1. Why do I need to provide training?
There is a legal and moral obligation for employers to provide a workplace that is free of hazards which can cause serious injury and death. According to 2005 data from the federal Bureau of Labor Statistics, an average of 25 to 30 injuries and one fatality occur every day in the U.S. due to electrical shock or arc flash. Training employees in safe work practices and hazards is an integral part of meeting this obligation.

The Occupational Safety and Health Administration (OSHA) requires employee training according to OSHA Title 29, Regulations 1910.332 and 1910.269 (a)(2). In addition, Article 110.6 of the National Fire Protection Association NFPA 70E, Standard for Electrical Safety in the Workplace, contains training requirements. These regulations and standards specify who must be trained and the content of the training.

2. Who needs training?
All employees that work on or near exposed energized parts of 50 volts or more, that have not been placed in an electrically safe condition, must be qualified. Employees that have been trained in construction and operation of equipment and the hazards involved are considered qualified.

OSHA 1910.132 table S-4 lists the following personnel as those that face higher than normal risk of electrical accident and require training:
     • Blue collar supervisors
     • Electrical and electronic engineers
     • Electrical and electronic equipment assemblers
     • Electrical and electronic technicians
     • Electricians
     • Industrial machine operators
     • Material handling equipment operators
     • Mechanics and repairers
     • Painters
     • Riggers and roustabouts
     • Stationary engineers
     • Welders

3. What does it mean to be qualified?
Other than construction and operation, qualified employees must be trained to recognize and avoid electrical hazards (i.e., shock and arc flash), understand special precautionary techniques and use of PPE, insulating and shielding materials and insulated tools and equipment. In addition:

• Qualified employees must be able to recognize various parts of the electrical equipment and visually determine which parts are likely to be current carrying and which parts are not expected to be energized.

• Qualified employees must be able to read the label, single-line diagrams, schematics, take voltage measurement or otherwise determine nominal voltage of exposed live parts.

• Qualified employees need to be able to determine arc flash, limited approach, restricted approach, and prohibited approach boundaries.

• Qualified employees must be able to determine maximum available fault current and clearing time of protective devices (required for arc flash hazard analysis), or be provided with information on the level of arc flash hazard by employer.

• Qualified employees must also be able to perform a hazard analysis, determine the shock and arc flash hazard, plan the job and protect themselves and others from harm.

Many employees and employers claim that they do not work on energized parts; therefore, they contend that training beyond lockout is not required. However, electrical parts are considered energized until proven otherwise. Tasks such as troubleshooting, calibration, voltage measurement and other electrical measurement cannot always be performed on equipment that has been placed in an electrically safe condition. Therefore, if employees are expected to perform these tasks, then they must be trained and meet the definition of a qualified person.

4. Who needs to be qualified in my facility?
This introduces the level of qualification. In the following example, assume there are two employees. The first employee is the equipment operator that is required to access an electrical cabinet as a part of his daily routine, which contains exposed energized parts. Does he need to be qualified? The answer is yes, but the length, content and frequency of training required to qualify him is much less than the second employee, a maintenance person. Maintenance personnel are expected to perform electrical measurement, troubleshoot or calibrate energized electrical equipment, lockout/tagout, repair and modify the cabinet, and therefore require additional training that covers all of these areas. Keep in mind that an employee may be considered qualified for certain tasks and equipment and unqualified for other tasks and equipment at the same time.

As a side note, insulating and isolating the energized parts in the cabinet accessed by the operator eliminates the shock hazard. If there is no arc flash hazard, then the employee does not need to be electrically qualified.

5. What is the content of training?
The content of the training, length of training and refresher frequency is based on the complexity of the task the employer expects the maintenance person to perform. As with any electrical safety program, it must include a statement from the company that electrical equipment must be placed in an electrically safe condition before employees work on or near it, and that the employer will determine and certify if energized work is required based on allowed justifications in the regulations. The rest of the training depends on the audience and its level of expertise. In the earlier question, “What does it mean to be qualified?”, there is a list of what a qualified employee needs to know. This list, along with job site hazards and the tasks the employee is expected to perform, provide an outline for the course content. For example, an employee whose sole exposure to electrical equipment is operating a 480V disconnect switch may need one hour of training, one time. The content of training would include how the switch works, verification the cover is closed, why it is closed, where to stand, when to ask for help and what the switch operates.

However, a maintenance person, supervisor or team leader is required to:
    • Develop procedures to be used when working on
      or near exposed energized parts
    • Determine safe work practices
    • Complete a shock hazard analysis and determine
      shock protection boundaries
    • Complete a flash hazard analysis and flash
      protection boundary
    • Determine and select appropriate PPE
    • Hold a job briefing and protect unqualified employees

A maintenance person, supervisor or team leader may need eight to 24 hours or more of training each year to ensure skills are up to date and augmented with new information. The new information presented may include facility changes, construction and operation of new equipment, new procedures, new methods of hazard analysis and hazards not previously identified.

6. How often does OSHA or NFPA require training?
Neither regulations (OSHA) nor the consensus standards (NFPA) require a certain length or specify how often refresher training is required. Only the employer and employee working together can determine how much and how often training is required.

For example, Schneider Electric provides eight hours of initial electrical safety training for manufacturing plant and maintenance personnel, followed by four hours of additional training each subsequent year. For Square D Services personnel that work at a customer site, Schneider Electric provides eight hours of electrical safety training every year. This training is in addition to the equipment’s construction and operation training that they have to complete in order to remain qualified.

7. When do I provide training?
Employees must be qualified for the tasks that they are expected to do and may be trained on the job and in the classroom. As long as a new employee, or an employee that is being qualified for new equipment, can demonstrate that he understands the basics of the equipment and its hazards, he may work on or near energized parts under direct supervision of a qualified employee. He will continue to work with a qualified employee until the employer determines that the new employee is qualified.

8. Who is authorized to provide equipment and safety training and how is it documented?
Recall that the employer determines that the employee is qualified. To the knowledge of Square D Services, there are no agencies or groups that certify an instructor or a company to train and qualify maintenance workers for electrical work.

If the company does not have the expertise internally to qualify employees, then good resources to investigate include local technical schools and colleges, the original equipment manufacturer, and test tools and equipment manufacturers, which provide training in construction and operation of the equipment.

Be sure to document the training using a sign-in sheet or certificates attached to the training materials. If a trainer is hired to train employees on the hazards of working on energized parts (i.e., electrical safety training), then the provider’s expertise, experience, references and instructor qualification must be evaluated to ensure the instructor is capable of conveying the needed information and, once again, document the training.

Certification requirements vary from state to state, so check with local authorities for additional information.

9. Do I have to audit safe work practices?
According to OSHA 1910.269 and 1910.147 (lock out/tagout), an employer is required to audit a qualified employee’s work practices at least once per year.

Therefore, managers and supervisors must attend electrical safety training classes, as without their understanding of the requirements and proper safe work practices, employee audits would not be very effective.

10. Final thoughts
Maintenance workers and all other employees exposed to energized parts of 50V or more must be qualified. The employer is ultimately responsible for determining what level of classroom and on-the-job training is required for the employee to be considered qualified. A vital part of electrical safety training is understanding the electrical system, determining shock and arc flash hazards, and developing and implementing an electrical safety program based on those hazards. Employees must be trained on construction and operation of electrical equipment and the specific hazards involved before they are considered qualified. Auditing of the electrical safety program and safe work practices utilized, along with retraining and improving safe work practices based on audit results, will ensure compliance and continuous improvement.

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