Electrical Utility Q&A: Emergency Response Requirements

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Electrical Utility Q&A: Emergency Response Requirements

Emergency Response at a Utility: When CPR/First Aid is Required

We hear often about the need for electrical personnel to have at least a basic level of CPR and First Aid training. In addition, proper use of an Automated External Defibrillator is sometimes the only proven method of saving the life of an electrical shock victim. This article explains the standard requirement from NFPA 70E, as well as the applicable OSHA regulations in electrical applications.

Training For Those Responsible for Emergency Response

NFPA 70E covers the requirements for training for those responsible for emergency response to electrical incidents. 110.2(C) (1), 2018 edition, requires training in contact release for two groups of people:

(1) Those exposed to shock hazards, and

(2) Those responsible for the safe release of victims from contact with energized conductors or circuit parts.

Annual training is required for locations complying with NFPA 70E requirements.

Training Over First Aid, Emergency Procedures, and Resuscitation

The second requirement in this vein is 110.2 (C)(2), which stipulates first aid, emergency response, and resuscitation training requirements. As we will see in a few paragraphs, OSHA’s wording for electrical response training differs from NFPA’s wording. NFPA 70E states that “Employees responsible for responding to medical emergencies” must be trained in first aid, emergency procedures, cardiopulmonary resuscitation (CPR), and automated external defibrillator (AED) training if the site has AEDs available. Keep in mind the words in quotation marks, that this training applies to those responsible for such response activities.

Also, notice that 70E makes no mention of requiring electrical incident response training for qualified electrical personnel.

Shock release method training, however, is required for electrically-qualified personnel, as they are certainly “exposed to shock hazards” on a routine basis. It’s part of the job as an electrician, electrical technician, electrical engineer, or those performing similar tasks.

Specific Requirements for Utility Electrical Workers

OSHA has specific requirements for electrical incident response. We find specific requirements for employees working in the electrical utility environment in 1910.269 Electrical Power Generation, Transmission, and Distribution.

1910.269(b) is entitled, “Medical Services and First Aid.”  Section (b), (b)(1), (b)(1)(i)-(b)(1)(ii) states,

The employer shall provide medical services and first aid as required in §1910.151. In addition to the requirements of §1910.151, the following requirements also apply:

First-aid training. When employees are performing work on, or associated with, exposed lines or equipment energized at 50 volts or more, persons with first-aid training shall be available as follows:

For field work involving two or more employees at a work location, at least two trained persons shall be available. However, for line-clearance tree trimming performed by line-clearance tree trimmers who are not qualified employees, only one trained person need be available if all new employees are trained in first aid within 3 months of their hiring dates. For fixed work locations such as substations, the number of trained persons available shall be sufficient to ensure that each employee exposed to electric shock can be reached within 4 minutes by a trained person. However, where the existing number of employees is insufficient to meet this requirement (at a remote substation, for example), each employee at the work location shall be a trained employee.”

Breaking It Down

As we break this down, we simplify the rules by saying this:

(1) At a FIELD work location, two people must be trained in first aid and proper medical services.

(2) At a FIXED work location, one of the following is required:

(a) Have a trained response team that can guarantee a 4-minute or less response time to an electrical incident.

(b) Train each employee at the work location.

In 1910.151, the specific MINIMUM requirements are very vague. This standard simply says that personnel must be trained in rendering first aid, and that first aid supplies must be available. There is no mention of CPR or AED training, nor is there mention of appropriate electrical-specific response to electrical incidents.

However, in true OSHA fashion, we must keep digging. 1910.269(x) DEFINES first aid as the following:

“Training in the initial care, including cardiopulmonary resuscitation (which includes chest compressions, rescue breathing, and, as appropriate, other heart and lung resuscitation techniques), performed by a person who is not a medical practitioner, of a sick or injured person until definitive medical treatment can be administered.”

So, we MUST provide training, including CPR and other techniques. This certainly should include AED training if these units are available on the worksite.

One last note: Remember that these rules not only apply to electrical utilities, but to other sites that use similar equipment (e.g. industrial substations, backup generation, etc.) Non-compliance can always be cited under the OSHA General Duty Clause.

Here is some good reading from an OSHA interpretation letter regarding the same subject matter.

Q: Does the OSHA [1910.269, Electric Power Generation, Transmission, and Distribution Standard] require, at all shifts, that an employee in a generating station be reached by another employee or a second person, trained in cardio-pulmonary resuscitation (CPR) and first aid, within 4 minutes?

A: No, not in all circumstances. OSHA Standard 29 CFR 1910.269(b)(1)(ii) requires that for fixed work locations such as generating stations, the number of trained persons available shall be sufficient to ensure that each employee exposed to electric shock can be reached within 4 minutes by a trained person. 

However, where the existing number of employees is insufficient to meet this requirement (at a remote substation, for example), all employees at the work location shall be trained. In the rulemaking, OSHA clarified that this provision was required only for employees exposed to the hazards of electrical shock when they perform work on or associated with exposed lines or equipment energized at 50 volts or more. This does not pertain to employees working near insulated electrical equipment, as the exposure to electrical shock hazard is minimal.

Is e-Hazard Training For You?

e-Hazard provides training to personnel on electrical shock and arc flash immediate medical response, available upon request.

Also, our Low Voltage Qualified class contains some medical response training.

Call our office at (502) 716-7073

Have a question about electrical safety and standards?   

Ken Sellars

Ken Sellars is an instructor of electrical safety, NEC, Grounding/Bonding and Arc Flash Safety courses nationwide. Read more about Ken.

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