How Do You Know Your Workers Are Qualified?
Take the time now to make sure both qualified and unqualified workers have the training they need to work on or near electrical equipment.
OSHA has long required employers to evaluate the workplace for electrical hazards. Most companies are familiar with possible shock hazards and know that OSHA requires all qualified workers be properly trained to work on or near electrical equipment. However, many safety managers are unaware that OSHA also requires so-called unqualified personnel to be trained to recognize and avoid electrical hazards. These workers--including maintenance personnel, painters, cleanup crews, etc.--are not expected to work on electrical equipment, but they must receive sufficient training to ensure their safety and the safety of others in the facility.
The same requirements also apply to the use of outside contractors to work on 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, ideally from a professional instructor.
Companies ignore these requirements 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 exposing them to hazards they are not prepared to handle.
Who's Qualified; Who Isn't
NFPA 70E defines a qualified person as one who has skills and knowledge related to the construction and operation of the electrical equipment and installation and has received safety training on the hazards involved. 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 problems if OSHA performs an inspection.
NFPA 70E defines an unqualified person as simply "a person who is not a qualified person." There are two kinds of unqualified persons:
• An unqualified 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 painter, who is not expected to work on live electrical equipment.
While these definitions may be clear, they provide only a bare minimum of guidance. Companies can get into trouble if they interpret the definitions to mean that they need to train only electricians who work on live circuits. A reading of NFPA 70E Article 110 sheds more light on 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--both qualified and 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.
Paragraph 100.6 specifies that employees who face the risk of electrical hazard must be trained. It makes no distinction between qualified and unqualified workers but requires that these employees be trained to understand the specific hazards associated with electrical energy. This means they must be trained in safety-related work practices and requirements necessary to protect themselves from the electrical hazards associated with their jobs or tasks.
Workers must be trained to identify and understand the relationship between electrical hazards and possible injury. Further, people working on or near exposed, energized electrical conductors or circuit parts must be trained in methods to release victims from contact with exposed electrical circuits and in methods of first aid.
Paragraph 110.6 (D) then makes it clear that these requirements apply to both qualified and unqualified workers by outlining the training required for each. Obviously, the training for qualified workers is more comprehensive than that for unqualified workers. But the message is clear: Companies cannot neglect electrical safety training for unqualified workers simply because they are not expected to work on live, exposed circuits.
OSHA Requirements
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
• Electricians
This article originally appeared in the November 2007 issue of Occupational Health & Safety.