By Safety Management Group
State and federal regulations regarding workplace safety can often be confusing or ambiguous. But whether a company fully understands the rules, it is expected to fully comply with them.
One area that raises many questions involves the need for what many regulations refer to as “qualified electrical workers.” What does it take for a worker who handles electricity to be qualified? What types of tasks demand that level of qualification? And is there a difference between a qualified electrical worker and an electrician? In this article, we’ll review the basics of the regulations and provide straightforward answers to those questions.
What are the regulations?
There are a variety of rules that require qualified electrical workers under specific circumstances. While the wording of the rules may differ slightly, they all focus on ensuring that workers have sufficient skills and training to work safely in situations that involve electrical hazards.
For most companies, the rules can be found in the Code of Federal Regulations (CFR). Part 1910 of Title 29 of the CFR addresses electric utilities and other industrial operations, while Part 1926 focuses on the construction industry. Most companies also operate under the National Fire Protection Association’s (NFPA) National Electrical Code (NEC) and its workplace safety standards (NFPA 70E). Electric utilities are covered by the Institute of Electrical and Electronic Engineers’ (IEEE) National Electrical Safety Code (NESC).
While those organizations created the standards, the actual enforcement is left up to state and federal regulatory agencies, including OSHA.
When must workers be qualified?
Generally, the regulations agree that any electrical circuit or equipment that is energized with at last 50 volts of electricity has to be guarded, covered, protected, or made inaccessible to everyone except qualified electrical workers. That includes panels that contain energized components that are exposed. NFPA 70E adds a requirement than anyone who is not qualified must stay at least 42 inches from exposed circuits or equipment that’s energized to between 50 and 750 volts (unless a qualified person is present).
The regulations also state that any electrical testing must be performed by qualified workers. That means an unqualified worker cannot even verify whether a circuit has been de-energized. In addition, if a company has a lockout/tagout procedure, it must be supervised by a qualified person. That qualified person must verify that the equipment has been properly de-energized before any work can be performed, and that it’s safe to re-energize the equipment once the work has been completed.
So who is a qualified person?
According to the rules, a worker is considered to be a qualified person when he or she has the training or experience to be familiar with the construction and operation of the equipment, along with any hazards that may be involved. Some of the regulations and standards also specify that a qualified person must have the knowledge to work safely on energized circuits, and to be completely familiar with precautionary techniques and safety equipment. Keep in mind that a person who is considered to be qualified for working on and around some equipment may lack the expertise to work on others, making him or her unqualified in those situations. This also holds true for certain work tasks. Just because a person is qualified to perform specific electrical tasks doesn't mean they are automatically qualified to perform all tasks.
In some jurisdictions, being qualified also includes earning the local license that certifies knowledge of electricity and electrical work, or being a member of a recognized union such as the International Brotherhood of Electrical Workers.
Does the worker have to be a qualified electrician?
In most cases, work that must be performed by a qualified electrical worker does not need to be performed by a qualified electrician. One exception is a rule in the CFR that calls for resistance welding equipment to be installed only by qualified electricians.
By definition, a qualified electrical worker has the knowledge and training to perform one or more specific tasks. That worker must also have sufficient safety training to recognize and know how to address the specific electrical hazards that are associated with those tasks, including the correct personal protective equipment (PPE).
In contrast, a qualified electrician has broader and deeper electrical knowledge, including a general understanding of the nature of electricity and all of the hazards associated with it. Qualified electricians also have more extensive safety training and more experience performing a variety of electrical tasks.
In other words, a company does not have to turn to a qualified electrician for every electrical task, as long as the worker assigned to perform the task meets the criteria of qualified electrical worker for the task.
How do workers qualify?
While the regulations dictate that work must be performed by qualified electrical workers, they’re less specific about what companies must do to determine whether those workers are actually qualified. It falls to company managers to review the scope of work that is required and the associated hazards, determine the minimum level of skill and knowledge that workers need to perform the task safely, and identify the training needed to provide that level of knowledge and skills.
Documenting those requirements and the process by which employees meet them is critical. Each employee’s personnel file should include clear evidence of the employee’s qualifications, how those qualifications were obtained and verified, past experience with tasks of this type, training related to regulations, and training for proper PPE.
In addition, it’s also a good idea to document any refresher or re-training the employee receives, especially if that training is intended to correct a deficiency in the employee’s knowledge or performance.
One approach to qualification
Don’t fall prey to the common misconception that attending single-day training on NFPA 70E is adequate for qualifying an employee to perform electrical work. While that training can be vital, it should be just one component of a broader overall training program.
To develop your training program, start by listing the tasks that employees will need to perform on or near energized equipment. Then identify the hazards associated with those tasks and the specific skills and knowledge employees will need to perform the work safely. Include any training associated with acquiring and verifying those skills. Finally, compare those requirements to the actual skills and knowledge of each employee, so you can identify the training needed to fill any gaps.
As a general rule, each qualified electrical worker will need at least two to five days of training each year to maintain the level of skill. It’s a good idea to plan for that training over a three-year period to ensure that your qualification process continues to track changing requirements. It can also be beneficial to have your program regularly reviewed and audited by a professional safety consultant. That way, you can protect your workers from hazards while protecting yourself from negative actions from regulatory agencies.
One final thought. Compliance inspectors receive guidance and training in evaluating whether or not employees are qualified to perform certain tasks. While the documentation serves as a guideline, there will inevitably be variations in how compliance personnel interpret the guidelines.