OSHA Dress Rehearsals
Defining who’s qualified for electrical construction and operation.
NFPA Journal®, September/October 2008
When meeting OSHA requirements, the difference between a qualified and an unqualified person can be something as simple as a dress rehearsal.
The definition of “qualified person” remains unchanged in the 2009 edition of NFPA 70E®, Electrical Safety in the Workplace®, and matches the definition in the 2008 edition of NFPA 70®, National Electrical Code®. According to these two documents, a qualified person is “one who has skills and knowledge related to the construction and operation of the electrical equipment and installations and has received safety training to recognize and avoid the hazards involved.”
Section 1910.399 of OSHA’s electrical requirements, which was revised in August 2007, defines a qualified person as “one who has received training in and has demonstrated skills and knowledge in the construction and operation of electrical equipment and installations and the hazards involved.” OSHA has established a benchmark on which the qualifications of a worker must be measured by including the phrase “has demonstrated skills” in this definition. To be qualified to perform a task, workers must now demonstrate that they can safely perform a task before they are qualified to do the task. Because the 2009 NFPA 70E revision cycle was well underway when OSHA issued its new definition, correlation between the two definitions will have to wait until the next revision of NFPA 70E unless a tentative interim amendment is processed.
Section 110.6 of NFPA 70E provides training requirements that apply to employees who face a risk of electrical hazard that is not reduced to a safe level by the applicable electrical installation requirements. Section 110.6(B) permits the training to be conducted in the classroom, on the job, or as a combination of the two, while Section 110.6(D)(1) lists the extensive training required for a qualified person.
Two new requirements of the 2009 edition mandate that employees performing tasks that are performed less than once a year be retrained before starting the task and that employees be trained to select an appropriate voltage detector. This last requirement can be found in Paragraph 110.6(D)(1)(d) and (e). Section 110.6(E) of the 2009 edition now requires that training be documented, as well.
Let’s look at a few specific cases. The first is the basic task of turning lights on and off in an office from a circuit breaker panel. To be qualified to do this, workers assigned to the task need training. To meet the objective measures specified in the OSHA definition of a qualified person, they must actually demonstrate that they know how to operate the breaker. If there are breakers in the panel that should not be turned on or off, they must also be trained to recognize them. If a breaker is locked or tagged, they must understand what that means and not interfere with the task in process. The training should also include an explanation of the requirements of Section 130.6(K) that prohibit reclosing a tripped breaker until the workers assigned determine that the circuit can be safely re-energized. If the office lights go out because the circuit breaker in the panel trips, the person qualified to turn the lights on in the morning is not qualified to reset the breaker.
This seems like a lot of training just to turn on the lights, but it would actually only take five minutes of every office worker’s annual electrical safety training. If that annual training is recorded and a record of attendance is kept, the documentation requirement of training is also met.
Now let’s use an industrial example. Consider the training required to ensure that plant electricians are qualified to withdraw a motor control center “bucket.” Again, workers need all the training found in Section 110.6(D)(1), which includes “trained and knowledgeable of the construction and operation of equipment.” If the motor control center is a Model X made by Vendor A, the workers must know the specific features of that model bucket, including the release mechanism operation and location. Once again, the benchmarks set by the OSHA definition requires workers to demonstrate their skill by withdrawing a bucket before they are considered qualified to do so. Workers can demonstrate their skill by removing a bucket before the motor control center is put in service with training from the person installing the center or with on-the-job training from someone already qualified.
Now let’s get to the dress rehearsal. The arc flash incident energy level at the motor control center is 21 calories/centimeter squared, and the worker knows that Hazard/Risk Category 3 personal protection equipment (PPE) is required. Before workers are qualified, they must actually demonstrate their skill, which includes wearing the correct 2008PPE. Why? Because it will allow the workers to discover whether the gloves provide enough dexterity to operate the mechanisms, whether the tint of the face shield makes additional lighting necessary, and whether the PPE provides enough dexterity to withdraw the buckets on the floor level and the very top.
Workers sent to another facility with Model W of Vendor A’s motor control centers will not be qualified to withdraw a bucket until they have demonstrated their skill, including withdrawing Model W buckets wearing the appropriate PPE.
Several people have asked me whether a state-licensed electrician is electrical-safety qualified. In order to be electrical-safety qualified, personnel must be trained per Section 110.6(D)(1) and demonstrate the skill the specific task requires.
Bill Buss is senior electrical engineer for NFPA and is staff liaison for NFPA 70E.