By Dennis Neitzel
AVO Training Institute, Director Emeritus
Are Your Electrical Workers Qualified?
There is a serious misconception throughout industry that a licensed Journeyman or Master Electrician constitutes a Qualified Person. This is not necessarily true. A Journeyman or Master license is obtained through a required number of years working under a licensed electrician (depending on the state, county, or municipality requirements) and passing a National Electrical Code® (NEC) exam. As an example; a licensed Master Electrician may have 10 years of hands-on field experience and qualifications in wiring residential buildings but they would not be experienced or qualified to work in a manufacturing facility and therefore could not be hired as a Qualified Person. The following definitions will make this clear.
The OSHA 29 CFR 1910.399 defines a Qualified Person “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 to the definition:
“Note 1 to the definition of ‘‘qualified person:’’ Whether an employee is considered to be a ‘‘qualified person’’ will depend 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 have provided strict requirements for training that go hand-in-hand with the qualification of an employee. The following information is provided in order to clarify the OSHA mandates for training qualified workers in the electrical field.
OSHA 29 CFR 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.” OSHA goes on to require: “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, and
• 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).” 
OSHA 1910.332 also states the following concerning the training required for qualified employees:
“The training requirements contained in this section [1910.332] apply to employees who face a risk of electric shock…
Note: 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.”
Typical Occupational Categories of Employees Facing A Higher Than Normal Risk of Electrical Accident
|Blue collar supervisors (1)
|Electrical and electronic engineers (1)
|Electrical and electronic equipment assemblers (1)
|Electrical and electronic technicians (1)
|ndustrial machine operators (1)
|Material handling equipment operators (1)
|Mechanics and repairers (1)
|Riggers and roustabouts (1)
|Stationary engineers (1)
|Footnote(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 the supervise close enough to exposed parts of electric circuits operating at 50 volts or more to ground for a hazard to exist.
OSHA 29 CFR 1910.269(a)(2)(i), as well as NFPA 70E, 110.2 requires employees to be trained in and familiar with the safety-related work practices, safety procedures, and other safety requirements as it pertains to their respective job assignments. OSHA also requires employees to be trained in any other safety practices, including applicable emergency procedures that are related to their work and are necessary for their safety.
Qualified employees are required to be trained and competent in:
- Skills and techniques necessary to distinguish live parts for 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. They also require the employer, through regular supervision and annual inspections, to verify that employees are complying with the safety-related work practices. Additional training or retraining may also be required if:
- The supervision or annual inspection indicate non-compliance with work practices
- New technology
- New types of equipment
- Changes in procedures
- Employee is required to use work practices that they normally do not use
Tasks that are performed less often than once per year would require refresher of 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. In fact, OSHA 1910.269 requires the employee to demonstrate proficiency in the work practices involved before the employer can certify that the employee has been trained. Note the statement that requires the employee to demonstrate proficiency in the work practices involved. The only way the employee can demonstrate proficiency is through a written exam and/or to actually do the work after receiving or as part of the training. Hands-on training would be required in order to accomplish this OSHA requirement.
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 that 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.” All training and retraining must be documented.
One of the most important aspects of electrical safety is to ensure that all employees who are or may be exposed to energized electrical conductors or circuit parts are properly trained and qualified. In addition to the requirements stated above from OSHA, NFPA 70E, 110.2, Training Requirements, states that employees are required to be “trained to understand the specific hazards associated with electrical energy,” “the 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.”
OSHA 1910.269(a)(2) also states that “the training shall establish employee proficiency in the work practices required by this section and shall introduce the procedures necessary for compliance with this section.
The employer shall certify that each employee has received the training required by paragraph (a)(2) of this section. This certification shall be made when the employee demonstrates proficiency in the work practices involved and shall be maintained for the duration of the employee's employment.”
According to OSHA, “Qualified Persons" are intended to be only those who are well acquainted with and thoroughly conversant in the electric equipment and electrical hazards involved with the work being performed. 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.
As can be seen by the above quotes from NFPA 70E 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. Protective devices, controls, instrumentation, and interlock systems demand that technicians be trained and qualified at a high technical skill level. Safety and operating procedures utilized in working on these systems are equally as complex requiring technicians to be expertly trained in all required skills, as well as safety practices and procedures.
Utilizing only Qualified Persons to perform electrical work can greatly reduce the risk to the safety of employees, as well as increasing reliability of the electrical system and equipment.