined by the risk to the employee.
The OSHA standard requires that unqualified persons be trained in and familiar with electrically related safety practices that are necessary for their safety. Finally, OSHA adds the following blanket statement:
Any other employees who may reasonably be expected to face comparable risk of injury due to electric shock or other electrical hazards must also be trained.
This makes it clear that virtually all employees who work anywhere near electrical equipment must be trained.
GETTING STARTED WITH TRAINING
In the past, OSHA has assessed employers more than $34 million in fines; 34% were due to electrical hazards. With the stakes so high, it is essential that companies assess their electrical infrastructure and work practices. Quality training and a quality training program are vital parts of an assessment, and unless the instructor has the special expertise required, the company risks falling short of OSHA requirements.
Because of the complexities involved, many companies reach out to a consultant or training firm that can advise or provide employee safety training and continuing audits. At a minimum, training consultation or training firms should meet the following requirements:
- Use instructors trained in OSHA and NFPA, ensuring that course content is up to date, practical, and focused on the things OSHA cares about most.
- Uses instructors who can draw upon real-world experiences to show trainees how to identify and assess electrical hazards.
- Offer a broad selection of courses (on-site and online) that go beyond theory to what experience proves are best practices.
- Offer courses on-site or at a nearby location or instructor-led virtual classrooms to minimize employee travel and time away from work.
- Provide employees with certification of training completion.
Training topics should include:
- Fundamentals of electricity
- Standards that govern electrical work and their requirements, including NFPA 70E® and others
- Electrical safety work practices, including lockout/tagout procedures per 29 CFR 1910
- The difference between qualified and unqualified workers and work limitations for unqualified workers
- Comprehensive examples of acceptable and unacceptable work practices, including those in wet or damp locations
- Use of key interlocking systems
- Identifying type and level of hazards, including electrical shock and arc flash hazards
- Identifying energized components and conductors
- Determining nominal circuit and equipment voltages
- Use of voltage sensors and meters
- Interpreting hazard warning labels
- Safe approach distances to exposed electrical conductors
- Rules for justified energized electrical work and use of energized electrical work permits and job briefings
- The consequences of poor electrical safety practices to people, equipment, and the environment
- PPE requirements, including selection, proper use, and maintenance
- Required and recommended maintenance and safety inspections
- Grounds and grounding
- Pertinence of OSHA or other local rules and penalties for noncompliance
All training should include appropriate job aids and should be integrated with the employer’s standard operating procedures and enforcement policies.
Qualified electrical workers must understand the hazards presented by exposed energized parts and know how to protect themselves using safe electrical work practices. However, the responsibility for providing the appropriate training to ensure the safety of qualified as well as unqualified workers falls on the employer.
Cybart, Kenneth. “How Do You Know Your Workers Are Qualified?” OH&S. Accessed at www.ohsonline.com/Articles/2007/10/How-Do-You-Know-Your-Workers-Are-Qualified.aspx
Thomas Sandri is Director of Technical Services at Protec Equipment Resources, where his responsibilities include the design and development of learning courses. He has been active in the field of electrical power and telecommunications for over 35 years. During his career, Tom has developed numerous training aids and training courses, has been published in various industry guides, and has conducted seminars domestically and internationally. Thomas supports a wide range of electrical and telecommunication maintenance application disciplines. He has been directly involved with and supported test and measurement applications for over 25 years and is considered an authority in application disciplines including insulation system analysis, medium- and high-voltage cable, and partial discharge analysis, as well as battery and DC systems testing and maintenance. Tom received a BSEE from Thomas Edison University in Trenton, New Jersey.