How Qualified is Qualified'
12/6/2006
By John Klingler, P.E.
In the real world of operations, maintenance, service, and construction, employees must be qualified if they are going to be exposed to electrical hazards capable of injuring, disabling or even killing. Different industries have different regulations or standards that address this need for qualified persons. Although most of these electrical regulations and standards have some minor differences in the wording they use, the intent is the same; employees, contractors, and service personnel must be qualified to work on or near electrical hazards.
Regulations and Standards
The primary regulation that governs most companies is the Code of Federal Regulations (CFR). There are at least three parts of the CFR that address qualified persons for electrical work: Title 29 Part 1910 for General Industry and Electric Utilities, Title 29 Part 1926 for the Construction Industry, and Title 30 Part 75 and 77 for Coal Mines.
In addition to the CFR, most companies are also affected by one or more additional electrical safety standards that address qualified persons: the National Fire Protection Association NFPA 70 ' National Electrical Code (NEC) and NFPA 70E ' Standard for Electrical Safety in the Workplace, and the Institute of Electrical and Electronic Engineers (IEEE) National Electrical Safety Code (NESC) ' Safety Standard for Overhead and Underground Electric Utility and Communications Utility Installations.
Enforcement of these regulations and standards is provided by the Occupational Safety and Health Administration (OSHA), the Mine Safety and Health Administration (MSHA), and other Authorities Having Jurisdiction (AHJ), including state, county, and local government jurisdictions, as well as insurance companies.
Who needs to be Qualified
The common thread of most electrical regulations and standards is that all electrical circuits and equipment energized at 50 volts or more must be guarded, covered, protected, or otherwise made inaccessible, except to qualified persons. This means only qualified persons are allowed to have access to energized circuits and equipment. Anyone opening industrial panels containing exposed energized components must be qualified. Only qualified persons shall have access to rooms containing exposed energized components unless the components are guarded, covered, or protected by barriers or equally effective means. NFPA 70E specifies a minimum approach boundary for an unqualified person of 42 inches to exposed circuits and equipment energized between 50 and 750 volts, unless continuously escorted by a qualified person.
Based on the access restriction of the previous paragraph, it goes without saying that only qualified persons may perform electrical work on energized equipment. But the regulations go even further in stating that only qualified persons may perform electrical testing. This means that even the fundamental task of voltage verification and checking to see if a circuit is deenergized can only be performed by a qualified person.
Lockout/tagout also requires involvement of qualified persons. The person in control of the lockout/tagout procedure is required to be qualified. A qualified person is required to verify the equipment has been properly deenergized before work begins and verify that it is safe to reenergize the equipment after the lockout/tagout procedure has been completed. Additionally, a qualified person is required to conduct an audit of lockout/tagout procedures at least annually.
Finally, there are a number of electrical installation standards that are relaxed if a facility utilizes only qualified persons to maintain and repair their electrical systems. These frequently used allowances and exceptions are common in the CFR and the NEC.
Plainly stated, electrical regulations and standards require anyone (including employees, contractors, and service personnel) opening a door or entering a control panel, cabinet, motor control center, panelboard, switchboard, room or vault, that exposes parts energized at 50 volts or more to contact, to be qualified.
Description of a Qualified Person
Regulations and standards state to be qualified a person must be familiar, through training or experience, with the construction and operation of the equipment and the hazards involved. Some regulations and standards state the qualified person must be capable of working safely on energized circuits and be familiar with the proper use of special precautionary techniques, personal protective equipment/clothing, insulating/shielding materials, and insulated tools. Most regulations and standards now require a qualified person to be safety trained to recognize and avoid electrical hazards.
A couple of important notes are included with the descriptions of a qualified person:
1. Training can be of the classroom type, on-the-job, or a combination of both.
2. An employee undergoing on-the-job training and who, in the course of such training, has demonstrated an ability to perform duties safely at his level of training and who is under the direct supervision of a qualified person is considered to be a qualified person for the performance of those duties.
3. A person can be considered qualified with respect to certain equipment and methods but still be unqualified for others.
MSHA requires a qualified person successfully pass an MSHA approved electrical exam and receive electrical safety retraining annually thereafter.
Many states, counties and cities require persons performing electrical work, primarily contractors and contract electricians, to be licensed. This generally means the person must have documented electrical experience and have passed an electrical exam to prove they are qualified.
Plainly stated, to be qualified, one of the following is required:
1. Be licensed or certified by a recognized entity such as the IBEW (International Brotherhood of Electrical Workers), MSHA or government jurisdiction such as a state or county. Additionally, the person should be trained in CPR if medical help is not readily available in the workplace.
2. Have documented proof of all the following:
- Be safety trained to understand, recognize and avoid electrical hazards
- Trained to determine the nominal voltage and safe working distance around electrical equipment
- Trained in the selection, use, and care of personal protective equipment, clothing, insulating tools, test equipment, barriers, etc. necessary to perform the task(s)
- Knowledgeable of the equipment operation and electrical installation
- Trained to perform task(s) safely
- Trained in CPR if medical help is not readily available in the workplace
Qualified Person Versus Qualified Electrician
To my knowledge there is only one regulation that specifically requires a qualified electrician; 29CRF1910.255 requires resistance welders be installed by a qualified electrician. With that exception, I am not familiar with any regulations referencing qualified electricians, only qualified persons. There are differences between qualified electrician and qualified person. The difference is the extent of the person's electrical knowledge, training, and experience.
qualified electricians should have a good general understanding of electricity, a broad-base of technical electrical training, electrical safety training, and actual experience performing electrical tasks. The qualified electrician should be capable of performing a wide variety of electrical tasks related to their work environment, have the required PPE for electrical hazards encountered in the workplace, and know when and how to use and care for the PPE. They should be trained on the capabilities of their test equipment and safety trained on how to use and care for the equipment.
A qualified person is a person trained to safely perform a limited number - possibly only one specific task, involving exposure to electrical hazards. This person must be safety trained to understand, recognize and avoid the electrical hazards associated with the specific task they are to perform, understand their limitations in performing the task, equipped with the proper PPE and test equipment for the task, and know when and how to use and care for the PPE and equipment.
This is not to suggest that everyone can be or should be qualified. However, it does suggest there is nothing wrong with employees other than electricians performing specific tasks involving limited exposure to energized parts, provided they meet the criteria of a qualified person for that task.
OSHA recognizes that persons in job classifications other than electrician may occasionally be exposed to electrical hazards; this is evident in 29CFR1910.332 where OSHA requires safety training on electrical regulations 29CFR1910.331-.335 for those persons (not limited to electricians) who face a risk of electric shock. The persons they identify as most likely to need this training include but are not limited to:
Blue Collar Supervisors
Electrical and Electronic Engineers
Electrical and Electronic Equipment Assemblers
Industrial Machine Operators
Material Handling Equipment Operators
Electrical and Electronic Technicians
Electricians
Mechanics and Repairers
Painters
Riggers and Roustabouts
Stationary Engineers
Welders
In addition OSHA requires electricians and other qualified persons to receive additional safety training as was described previously.
Plainly stated, qualified persons must have appropriate training, knowledge, and skills for the task(s) which they are to perform.
Qualifying and Maintaining Qualification
Determining the qualification of an employee is the responsibility of management, not the government. Management must determine the scope of work expected of each employee and assess the workplace for hazards the employee may encounter. Once these assessments are complete, management can established a minimum skill and knowledge level necessary to complete the scope of work safely and effectively. The employee's personnel file should reflect the employee's experience and technical training as well as the safety training to perform the task safely and effectively.
Plainly stated, documentation, documentation, and documentation is critical in supporting your decision to qualify an employee. The employee's personnel file should include documentation of formal electrical training, years of experience in performing similar tasks, training on electrical equipment and circuits, electrical safety training, training on the applicable regulations and standards, and training on PPE.
Retraining and documentation of retraining are equally important. Some conditions that indicate the need for retraining include changes in the workplace, in the equipment, in the PPE, in the regulations and standards, or deficiencies in actual task performance.
A Suggested Approach to Satisfy Qualification Requirements
Proof of attendance at a one-day training session on NFPA 70E is not adequate to qualify your employees to perform electrical work. Although NFPA 70E training is definitely recommended, if not required for your qualified employees, it should only be a single component of a much broader-based training program.
Management should start by preparing a list of the task(s) on or near exposed energized parts that the qualified person or electrician is expected to perform; often referred to as a job/task analysis (JTA).
Next, complete a job hazard analysis (JHA) and prepare a description of the skill and knowledge required to perform the job safely; this must include the training requirements discussed previously.
Now compare these requirements to the knowledge, skills, and training of the person expected to be qualified to perform the task(s). This comparison should identify the areas of weakness and be a guide to developing a training schedule to address these weaknesses.
Training budgets are limited, so concentrate on the weakest areas first and keep training until you have addressed the needs of the employee to perform the task(s) safely. Try to develop a three-year plan, which will coincide with updates to the regulations and standards. Schedule a minimum of two to five days of training annually for each qualified employee.
The following is a suggestion of training for qualified persons:
About the Author
John Klingler, P.E. (email) is the Manager of Klingler Electrical Safety, LLC. He provides electrical safety training, including NFPA 70E and National Electrical Code, and provides arc-flash hazard analyses and electrical safety audits.
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