What constitutes a qualified electrical worker?
Let’s begin with a basic definition of the word qualified:
Referencing dictionary.com, “qualified” means several things. Here are two definitions:
a. having the qualities, accomplishments, etc.,that fit a person for some function, office, or the like
b. having the qualities, accomplishments, etc., required by law or custom for getting, having, or exercising a right, holding an office, or the like
The second definition fits this discussion. One is considered qualified when a certain accomplishment has been met, and this accomplishment is backed up with some sort of documentation. Standards like the NFPA 70 National Electrical Code (NEC), National Electric Safety Code (NESC), and NFPA 70E discuss a “qualified” electrical worker. OSHA also refers to the term “qualified” in many electrical standards, like 1910.331 and 1910.269.
Now let’s continue to a few of the industry definitions:
The NFPA 70E definition states this:
Qualified person. One who has demonstrated skills and knowledge related to the construction and operation of electrical equipment and installations and has received safety training to identify the hazards and reduce the associated risk.
In Subpart S, OSHA 1910.331(a) imparts:
The provisions of 1910.331 through 1910.335 cover electrical safety-related work practices for both qualified persons (those who have training in avoiding the electrical hazards of working on or near exposed energized parts) and unqualified persons (those with little or no such training) working on, near, or with the following installations:… (emphasis added)
OSHA 1926.32(m) contains this definition:
Qualified employee (qualified person): One knowledgeable in the construction and operation of the electric power generation, transmission, and distribution equipment involved, along with the associated hazards.
Note 1: An employee must have the training required by 1910.269 in order to be considered a qualified employee.
Note 2: Except as provided in 1910.260, 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.
Finally, this is what OSHA 1910.269(a)(2)(ii) has to say:
Each qualified employee shall also be trained and competent in:
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 exposed live parts,
3. The minimum approach distances specified in this section corresponding to the voltages to which the qualified employee will be exposed and the skills and techniques necessary to maintain those distances,
4. The proper use of the special precautionary techniques, personal protective equipment, insulating and shielding materials, and insulated tools for working on or near exposed energized parts of electric equipment, and
5. The recognition of electrical hazards to which the employee may be exposed and the skills and techniques necessary to control or avoid these hazards.
Note to paragraph (a)(2)(ii): For the purposes of this section, a person must have the training required by paragraph (a)(2)(ii) of this section to be considered a qualified person.
Who can qualify an electrical worker?
The qualification must come from the employer, who is the qualification body.
Basically, you must remember these 2 points:
- OSHA requires that workers in the electrical field be qualified.
- The employer must provide a method of qualification, including documentation.
If a state, county, or municipality employs someone who is required to be a Qualified Electrical Worker (QEW,) that governmental body would also have to provide a method of qualification and documentation.
Does holding a current electrical license qualify me?
Some employers believe that an electrical license meets the requirements of qualification. This is not true, however, from an OSHA standpoint. Theoretically, a licensed electrician, who may hold 2 or 20 state licenses, could start work tomorrow at your company. But that person would NOT be a QEW at your facility until your company puts the new-hire through a qualification process and deems this new-hire a QEW. Until then, you have a licensed, unqualified electrician. (Usually, your written Electrical Safety Program includes the qualification process.)
The same holds true if you hire an electrical engineer, instrument technician, etc. The company that the person works for must do the qualifying.
The Major Takeaways (Requirements of Employers)
- OSHA requires certain electrical tasks to be performed by qualified personnel.
- The employer creates a method (process) to qualify workers for electrical tasks, regardless of the individual’s licensure or prior experience. The qualification process must include demonstration of skills.
- The employer documents each step in a worker’s qualification.
- OSHA requires workers to be trained on the electrical hazards and the mitigation of those hazards.
- Employer provides employee training on the electrical hazards and mitigation of hazards.
For further reading, see the blog So Many Electrical Safety Terms – What Do They Mean? .
Have a question about electrical safety and standards? Ask us here OR on our forum!
This article originally posted on our blog August 2018.
Excellent topic, Ken.
I can’t tell you how many people I have come across that hold an electrical license of some sort that think they are qualified. You said it right that they are a licensed unqualified person.
Thanks Bill! It is pretty scary out there. I have run across some people that truly have no business being in the electrical trade. That sounds mean-spirited (not my intention), but unfortunately is true.
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Great article Ken. This would directly apply to those companies that continue to have employees seek their own “On Line” training thinking that it will satisfy this requirement. How can a company deem you “qualified” if they do not train you on the exposures that you may be exposed to within their organization and their specific Electrical Safety Programs? Unfortunately there are still a lot of companies that are not willing to provide this training and try to save costs by putting the requirement on the employee with some as a pre-employment requirement.
You are right Terry. Unfortunately the responsibility of training is totally legally on the employer from the OSHA perspective. I’d never assume that a degree or a card means you are qualified. Many of the incidents I have investigated have been of people who were qualified for one job but NOT for the job they got hurt doing.
Hugh
Can a non-supervisory personnel (like a peer, not management) be the one who sign off as the qualifier of the employee to be a QEW? Or in other words can the non-qualified demonstrate to a peer who is qualified? Will that suffice or must the “employer” be a supervisor or management?
This is up to the employer. THEY are responsible. If they delegate this to a more qualified assessor who is not a manager, the company/employer is still responsible from OSHA’s perspective. That person could be the AHJ or they could just be a qualified assessor designated by the company.