Setting Up a Qualified Electrical Worker Program
by American Trainco
Introduction
As compliance requirements increase, so does the need for well-defined safety processes and
programs. A critical component of an overall electrical safety program is having a clearly
defined qualified electrical worker program. Regardless of the size or scope of your company, if
you employ electrical workers, you will benefit from having a clearly defined qualified electrical
worker program.
Defining “Qualified”
Both OSHA and the NFPA discuss qualified workers. OSHA 1910.399 defines a qualified
person as “One who has received training in and has demonstrated skills and knowledge in the
construction and operation of electric equipment and installations and the hazards involved.” The
NFPA 70E® 2012 “Standard for Electrical Safety in the Workplace®” definition is nearly
identical. The terms “qualified worker” and “qualified electrical worker” are synonymous with
“qualified person”. Organizations that have people working on or around electrically energized
equipment must comply with OSHA and NFPA 70E® safety standards to keep workers safe and
reduce employer liability, and that entails creating and implementing a qualified worker
program.
Although definitions of “qualified worker” and “qualified person” exist, there is no universal
certification program or standard. It is the responsibility of the employer to determine what
constitutes “qualified.” Consider that each employer may have different equipment in different
configurations, and it becomes clear that no single certification could encompass all possible
scenarios. Further, an employee might be qualified for one task or piece of equipment, but not
another. Typically, an employee would be qualified for multiple tasks, not just one function.
Essential Program Components
Documentation
While it is up to the employer to determine what a “qualified” worker is, documentation is a
critical part of any qualified worker program. Documentation is also specified as a requirement
in NFPA 70E® Article 110.2. Having records of training demonstrates that you, as an employer,
are committed to ensuring that employees are qualified to perform a given task or operate
specific equipment. While you can conduct internal training, it may also be advantageous to
select a third-party trainer in order to maintain objectivity. Training companies should provide
accurate and adequate records, and should have a system for maintaining those records over
time.
You can place a paper copy of any certificates or licenses in an employee file, and this may
certainly suffice if your needs are minimal or your organization is small. However, larger
organizations or those with employees performing multiple and diverse tasks may also benefit
from creating a database to track employee training and to record certifications and licensures
from other agencies (for example, state electrical licenses). With a database, reports can be
produced more efficiently, impending license renewals or retraining can easily be tracked, and
information can easily be shared across geographic locations. Data, including images of
certificates and licenses, can also be backed up, providing additional assurance that your records
are accessible at all times.
Developing a Training Plan
While the required training will vary by employee and job function, it will behoove employers to
develop a training plan for the tasks required by that job function. Again, the specific training
depends on the circumstances, but qualified electrical worker plans will benefit from including,
at minimum, training on general electrical safety, electrical code, and electrical troubleshooting.
Training should also be provided for specific machines or electrical conditions, such as battery
rooms or hazardous locations.
A training plan will provide for ongoing education. Refreshers and updates will depend, in part,
on the equipment and employee in question, but knowing that the NFPA 70E® and the National
Electrical Code® are updated every three years, you should plan on training in these areas at least
every three years. Since the NFPA 70E® and National Electrical Code® are not updated in the
same year, you may wish to consider an annual training, perhaps with an NFPA 70E® update one
year, a subject matter or equipment training another year, and a National Electrical Code update
the next year. Of course, you do not need to limit training to an annual event; you can certainly
provide training more often.
Demonstrating Knowledge and Skills
The definition of “qualified” includes training, but it doesn’t stop there. A qualified person must
also have “demonstrated skills and knowledge” in their assigned tasks or responsibilities. One of
the best ways to ensure that employees have that knowledge is testing. Written tests allow you to
gauge how well an employee has mastered relevant knowledge, and provide additional
documentation that your workers are qualified. Again, it is up to the employer to decide what
constitutes qualified, but many employers use the guideline that the employee needs to have a
score of 70% or higher on a test to have sufficiently demonstrated knowledge.
You can also incorporate hands-on demonstrations of skills, but these should still be documented
in some way, perhaps through a checklist of skills required for that task. It goes without saying
that such a demonstration should be verified by someone other than the employee—usually a
supervisor, or someone who has sufficient knowledge to assess that the employee can perform
the required tasks safely and correctly.
Both written tests and hands-on demonstrations can be developed internally, but if your
workforce is smaller, or if a significant amount of work at your facility is highly specialized, you
may prefer to use a company that can develop and/or deliver tests or demonstrations for you, and
provide you with an assessment of employee knowledge and skills. Choosing this route has the
added benefit of greater objectivity, since the external company is a third party. Some companies
will provide highly customized testing, and others can provide more generalized subject matter
testing. Depending on your needs, either or both may be an important part of your qualified
worker plan.
Whatever course you choose, if the results indicate a need for training beyond code updates and
refreshers, consider how much and what type of additional training would benefit employees. If,
for example, there is a company-wide lack of electrical safety awareness and practices, it would
benefit all employees to have additional training in this area. On the other hand, if a few
employees need reinforcement in specific areas, it may be a good idea to find a training just for
those employees (in addition to regular code updates and refreshers).
Types of Training
Training is available through many venues, including online courses and DVDs. Remote and
self-paced options such as this are wonderful ways to contribute to employee development, but
they may not meet all requirements. In discussing qualified persons and qualified workers,
OSHA 1910.332(c) and NFPA 70E® 110.2 specifically state that the type of training required
“shall be in the classroom or on-the-job” training. Therefore, you should plan on providing some
form of live training.
On-the-job training will necessarily take place at your facility, but classroom training can take
place either at your facility or at another location. Consider what is most convenient and efficient
for you. For example, most employers find it difficult to have their entire crew out at the same
time, or a production facility may have several shifts to accommodate. In such cases, if you can
find a trainer that will come to you, you may be better able to train all of your employees in one
or a few sessions close together, rather than numerous individual sessions scattered throughout
the year. Group trainings are also easier to track.
Conclusion
Developing a solid qualified worker program will not happen overnight. It will take time to
determine what works best for your company and your employees. And as codes and technology
change, so will your training needs. A good qualified worker and training program is not static,
but it does need a solid foundation of regular, relevant training and documentation of that
training. Once those processes are established, your qualified worker program is poised to thrive.