Bringing clarity to contractors about construction safety and OSHA standards has become a quest for Palmer Hickman, director of code and safety curriculum and training at the Electrical Training Alliance, Bowie, Md.
He said all contractors may not be aware that OSHA 10 and OSHA 30 outreach training does not satisfy OSHA’s standard training requirements.
OSHA 10 is intended to provide entry-level construction workers an awareness about their rights, employer’s responsibilities, how to file a complaint and how to identify, abate, avoid and prevent job-related hazards. OSHA 30 provides a variety of training to workers with some supervisory and safety responsibility, and it emphasizes hazard identification, avoidance, control and prevention.
“OSHA states that OSHA 10 and 30 outreach training is voluntary,” Hickman said. “And, although apprenticeship standards allow for OSHA 10 and OSHA 30 to be selected as an elective option, neither is a mandatory part of apprenticeship standards.”
Both courses apply to workers employed in a variety of industries, not just the electrical trade. Taking the courses does not make electrical contracting personnel qualified to work energized or to be considered competent for making calls to shut down work sites due to hazardous conditions, Hickman said.
Achieving “qualified” or “competent” status requires satisfying OSHA standards for the electrical industry.
Fueling assumptions that OSHA 10 and 30 satisfy more of the burden for safety than they actually do, construction contracts frequently stipulate that electrical contractor employees must have received these two trainings in the last four to five years.
Affirming this trend is Brad Caldwell, director of safety for Morrow-Meadows Corp., City of Industry, Calif., which operates with a 2,000-strong workforce and four regional offices on the West Coast.
To satisfy contract requirements, Morrow-Meadows makes certain that journeymen and apprentices are trained every four to five years in the 10-hour course. Supervisors receive the 30-hour training.
The company selects personnel for OSHA 500 and 502 instructional training, enabling them to provide in-house OSHA 10 and 30 training. Morrow-Meadows also relies on Apprenticeship-Journeymen Training Centers and local IBEWs to provide OSHA 10 and 30 training.
“While OSHA 10 and 30 are important, there’s a lot more to operating safely in the electrical industry,” Hickman said. “That will always require satisfying OSHA standards and that includes training beyond OSHA 10 and 30.”
Because the electrical code is updated every three years, and because every construction job is different, satisfying OSHA standards poses significant challenges.
Hickman identified Morrow-Meadows as an example of a contractor that trains employees beyond OSHA 10 and 30. The company frequently works on complex large-scale projects likely to expose safety vulnerabilities.
A winner of NECA’s Recognition of Safety Achievement Awards in 2018, 2019 and 2021, Morrow-Meadows employs 11 full-time safety professionals. Of those, seven have Board of Certified Safety Professionals certifications as construction health and safety technicians. The rest are working toward these certifications.
“Because we’re not expecting our field supervisors to memorize the entire electrical code, having safety professionals really takes the pressure off,” Caldwell said. “It helps supervisors to know they have an avenue for researching and responding to safety issues. A lot of times, we’re just confirming that their thinking is right, that they are going in the right direction. If it’s more complicated, we can get someone to the site to work out a solution.”
For larger projects, Morrow-Meadows assigns full-time safety personnel.
NFPA 70E, Standard for Electrical Safety in the Workplace, provides a prescriptive-based approach that many electrical contractors prefer as a means to comply with OSHA’s performance-based rules, Hickman said.
Morrow-Meadows’ safety team developed a 16-hour course in NFPA 70E.
“We limit those who attend the class,” Caldwell said. “We’re looking for people who are calm under stress, who can absorb pressure, those who make educated decisions and who will be working on energized components.”
To pass the course and be considered “qualified” according to OSHA standards, the employee must demonstrate the ability to work energized.
Morrow-Meadows personnel considered “competent” for ensuring safety requirements are not required to take the NFPA 70E class or demonstrate the ability to work energized, he said.
“For us, OSHA (the regulations) are the ‘shall’ and NFPA 70E is the how,” Caldwell said.