Reducing workplace risk by employing qualified personnel

Author: Dennis Neitzel - Director Emeritus - AVO training institute INC , US

Introduction
This article defines who a qualified person is, and identifies their training requirements. The Occupational Safety and Health Administration (OSHA) and the National Fire Protection Association (NFPA) require companies to protect their employees from electrical hazards in the workplace. To accomplish this, there must be a strong emphasis on “qualified persons only” performing work on or near exposed energized and de-energized electrical systems and equipment. Proper training and qualification of personnel is extremely important because maintenance of electrical protective devices, particularly circuit breakers and relays, is vital to the reliability of electrical systems and equipment and also to the safety of employees working on, near, or interacting with these systems and equipment.

Qualified person requirements
OSHA 29 CFR 1910.399 defines a “qualified person” as “One who has received training in and has demonstrated skills and knowledge in the construction and operation of electric equipment and installations and the hazards involved.” OSHA provides additional information on what constitutes a qualified person in the following notes:
Note 1 to the definition of ‘‘qualified person”: Whether an employee is considered to be a ‘‘qualified person’’ depends upon various circumstances in the workplace. For example, it is possible and, in fact, likely for an individual to be considered ‘‘qualified’’ with regard to certain equipment in the workplace, but ‘‘unqualified’’ as to other equipment. (See 1910.332(b)(3) for training requirements that specifically apply to qualified persons.)
Note 2 to the definition of ‘‘qualified person”: An employee who is undergoing on-the-job training and who, in the course of such training, has demonstrated an ability to perform duties safely at his or her 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.

OSHA and NFPA 70E, Standard for Electrical Safety in the Workplace have provided strict requirements for safety training that go handin-hand with the qualification of an employee.  The following information is provided in order to clarify the mandates for training employees in the electrical field.
The OSHA 1910.332 Training requires a qualified person to be trained in “the safety-related work practices that are required by 1910.331 through 1910.335 that pertain to their respective job assignments.” Qualified Persons (i.e. those permitted to work on or near exposed energized parts) shall, at a minimum, be trained in and familiar with the following:

• The skills and techniques necessary to distinguish exposed live parts from other parts of electric equipment
• The skills and techniques necessary to determine the nominal voltage of exposed live parts
• The clearance distances specified in 1910.333(c) and the corresponding voltages to which the qualified person will be exposed

Note 1: For the purposes of 1910.331 through 1910.335, a person must have the training required by paragraph (b)(3) of this section in order to be considered a qualified person.
Note 2: Qualified persons whose work on energized equipment involves either direct contact or contact by means of tools or materials must also have the training needed to meet 1910.333(C)(2).

The training requirements contained in this section [1910.332] apply to employees who face a risk of electric shock. Employees in occupations listed in Table S-4 face such a risk and are required to be trained. Other employees who also may reasonably be expected to face comparable risk of injury due to electric shock or other electrical hazards must also be trained.

Table S-4
Typical occupational categories of employees facing a higher than normal risk of electrical accident.

(1) Workers in these groups do not need to be trained if their work or the work of those they supervise does not bring them or the employees they supervise close enough to exposed parts of electric circuits operating at 50 volts or more to ground for a hazard to exist.

Employees are also required to be trained in the safety-related work practices, safety procedures, and other safety requirements as they pertain to their respective job assignments. This training includes any other safety practices, including applicable emergency procedures that are related to their work and are necessary for their safety. 

NFPA 70E also requires qualified employees to be trained and competent in:

• Skills and techniques necessary to distinguish live parts from other parts
• Skills and techniques necessary to determine the nominal voltage
• Minimum approach distances to live parts
• The proper use of:
  • Special precautionary techniques
  • Insulating and shielding materials
  • Insulated tools and test equipment
  • Job planning

A person must have this training in order to be considered a qualified person. The employer, through regular supervision and annual inspections, must verify that employees are complying with the safety-related work practices. Additional training or retraining may be required if:

• The supervision or annual inspection indicate non-compliance with work practices
• New technology is introduced
• New types of equipment are introduced
• There are changes in procedures
• Employees are required to use work practices that they normally do not use

OSHA and NFPA consider tasks that are performed less often than once per year to necessitate retraining before the performance of the work practices involved. This retraining may be as simple as a detailed job briefing prior to the commencement of the work or it may require more in-depth classroom instruction, along with on-the-job training. All training is required to establish employee proficiency in the work practices and procedures. Employees are required to demonstrate proficiency in the work practices involved before the employer can certify that the employee has been trained.

OSHA 1910.332 states: “The training required by this section shall be of the classroom or on-the job type. The degree of training provided shall be determined by the risk to the employee.” NFPA 70E goes on to state: “the training shall be classroom, on-the-job, or a combination of both, and that retraining shall be performed at intervals not to exceed 3 years.” Training and retraining are required to be documented.
In addition to the requirements stated above from OSHA, the NFPA 70E states that employees are required to be “trained to understand the specific hazards associated with electrical energy,” “safety-related work practices,” and “procedural requirements.” These training requirements are necessary to help protect employees from the “electrical hazards associated with their respective job or task assignments” as well as to “identify and understand the relationship between electrical hazards and possible injury.” Training in emergency procedures is also required when employees are working “on or near exposed energized electrical conductors or circuit parts.”

OSHA and NFPA are consistent in their requirements for training and qualifying employees to perform work on electrical equipment and systems. As can be seen by the above statements, proper training is a vital part of the worker’s safety and proficiency, as well as reducing risk to the employee.

Conclusion
As evidenced by the above quotes from NFPA and OSHA, an employee, in order to be considered a qualified person, must receive extensive training. The goal of any training program is to develop and maintain an effective and safe work force.

Electrical power systems today are often very complex. The complexity of modern protective devices, controls, instrumentation, and interlock systems demands that technicians be trained and qualified at a high technical skill level. Safety and operating procedures utilized when working on these systems are equally complex, requiring technicians to be expertly trained in all maintenance and safety practices and procedures. OSHA regulations, as well as NFPA 70E require employers to document that employees have demonstrated proficiency in electrical tasks and that they are qualified. Utilizing only qualified persons to perform electrical work can greatly reduce risks to the safety of the employee, as well as increasing reliability of the electrical system and equipment.