Workplace safety rules use a variety of terms that can easily be misunderstood, so it’s important to understand what regulators mean by a specific term. A great example is the phrase “qualified electrical workers.” How does one determine whether a worker who handles electricity is qualified? Which workplace tasks demand that level of qualification? And are qualified electrical workers and electricians the same thing? Let’s review the basics of the regulations and provide straightforward answers to those questions.
Where can you find the regulations?
For most companies, the rules that require qualified electrical workers 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). The actual enforcement of all those rules is left up to state and federal regulatory agencies, including OSHA.
Which workers must be qualified?
In simple terms, the regulations require that any electrical circuit or equipment 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 containing exposed energized components. NFPA 70E adds a requirement that non-qualified workers must remain at least 42 inches from exposed circuits or equipment that’s energized to between 50 and 750 volts (unless they’re in the presence of a qualified person).
All electrical testing must be performed by qualified workers, so an unqualified worker can’t legally verify whether a circuit has been de-energized. If a company uses a lockout/tagout procedure, it must be supervised by a qualified person. A qualified person must verify that the equipment has been properly de-energized before any work can be performed, as well as that it’s safe to re-energize the equipment once the work has been completed.
Who exactly is a qualified person?
A worker is considered to be a qualified person when they have the training or experience to be familiar with the construction and operation of the equipment, along with any inherent hazards. Some rules add 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. A person who is qualified for working on and around some equipment may lack the expertise to work on others, making him or her unqualified in those situations. Don’t assume that a person qualified to perform specific electrical tasks is automatically qualified to perform others.
Some jurisdictions required qualified persons to earn the local license that certifies knowledge of electricity and electrical work or belong to a recognized union such as the International Brotherhood of Electrical Workers.
Must qualified workers also be qualified electricians?
Generally, work that must be performed by a qualified electrical worker does not need to be performed by a qualified electrician. An exception is a rule in the CFR that resistance welding equipment may only be installed by qualified electricians.
Qualified electrical workers have the knowledge and training to perform one or more specific tasks. They must also have safety training to recognize and address the electrical hazards associated with those tasks, including the correct personal protective equipment (PPE).
Qualified electricians have broader and deeper electrical knowledge, including a general understanding of the nature of electricity and all of the hazards associated with it. They also have more extensive safety training and more experience performing a variety of electrical tasks.
How do workers attain qualification?
The regulations requiring that work must be performed by qualified electrical workers are less specific about what companies must do to determine who is qualified. Company managers are responsible for reviewing the scope of work and the associated hazards, determining the minimum level of skill and knowledge needed to perform the task safely, and identifying the training needed to provide that level of knowledge and skills.
It’s important to document those requirements and the process by which employees meet them. Personnel files should include clear evidence of the employee’s qualifications, how they were obtained and verified, and past experience with tasks of this type, as well as training related to regulations and proper PPE. It’s also wide to document any refresher or retraining the employee receives, especially if that training’s intent is to correct a deficiency in the employee’s knowledge or performance.
A practical approach to qualification
Attending single-day training on NFPA 70E is not adequate for qualifying an employee to perform electrical work. While that training can be helpful, it should be just one component of a broader overall training program.
When developing your training program, start by listing the tasks that employees will need to perform on or near energized equipment. Identify any hazards associated with those tasks and the specific skills and knowledge needed to perform the work safely. Include training associated with acquiring and verifying those skills. Finally, compare those requirements to employees’ actual skills and knowledge, so you can identify any training needed to fill gaps.
As a general rule, qualified electrical workers will need at least two to five days of training each year to maintain their skill level. 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. You can also benefit by having your program regularly reviewed and audited by a professional safety consultant.
Also keep in mind that compliance inspectors receive training in evaluating whether or not employees are qualified to perform certain tasks. While your documentation serves as a guideline, there will inevitably be variations in how compliance personnel interpret the guidelines.