Subpart V is the corresponding construction standard to 20 CFR 1910.269 Electrical Power Generation, Transmission, & Distribution: Electrical Protective Equipment. These two standards outline how we are to do the work in the electrical construction business.

For purposes of this column, I want to just focus on the training requirements under 1926, since OSHA continues to focus inspections on what is required in the training space. I will not cover the specialized training for jobs such as live line barehand and hot stick work. Let’s take a look at the guidance OSHA provides.

OSHA’s 1926 Subpart V covers safety requirements for the construction of electric power transmission and distribution lines and equipment. A crucial component of this standard is ensuring  workers are adequately trained to recognize and avoid hazards associated with this high-risk work environment.

The training requirements are designed to ensure all employees working on or near energized lines or equipment have the knowledge and skills necessary to perform their jobs safely.

Per 1926.950(b), employers are required to ensure that employees exposed to electrical hazards are trained in the safety-related work practices, procedures and other requirements pertaining to their jobs. Training must be provided before the employee is assigned to work involving exposure to these hazards.

Qualified versus unqualified employees

• OSHA distinguishes between two types of employees. All qualified employees:
• Have received training and demonstrated the ability to work on or near exposed energized parts
• Must understand the construction and operation of equipment involved and the hazards
• Must be able to distinguish exposed live parts and determine the nominal voltage
• Must know the minimum approach distances for live parts and the proper use of protective equipment

An employee is not qualified until the employer has verified their qualifications through demonstration and documentation of their proficiency in the safety practices. This can be through observation by supervisors, formal testing or performance evaluation. 

An unqualified employee can only become qualified under the direct supervision of a qualified person until they demonstrate proficiency. Unqualified employees must still receive safety training, but they are prohibited from working near energized parts unless under the direct supervision of a qualified employee. 

Initial training must be provided before the employee performs work exposing them to electrical hazard and should include practical instruction, classroom sessions and, if applicable, on-the-job training.

Refresher training and retraining

Retraining is required when supervision or annual inspections indicate noncompliance with safe work practices, new technology or equipment is introduced, the job duties change, an incident or near-miss occurs or retraining must re-establish proficiency.

OSHA does not specify a frequency for retraining, but it should be done as often as needed to maintain safe work practices. While the language does give flexibility, it should be noted that refresher training needs to occur and be documented at least annually.

The specific training for qualified employees must include: identification of electrical hazards; application of personal protective equipment; safe approach distances to energized parts; use of insulating tools and equipment; procedures for de-energizing lines and equipment; emergency response and first aid, including CPR; fall protection and aerial lift operation (if applicable); grounding techniques and inspection of grounding devices; proper use of protective grounds and testing for absence of voltage; and minimum approach distances and how they are determined.

For first aid training and CPR, at least two trained employees must be present at a work site and be current on their certifications.

Unqualified workers must be trained to understand the hazards and precautions necessary to avoid injury, including maintaining safe distances and recognizing warning signs and barriers. 

All training must be documented and include the date it happened, content covered, name and qualifications of trainer, and employee names and signatures. Employers are responsible for ensuring workers retain and apply the training.

OSHA 1926 Subpart V mandates comprehensive training to ensure worker safety in the electric power transmission and distribution industry. It emphasizes the difference between qualified and unqualified employees, the need for initial and ongoing training, and the requirement for documentation and proficiency demonstration. Ultimately, training is an employer’s responsibility and is critical for compliance and the prevention of serious injuries or fatalities in this high-hazard industry.

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