NFPA 70E, the National Electrical Code and OSHA requirements for construction and general industry all require that an employee be qualified for the task at hand.
NFPA 70E defines “qualified person” in Article 100 as “One who has demonstrated skills and knowledge related to the construction and operation of electrical equipment and installations and has received safety training to identify the hazards and reduce the associated risk.” While the NEC Style Manual applies to NFPA 70E and does not permit definitions to contain requirements, the NFPA 70E definition is short, contains requirements and describes the necessary attributes of a qualified person.
The first attribute is having demonstrated skills and knowledge related to the construction and operation of electrical equipment and installations. This necessitates looking at the equipment an individual will be tasked to work on. Do they have the skills and knowledge necessary to operate the equipment?
Consider an inside electrical worker with 30 years of experience. It’s very likely they understand the construction and operation of a standard main lugs only panelboard in a 208/120V system. An employer can document “demonstrated” skills and knowledge on equipment in many ways. Some set up training facilities with various types of distribution equipment to help document the demonstrated part, but it is not possible on every piece of equipment.
Skills and knowledge on “installations” are easily overlooked. The worker might have never been trained on or exposed to medium-voltage systems, ungrounded delta systems, two-phase five-wire systems and more.
The last piece of the “qualified person” definition is receiving safety training to identify the hazards and reduce the associated risk. This is addressed in the requirements of 110.6(A)(1) for qualified person training.
So who determines qualification? The employer decides, and OSHA says the foreman is the employer on each job site. All supervisory personnel should ensure each employee is qualified for the task assigned. In almost every case, an unqualified person can be trained in the field to understand. Frontline foremen play a key role with respect to qualifications. Foremen already understand this, as they would not likely assign certain tasks to electricians they do not know well; they will assign those tasks to workers they know have the requisite experience.
During 70E training, when we ask inside electrical workers if they are qualified, they almost always nod their head without knowing what task they will be performing. Asking example questions will get any group thinking hard about what they are and are not qualified for.
For example, let’s look at a 15-kilovolt fused disconnect with an observation window. Considering only the skills and knowledge related to the construction and operation of electrical equipment, determine if you are qualified for the following task: Open the switch and, with a flashlight, look in the observation window to ascertain if all the blades opened. At this point, you have determined your qualified status.
But here’s one more question: When you looked to see if all the blades opened, how many blades were you looking for? If you looked for three, you are not qualified. There is an accompanying arc chute blade for each main blade; you need to look for six.
Section 130.1 mandates that only qualified persons are permitted to work on electrical conductors or circuit parts that have not been put into an electrically safe work condition. This means they meet the definition of “qualified person” and are additionally trained as required in 110.6(A)(1). This mandates that qualified persons are trained and knowledgeable in the construction and operation of equipment or a specific work method and are trained to identify and avoid potential electrical hazards in that equipment or work method.
A person can be qualified for certain equipment and tasks but unqualified for others. Section 110.6(A)(1) requires familiarity with precautionary techniques, applicable electrical policies and procedures, PPE, insulating and shielding materials, and insulated tools and test equipment. Any employee who will cross the limited approach boundary must have skills and techniques to distinguish exposed energized electrical conductors and circuit parts from other aspects of electrical equipment and the ability to determine nominal voltage.
Training also includes determination of shock protection limited and restricted approach boundaries and the decision-making process to safely plan the job, identify electrical hazards, assess the associated risk and select appropriate risk-control methods from the hierarchy of controls in 110.5(H)(3). It can also include lockout/tagout, test instruments, emergency first aid, CPR and more.
Remember that all training must be documented. If it is not documented, it did not happen. (See page 10 for more on this topic.)
About The Author
DOLLARD is retired safety coordinator for IBEW Local 98 in Philadelphia. He is a past member of the NEC Correlating Committee, CMP-10, CMP-13, CMP-15, NFPA 90A/B and NFPA 855. Jim continues to serve on NFPA 70E and as a UL Electrical Council member. Reach him at [email protected].