Utilizing Only Qualified Persons for Electrical Work can Reduce Risk Presented by: Dennis K. Neitzel, CPE Director Emeritus AVO Training Institute, Inc. Introduction • Define and identify a Qualified Person • Identify training requirements – Skills and knowledge • Misunderstanding of what constitutes: – A Qualified Person – Required training • Maintenance by a Qualified Person is vital to: – Reliability and safety (reduce risk) Introduction • OSHA and NFPA 70E – Require employers to protect employees – Strongly emphasizes Qualified Persons Only • Energized and deenergized work – Understanding of potential hazards • Electric shock • Electric arc flash • Electric arc blast Introduction • Focus on overview of requirements for: – Qualified Person – Needs Assessment – Job/Task Analysis – Electrical Hazard Analysis – Personal Protective Equipment (PPE) – Safe Work Practices – Programs and Procedures – Required Training – Qualified Person Qualified Person Requirements • Misconception throughout industry – What constitutes a Qualified Person: • Licensed Journeyman Electrician? • Licensed Master Electrician? – Typical license requirements: • Required number of years under a licensed electrician • Pass a National Electrical Code (NEC) exam – Experience may be residential – Not qualified for petrochemical facility Qualified Person Requirements • Qualified employees requirements must be established, before conducting: – Needs Assessment – Job/Task Analysis • OSHA and NFPA – Establishes training and qualifying requirements Qualified Person Requirements • NEC definition of Qualified Person – “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.” Qualified Person Requirements • OSHA definition of Qualified Person: – “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.” Qualified Person Requirements • Note 1 to OSHA definition: – “Whether an employee is considered to be a ‘‘qualified person’’ will depend upon various circumstances in the workplace. For example, it is possible and, in fact, likely for an individual to be considered ‘‘qualified’’ with regard to certain equipment in the workplace, but ‘‘unqualified’’ as to other equipment.” Qualified Person Requirements • Note 2 to OSHA definition: – “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 direct supervision of a qualified person is considered to be a qualified person for the performance of those duties.” Qualified Person Requirements • OSHA 1910.332 requires: – Qualified Person to be trained in “the safetyrelated work practices that are required by 1910.331 through 1910.335 that pertain to their respective job assignments.” – Qualified Person shall, at a minimum, be trained in: • Skills and techniques to distinguish exposed live parts • Skills and techniques to determine nominal voltage • Clearance distances to exposed voltages Qualified Person Requirements 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 assemblers.(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 operating at 50 volts or more to ground for a hazard to exist. Qualified Person Requirements • Must be trained in the proper use of: – Special precautionary techniques – Insulating and shielding materials – Insulated tools and test equipment – Job planning Qualified Person Requirements • Additional training or retraining if: – Inspection indicates non-compliance – New technology – New types of equipment – Changes in procedures – Use work practices that are not normally used Qualified Person Requirements • Task performed less often that once per year – Retraining is required • Training must establish employee proficiency • Employee required to demonstrate proficiency Qualified Person Requirements • Demonstrate proficiency – Classroom with exam – On-the-job demonstration • Hands-on training Figure 1 Hands-On Low-Voltage Circuit Breaker Training Qualified Person Requirements • Training shall be: – Classroom – On–the–job – Or a combination of the two • Retraining is required: – Not to exceed 3 years • All training shall be documented Needs Assessment • Must be performed before training can be accomplished • Involves relevant company personnel who: – Are aware of job requirements – Are aware of codes, standards, and regulations • Provides insight into past and present performance problems • Other factors that may affect performance Job/Task Analysis • Review needs assessment information • Develop initial job description: – Job title – Qualification requirements for the job – General description of job requirements – Description of job position within organization – List of tools and equipment used in the job – List of resource documents and references – Inventory of tasks Job/Task Analysis • Task inventory is most difficult part of the job description – List of tasks that make up the job – Task is defined as a unit of work that is: • • • • Observable Measurable Definite beginning and end Of relatively short duration – Task are made up of elements or steps Electrical Hazard Analysis • The electrical hazard analysis determines: – Hazard mitigation techniques – Risk management responsibilities – Personal protective equipment (PPE) – Training program development – Requirements for an Electrical Safety Program Electrical Hazard Analysis • Analysis identifies the hazards of electricity: – Electric shock – Electric arc flash – Electric arc blast Electrical Hazard Analysis • Hazard assessment from OSHA 1910.132(d) – “The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE).” • NFPA 70E, 110.3(B)(1) provides requirements: – Shock Hazard Analysis – Arc Flash Hazard Analysis Electrical Hazard Analysis • OSHA 1910.132(d)(2) requires: – Employer to certify assessment was performed – Date of the hazard assessment – Workplace that was evaluated (area or location) • OSHA may require disclosure of documentation • Assessment identifies requirements for the Energized Electrical Work Permit Personal Protective Equipment • Perform the hazard assessment to determine necessary PPE • Training is required on hazards and PPE – When PPE is necessary – What PPE is necessary – How to don, doff, adjust, and wear PPE – Limitations of the PPE – Proper care, maintenance, useful life, and disposal Personal Protective Equipment • NFPA 70E, 130.4 provides requirements for: – Shock Hazard Analysis • Identifies voltage • Establishes shock protection boundaries • Determines proper rubber insulating PPE • NFPA 70E, 130.5 provides requirements for: – Arc Flash Hazard Analysis • Determine the incident energy • Establishes the Arc Flash Boundary • Identifies required arc-rated clothing and PPE Personal Protective Equipment Figure 2 Arc-Rated PPE Personal Protective Equipment • OSHA 1910.335(a)(2) requires: – “When working near exposed energized conductors or circuit parts, each employee shall use insulated tools or handling equipment if the tools or handling equipment might make contact with such conductors or parts.” Personal Protective Equipment Figure 3 Typical Insulated Hand Tools Personal Protective Equipment • Common misconception – Rubber insulating gloves not required when using insulated tools – this is FALSE • Rubber insulating gloves are shock protection • Insulated tools are used to prevent: – Going phase-to-ground – Going phase-to-phase • Rubber insulating gloves and insulated tools must be used together Personal Protective Equipment • OSHA 1910.335(a)(2)(ii) provides summary: – “Protective shields, protective barriers, or insulating materials shall be used to protect each employee from shock, burns, or other electrically related injuries while that employee is working near exposed energized parts which might be accidentally contacted or where dangerous electric heating or arcing might occur.” Electrical Safety Program • OSHA 1910.333(a) states: – Safety-related work practices shall be employed: • To prevent electric shock or other injuries – From either direct or indirect electrical contacts – When work is performed near or on equipment or circuits which are or may be energized – The safety-related work practices shall be consistent with the nature and extent of the associated electrical hazards Electrical Safety Program • OSHA 1910.333(a) also states: – If exposed live parts are not deenergized: • Safety-related work practices shall be used • Work practices shall protect workers • Work practices shall be suitable for the conditions and voltage – If deenergized but not locked or tagged: • Must treat as energized Electrical Safety Program • OSHA 1910.333(c) applies to energized work – Where employees are exposed to electrical hazards – Only Qualified Persons may work on energized – Persons shall be capable of working safely • OSHA Instruction STD 1-16.7 – Requires a “written procedures and strictly enforced” Electrical Safety Program • NFPA 70E, 110.3 outlines the requirements: – Awareness and Self-Discipline – Electrical Safety Program Principles – Electrical Safety Program Controls – Electrical Safety Program Procedures – Hazard Identification and Risk Assessment Procedure – Electrical Safety Auditing Conclusion • Extensive training is required for employees considered to be Qualified Persons • Training determined by: – Needs Assessment – Job/Task Analysis – Hazard Analysis Conclusion • OSHA and NFPA 70E require employers to: – Document employees have demonstrated proficiency – Certify employees are qualified – Maintain certification for duration of employee’s employment • Utilizing only Qualified Persons to perform electrical work can greatly reduce the risk to the employee, as well as increasing reliability of the electrical system and equipment. 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