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SPECIAL REPORT

STAY SAFE NOT SORRY

SPECIAL REPORT

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S M A R T S O L U T I O N S F O R M A I N T E N A N C E & R E L I A B I L I T Y

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Electrical Safety and the “Qualified Person” . . . . . . . . . 2Compelled to Stay Safe in Confined Spaces . . . . . . . . . 10How the IIoT is Changing Electrical Safety . . . . . . . . . . 14

Properly train and qualify your teams to avoid injury

in electrically hazardous areas

Occupational Safety and Health (OSHA) regulations, along with the National Fire

Protection Association (NFPA) in NFPA 70E® Standard for Electrical Safety in the

Workplace, require employers to document that employees have demonstrated

proficiency in electrical tasks. Employers must “certify” (document) that their employees

are trained and qualified and that this certification is maintained for the duration of the em-

ployee’s employment. OSHA’s intent here is to ensure that the training is well documented;

a notation in the employees training record would suffice for in-company training. If the

employee attends training outside of his/her company, a Certificate of Completion would

serve as acceptable documentation that the training was successfully completed. A copy of

the certificate should be maintained in the employees training record.

Utilizing only Qualified Persons to perform electrical work can greatly reduce the risk to the

safety of the employee, as well as increasing reliability of the electrical system and equip-

ment. This article defines and identifies who a Qualified Person is; outlines the training

requirements for the skills and knowledge required for a person to be considered qualified;

and explains how this can reduce the risk of employee injuries and fatalities.

Electrical Safety and the “Qualified Person”Reduce the Risk of Electrical Accidents by Utilizing Only Trained and Qualified Electrical Workers

By Dennis K. Neitzel, CPE, CESCP, AVO Training Institute, Inc.

& Timothy L. Gauthier, CESCP, AVO Training Institute, Inc.


ELECTRICAL SAFETY 2


ELECTRICAL SAFETY 3

QUALIFIED PERSON REQUIREMENTSThere is a serious misconception through-

out industry that a licensed Journeyman

or Master Electrician constitutes a Quali-

fied Person. This is not necessarily true. A

Journeyman or Master license is obtained

through a required number of years work-

ing under the guidance of a licensed electri-

cian (depending on federal, state, county,

or municipality requirements) and passing a

National Electrical Code (NEC®) exam. As an

example; a licensed Master Electrician may

have 10 years of hands-on field experience

and qualifications in wiring residential build-

ings but he/she would not be experienced

or qualified to work in a manufacturing or

processing facility and therefore could not

be hired as a Qualified Person. The follow-

ing definitions will help make this clear.

The NFPA 70E defines a Qualified Person

as “one who has demonstrated skills and

knowledge related to the construction and

operation of electrical equipment and in-

stallations and has received safety training

to identify and avoid the hazards involved.”

OSHA 29 CFR 1910.399 provides a simi-

lar definition of a Qualified Person, stat-

ing “one who has received training in and

has demonstrated skills and knowledge in

the construction and operation of electric

equipment and installations and the haz-

ards involved.”

OSHA provides additional information on

what constitutes a Qualified Person in the

following notes to the definition:

• Note 1 to the definition of qualified person:

“Whether an employee is considered to be

a “qualified person” will depend upon vari-

ous circumstances in the workplace. For

example, it is possible and, in fact, likely

for an individual to be considered “quali-

fied” with regard to certain equipment

in the workplace, but “unqualified” as to

other equipment. (See 1910.332(b)(3) for

training requirements that specifically ap-

ply to qualified persons.)”

• Note 2 to the definition of qualified per-

son: “An employee who is undergoing

on-the-job training and who, in the course

of such training, has demonstrated an

ability to perform duties safely at his or

her level of training and who is under the


ELECTRICAL SAFETY 4

direct supervision of a qualified person is

considered to be a qualified person for the

performance of those duties.”

Since one of the three qualification re-

quirements is being trained in the hazards

of the equipment, it must be addressed

specifically. OSHA and NFPA 70E have

provided strict requirements for safety

training that go hand-in-hand with the

qualification of an employee. The follow-

ing information is provided in order to

clarify the OSHA mandates for training

employees in the electrical field:

OSHA 29 CFR 1910.332 Training, requires a

Qualified Person to be trained in “the safe-

ty-related work practices that are required

by 1910.331 through 1910.335 that pertain

to their respective job assignments.” OSHA

goes on to require: “Qualified Persons” (i.e.

those permitted to work on or near exposed

energized parts) shall, at a minimum, be

trained in and familiar with the following:

1. The skills and techniques necessary to

distinguish exposed live parts from other

parts of electric equipment.

2. The skills and techniques necessary to

determine the nominal voltage of ex-

posed live parts, and

3. The clearance distances specified in

1910.333(c) and the corresponding volt-

ages to which the qualified person will be

exposed.”

• Note 1: For the purposes of 1910.331

through 1910.335, a person must have the

training required by paragraph (b)(3) of

this section in order to be considered a

qualified person.

• Note 2: Qualified persons whose work on

energized equipment involves either di-

rect contact or contact by means of tools

or materials must also have the training

needed to meet 910.333(C)(2).”


ELECTRICAL SAFETY 5

OSHA 1910.332 also states the follow-

ing concerning the training required for

qualified employees: “The training require-

ments contained in this section [1910.332]

apply to employees who face a risk of

electric shock. ... Note: Employees in oc-

cupations listed in Table S-4 face such a

risk and are required to be trained. Other

employees who also may reasonably be

expected to face comparable risk of injury

due to electric shock or other electrical

hazards must also be trained.”

Table S-4. Typical Occupational Categories of Employees Facing A Higher Than Normal Risk of Electrical Accident

Occupation

Blue collar supervisors.(1)

Electrical and electronic engineers.(1)

Electrical and electronic equipment as-semblers.(1)

Electrical and electronic technicians.(1)

Electricians

Industrial machine operators.(1)

Material handling equipment operators.(1)

Mechanics and repairers.(1)

Painters.(1)

Riggers and roustabouts.(1)

Stationary engineers.(1)

Welders.

Footnote (1): Workers in these groups do not need to be trained if their work or the work of those they supervise does not bring them or the employees the supervise close enough to exposed parts of electric circuits operat-ing at 50 volts or more to ground for a hazard to exist.

In addition to the requirements noted

above, qualified employees also are re-

quired to be trained in:

1) The proper use of:

• Special precautionary techniques

• Insulating and shielding materials

• Insulated tools and test equipment

• Job planning

2) Decision-making process necessary to be

able to do the following:

• Perform the job safety planning

• Identify electrical hazards

• Assess the associated risk

• Select the appropriate risk control

methods from the hierarchy of controls,

which include:

• Elimination

• Substitution

• Engineering controls

• Awareness

• Administrative controls

• PPE

A person is required to receive, as a mini-

mum, this training in order to be consid-

ered a qualified person. The employer is

required, through regular supervision and

annual inspections, to verify that employees

are complying with the safety-related work

practices. Additional training or retraining

may also be required if:

• The supervision or annual inspection indi-

cate non-compliance with work practices

• New technology

• New types of equipment

• Changes in procedures

• Employee is required to use work prac-

tices that they normally do not use


ELECTRICAL SAFETY 6

Tasks that are performed less often than

once per year may require retraining be-

fore the performance of the work practices

involved. This retraining may be as simple

as a detailed job briefing prior to the com-

mencement of the work or it may require

more in-depth classroom instruction, along

with on-the-job training. All training is re-

quired to establish employee proficiency in

the work practices and procedures. In fact

OSHA and NFPA 70E requires the employ-

ee to demonstrate proficiency in the work

practices involved before the employer can

certify that the employee has been trained.

The only way the employee can demon-

strate proficiency is through a written exam

and to actually do the work after receiving

or as part of the training.

Hands-on training would be valuable in

accomplishing the type of training that

requires demonstrated proficiency. The

required skills and knowledge training

must be classroom, on-the-job type, or a

combination of the two. The type of safety

training provided must be determined by

the risk to the employee. Electrical safety

retraining is required to be performed at

intervals not to exceed 3 years, due to the

3-year revision cycle of NFPA 70E. All train-

ing and retraining must be documented.


ELECTRICAL SAFETY 7

In addition to the requirements stated

above, employees must also be trained to

understand the specific hazards associated

with electrical energy, the safety-related

work practices, and procedural require-

ments. These training requirements are

necessary to help protect employees from

the electrical hazards associated with their

respective job or task assignments, as well

as to identify and understand the relation-

ship between electrical hazards and pos-

sible injury. Training in emergency pro-

cedures is also required when employees

are working on or near, or interacting with

electrical equipment, especially when there

are exposed energized electrical conduc-

tors or circuit parts.

Qualified Persons are intended to be only

those who are well acquainted with, and

thoroughly conversant in, the electric equip-

ment and the electrical hazards involved

with the work being performed. OSHA

and NFPA are consistent in their require-

ments for training and qualifying employees

to perform work on electrical equipment

and systems. As can be seen by the above

statements, proper training is a vital part of

the worker’s safety and proficiency, as well

as the reduction of risk to the employee

Dennis K. Neitzel, CPE, CESCP, is

Director Emeritus of AVO Training

Institute. Inc. (www.avotraining.com)

and has over 48 years of experience

in the electrical industry, specializing in electrical equip-

ment and systems maintenance, testing, engineering,

inspection, and safety. He is an active member of IEEE

(Senior Member), ASSE, AFE, IAEI, SNAME, and NFPA,

and is a Certified Plant Engineer (CPE), Certified Electri-

cal Safety Compliance Professional (CESCP), and a Cer-

tified Electrical Inspector-General. He is also a co-author

of the Electrical Safety Handbook, and can be contacted

at [email protected].

Timothy L. Gauthier, CESCP, is

Project Manager and Senior Training

Instructor of AVO Training Institute,

and has over 37 years of industrial

facilities electrical equipment and systems experience.

He is a Certified Electrical Safety Compliance Profes-

sional and a past General Motors Electrical Health and

Safety Certified Manager, and is an active member of

IEEE, ASSE, ASTM, IAEI, and NFPA. He can be contact-

ed at [email protected].


ELECTRICAL SAFETY 8

As can be seen in the main article, by the

quotes from NFPA 70E and OSHA, an

employee, in order to be considered a

Qualified Person, must receive extensive

training. The requirements for qualifying

employees must be established before the

needs assessment and job/task analysis

can be properly conducted.

Once these are complete, the hazards asso-

ciated with each task must be identified by

performing the electrical hazard risk assess-

ments, including the shock and arc flash risk

assessments, which are required by NFPA

70E. Proper training and qualification cannot

be properly developed and conducted until

these three functions are completed.

NEEDS ASSESSMENTThe needs assessment should be per-

formed before any significant Qualified Per-

son training can be developed and imple-

mented. This assessment involves relevant

company personnel who are aware of the

job requirements and all applicable codes,

standards, and regulations. Information

that is collected during the needs assess-

ment will provide insights into any past or

present performance problems that should

also be addressed in the training program.

This process can also be used to determine

whether or not training is the solution to

any problems that may exist.

JOB/TASK ANALYSISA review of the information collected

during the needs assessment will help to

write the initial job description. The job

description should contain the following

components:

• Job Title

• Qualification requirements for the job

• General description of job requirements

• Description of the job position within the

organization, including lines of super-

vision and assistance available to the

employee.

• Description of job environment

• Listing of tools and equipment used in

the job

• Listing of resource documents and refer-

ences used in the job

• Inventory of tasks

The most difficult part of the job descrip-

tion to develop is the task inventory,

which is a list of all tasks that make up

the job. A task is defined as an observ-

able, measurable unit of work which has

a definite beginning and end. A task

can be a performed in a relatively short

period of time (i.e., minutes, hours, or

days), and is independent of other ac-

tions. Each task is then made up of ele-

ments or steps, each of which must also

be identified.


ELECTRICAL SAFETY 9

ELECTRICAL HAZARD RISK ASSESSMENTSThe results of the electrical hazard risk

assessments constitute one of the most

important factors in determining hazard

mitigation techniques, risk management

responsibilities, the selection of personal

protective equipment, developing a train-

ing program for qualified persons, and

developing an effective electrical safety

program. The risk assessments are used

to identify the three hazards of electricity;

shock, arc flash, and arc blast, along with

potential employee exposure.

• The base requirement for conducting the

hazard assessments is provided by OSHA

1910.132(d)(1) which states: “The employ-

er shall assess the workplace to deter-

mine if hazards are present, or are likely

to be present, which necessitate the use

of personal protective equipment (PPE).”

NFPA 70E identifies what is needed for

conducting the electrical hazard risk as-

sessments for electrical equipment.

• The Shock Risk Assessment (Section

130.4) is performed to determine the

voltage exposure, shock protection

boundaries, and the required PPE neces-

sary to protect employees and minimize

the possibility of electrical shock.

• The Arc Flash Risk Assessment (Sec-

tion 130.5) is performed to help protect

employees by determining if an arc flash

hazard exists. If it is determined that

an arc flash hazard does exist then safe

work practices must be determined, the

arc flash boundary must be established

and required arc-rated PPE must be

identified in order to protect employees.

OSHA 1910.132(d)(2) additionally requires

employers to certify that they performed

a hazard assessment. The signed certifica-

tion must include the date of the hazard

assessment and the identification of the

workplace (area or location) evaluated.

Finally, the electrical hazard risk assess-

ments will also identify the requirements

for an Energized Electrical Work Permit.

Where employees are exposed to ener-

gized conductors or circuit parts, which

have not been placed in an electrically

safe work condition, the hazards must be

identified on the Energized Electrical Work

Permit along with the required PPE and

work procedures.

Compelled to Stay Safe in Confined Spacesby Matt Crouse, UL EHS Sustainability

The final years of the Obama administration have seen several changes to OSHA reg-

ulations in an agency not known for its ability to quickly promulgate standards. In

2015, OSHA released a new subpart to the 1926 construction standard. Subpart AA,

also noted as part 1201, is the Permit Required Confined Space for construction standard.

“Interesting,” you may say, “but I am not in construction. Why should I be concerned with

construction confined-space standards?” It’s important to remember that the activity you

are performing, not the industry classification, determines whether you follow 1910 Gen-

eral Industry standards or 1926 Construction standards. “Construction work” means work

for construction, alteration, and/or repair, including painting and decorating (see http://

plnt.sv/1606-OSHA for an August 1994 OSHA memorandum on “construction vs. main-

tenance”). Short of routine cleaning and component replacement, your activities could be

considered construction activities in the eyes of a compliance officer.

Work in and around electrical vaults presents unique hazards for workers. The obvious haz-

ard is electrical, and most companies have done their due diligence in reducing exposure.

But are you evaluating whether the vault is a permit-required confined space (PRCS)?

According to the new standards, a space will now be considered confined when it meets

the following construction industry definition:

ELECTRICAL SAFETY 10




1. It is large enough and so configured that

an employee can bodily enter it (notice

the difference from the general industry

standard in that it drops the “and perform

assigned work” wording),

2. It has limited or restricted means for en-

try and exit, AND

3. It is not designed for continuous occu-

pancy.

By the OSHA definition above, you are most

likely entering a confined space when you

enter an electrical vault. Further, a confined

space is a PRCS if it contains any other

recognized hazard. Until you verify that all

electrical hazard exposures are at a zero-

energy state, you are entering a PRCS when

going into an electrical vault. In practice,

rarely can all energy be at a zero state in

the entire vault. Because of that, any en-

try into an electrical vault is a PRCS entry

requiring that all permit procedures be

followed. It is not feasible to use alternative

methods and nearly impossible to maintain

a zero-energy state.

The solution: Upgrade your current con-

fined-space program to one based on the

requirements found in 29CFR1926 Subpart

AA. OSHA stated in the preamble to its

new standard that compliance with the

construction standard will meet compli-

ance with the general industry standard.

However, given the greater prescriptive

nature of the construction standard, the

reverse isn’t also true.

So what does such an upgrade look like?

To start, you’ll need a “competent person”

who can assess PRCS requirements on a

regular – or possibly daily – basis. Be se-

lective when choosing a candidate for this

position rather than making it an arbitrary

assignment. You will need documentation

of the person’s competency – in some cases

of noncompliance, this person can be held

criminally liable. If you select an untrained

hourly worker, you are not only setting ev-

eryone up for failure, but also you’re telling

a compliance officer that you did not take

this responsibility seriously.

After making a wise choice, be sure to em-

power your PRCS expert with the authority

to start and stop entries as well as provide

him or her with ongoing education and

certification. Your investment in this role

will pay additional dividends in an actively

engaged employee who sees value in this

responsibility.

Next, your PRCS expert should evaluate

and re-evaluate your spaces depending on



the activity performed there. Unless you are

cleaning, troubleshooting, or making in-kind

exact replacements in your electrical vault,

you could be viewed as performing con-

struction activities in your PRCS.

You will also want to revisit your rescue

program. Calling 911 is not a rescue plan.

OSHA requires rescuers to be familiar with

and practice actual rescues at least once

per year. It’s unrealistic to assume your lo-

cal fire department can train all potential

responders to practice rescue within your

spaces every year.

Lastly, the new subpart requires that if you

are relying on the local fire department for

a rescue, the department must notify you

if it is not going to be available to assist in

your rescue. If your entries are planned and

infrequent, it may not be cost-effective to

train and maintain rescue crews. Consider

performing only entries that can be self-

rescue or nonentry rescue. Note, too, that

an increasing number of companies perform

confined-space rescue services on demand.

Next, upgrade your equipment to include

ventilation failure and engulfment monitor-

ing. Don’t forget to train and document

employees expected to use this equipment.

Record daily or frequent bump tests to

prove your equipment is in good working

order and ready for service. If you can, get

extras of the exact same model of monitors,

because this equipment can and will fail.

The similarity of like models will prevent the

need for any additional training, documen-

tation, and calibration. You may not need

all of this equipment for all your entries, but

you will be ready for any construction entry.

Train, maintain, and document. Soon the

new standard will become the new norm.

It is only a matter of time before the gen-

eral industry confined-space requirements

found in 29CFR1910.146 will be replaced by

the requirements found in the construction

industry standard 29CFR1926.1201. Given

the speed with which this agency is begin-

ning to move, that may happen sooner

rather than later.

Upgrading your program to the new sub-

part AA of the construction standard will

ensure compliance regardless of the ac-

tivity. Of more importance, the review of

your PRCS program itself will improve your

safety program. These complicated changes

might seem onerous at first, but remember

their ultimate purpose. They will help keep

your workers safe, and that’s the most im-

portant thing for any employer to do.

Matthew Crouse is a senior EHS advi-

sor at UL EHS Sustainability (www.

ulehssustainability.com). His 16-year

career covers the automotive, heavy

manufacturing, metals processing, weapons manufac-

turing, and demilitarization arenas. Crouse is a certified

safety professional (CSP) and a certified hazardous

materials manager (CHMM).

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Most maintenance teams and environment, health, and safety (EHS) officers con-

sistently look for ways to improve team safety. While it’s often hard to justify

changing existing practices and tools, when it comes to electrical safety, there’s a

clear exception. Noncontact tools have measurably improved electrical safety, but new op-

portunities afforded by the Industrial Internet of Things (IIoT) heighten their potential.

Wireless tools are an example. Because they place greater distance between technicians

and potential hazards, the changeover to wireless tools that began several years ago is

likely to accelerate as more tools become wireless. They usually don’t cost any more than

regular models do, and they are no more complex to use.

Electrical safety technology providers are also adding cloud connectivity to their tool cata-

logs. For instance, certain multimeters, clamp meters, power quality meters, and infrared

cameras are IIoT-enabled by a radio that connects to a smartphone via a smartphone app.

The test tool live-streams its readings to the app, from which the user can read the mea-

surement in safer surroundings as well as tag and save the measurement to a cloud data-

base for later reference by the entire maintenance team.

How the IIoT is Changing Electrical Safetyby Sheila Kennedy, Contributing Editor





Early adoption of IIoT-enabled tools re-

flects a company’s risk profile and how

heavily regulated it is, suggests reliability

specialist Paul Dufresne, CMRP, CRL. “The

nuclear and pharmaceutical industries tend

to be more advanced in the technologies

they employ, such as safety tools tied back

into the DCS through smart controllers and

things like that.”

Not every company is at that point. Du-

fresne said that to date he has used a

kaleidoscope of tools for electrical safety –

grounding systems, electrical motor testing,

partial discharge testing, and infrared test-

ing among them – but they all were stand-

alone. No IIoT-enabled tools have yet been

used by his team, and there was no live,

active tracking of electrical safety system

monitoring results.

Corporate security policies also influence

tool decisions. “As a rule, we don’t use any

outside Internet vehicles such as the cloud,”

says Russell Flagg, CBM program owner

at Duke Energy’s Smith Energy Complex

(www.duke-energy.com). “We are a regu-

lated utility that must comply with the

NERC/CIP network security requirements,

so that pretty much rules out that method

of data transfer and review.”

The Smith Energy Complex is instead

leveraging the IIoT by installing continu-

ous motor monitoring sensors on all of its

medium-voltage switchgear so the gear can

be monitored 24/7. This eliminates having

to open energized switchgear and attaching

clamps on meters. “The continuous motor

monitoring will be fed into our SmartGen

program and will be part of our M&D center

monitoring regimen,” says Flagg.

At The J.M. Smucker Company, ultrasound,

infrared, and motor circuit analysis are

among the most useful tools for monitor-

ing and maintaining electrical safety, says

Joe Anderson, CMRP, CRL, and a former

reliability leader at Smucker who joined the

Schwan Food Co. as senior reliability man-

ager earlier this year. Anderson predicts

that all such tools soon will be IIoT-enabled.

“This will be driven by customer demand

and to help them maintain a competitive

advantage,” he says.

Contact Sheila Kennedy, CMRP, at

[email protected].



AVO® Training Institute, a Megger® subsidiary,

celebrates over 50 years keeping people safe

from electrical hazards. From electrical mainte-

nance safety procedures to safe work practic-

es, engineering services including arc flash studies, AVO is the com-

plete one-stop electrical training resource. Courses are offered at our

locations nationwide or on-site at your facility.

https://www.plantservices.com/assets/Media/1605/avo-course-catalog.pdf 2016 Course Catalog

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