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ElectricalSafety Training
Updated Standard Changes Definition of ‘Qualified Person’
BY
JIM
WHITE
Recent changes to OSHA’s
electrical standard, Subpart S 29CFR1910, include a revised
definition of a qualified worker.
The old definition was, “Qualified person – One
familiar with the construction and operation of the equipment and
the hazards involved.”
The new definition states, “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.”
Is this just a minor wording change? No! This
definition has three parts: 1) training in the skill required; 2)
demonstrating those skills; and 3) knowledge of the construction and
operation of electric equipment and installations and the hazards
involved.
Many companies are taking the approach
that CBT (computer-based training)or video-based training is
adequate for training their qualified electrical workers.
Negative! In OSHA’s view,
“Self-paced, interactive computer-based training can serve as a
valuable training tool in the context of an overall training
program. However, use of computer-based training by itself would not
be sufficient to meet the intent of OSHA’s training requirements…”
So, what is required to become a
qualified electrical worker? Experience is certainly one part. If
you’re a journeyman or master electrician, you are experienced. You
have the skills and knowledge required to perform the technical
aspects of your job.
What you may be (and probably
are) lacking is the OSHA-mandated safety training. Qualified
electrical worker safety training needs to include such items as
electrical hazard awareness, the applicable OSHA regulations
(29CFR1910.331 through .335; .137, .147, .133 and .132 to name a
few), use of PPE and equipment, conducting a Hazard/Risk Analysis
and familiarity with NFPA 70E.
Let’s take a look at each of
these:
• Electrical hazard awareness: if
you don’t recognize a hazard, you can’t avoid the hazard. Several
years ago I was in Petersburg, VA doing a training class for a
customer and right on the front page of the local newspaper was an
article about a painter. He constructed a scaffold three stories
high, climbed up and proceeded to paint the commercial building he
was working on. He made contact with the drip loop coming into
the building with his aluminum extension pole and was electrocuted.
Knowing several painters,
carpenters, bricklayers and the like, I knew he would never work on
electrical circuits, but he was not aware of the hazard. He saw the
conductors were covered, but didn’t take into account that there may
still be a hazard.
• OSHA regulations: Both the
worker and supervisor must be trained in the OSHA regulations and
understand them. I often am questioned about who requires training
and my answer is always the same, “Pretty much everyone. What
changes is the level of training required.”
Qualified electrical workers, of
course, but shift supervisors also need the same training so they
understand the problems and issues faced by working on or near
exposed, energized electrical conductors and parts.
Unqualified workers also need
some level of safety training. Painters, janitors, helpers,
apprentices and any other worker who may come in contact with
equipment that could be exposed and energized will require
electrical safety training. Mostly, this training consists of being
made aware of the hazards and how to avoid them. Don’t put your
fingers where they don’t belong, for example.
• Use of PPE and equipment: Use
of does not mean just how to pick something up and go after it. This
requirement also means training on:
How to select the proper tools, PPE and insulating and shielding
materials required.
• Are the materials and tools
being used appropriate for the voltage, conditions of use, and do
they meet ASTM and NFPA 70E standards? Is it the right tool for the
job? For example, channel locks are not fuse pullers. I know, I
know, they just look so right for the job.
How to inspect these items and
ensure they are safe to use.
• Is there any damage to arc
flash PPE that could cause them to be unsafe, such as cuts, rips or
holes in the material or grease spots? Are there gaps in the seals
that could allow heat to enter when wearing arc flash PPE? Has it
been exposed to an arc flash previously? Reusing arc-flash PPE is
not the way to save money.
Are they properly marked?
• On arc flash protective
clothing and equipment, does the arc rating on the outside match the
arc rating stated on the label? If the ratings don’t match, don’t
use it; send it back. Does the label state that it meets ASTM F1506
and the NFPA 70E? In the 2009 edition of the NFPA 70E, we added a
requirement that arc flash clothing and equipment be “arc rated.”
It must be designed and rated
specifically for electrical workers, not steel workers, not firemen.
The heat from an arc flash is very intense, but also of a very short
duration. Our needs are different than of these other workers.
How to safely use these items.
• Are the PPE and equipment being
worn properly? Is it adequate for the task and hazard? Do you know
how to determine that? Does it cover all ignitable clothing? Is the
clothing the right size? If you look like sausage boy in your arc
flash coveralls, the heat from an arc flash could be transferred
right through the clothing and you’ll receive a severe burn.
• Conducting a Hazard/Risk
Analysis: Let’s see, if something goes wrong while I’m working on
this motor control center bucket, I could be electrocuted or burned
to a crisp. I think that maybe I would want to know how to evaluate
the hazard and the risk involved in the task I’m about to do.
I’m in the minority. Most
electrical workers I run across think it’s too much effort; that
someone else should do it for them. Here’s a news flash: The other
person won’t be injured or killed. Don’t let someone else be
responsible for your safety.
They’re your biscuits; you keep
them out of the fire.
Evaluating the hazard is fairly
straightforward. The nominal voltage (system design voltage)
determines the glove class. If the system has had an arc flash study
performed on it, it will have the arc flash protection boundary and
incident energy at working distance listed on it. If not, I can
refer to Tables 130.7 in the NFPA 70E and choose my PPE and
equipment. Be certain to use the notes at the end of the tables,
however, or the PPE you choose may be inadequate for the hazard.
Evaluating the risk is another
story. The incident energy listed on the arc flash label or the
arc-rated PPE and clothing specified in the 70E are both based on
these three things:
• Equipment
that is properly designed and engineered;
• Equipment that is properly installed in accordance
with all applicable codes and standards;
• Equipment that is properly maintained. If any one
of these conditions is not met, the actual incident energy that the
worker could face is unknown. Maintenance is
where many
systems fall short of the mark.
It’s too easy to put off, either due to cost cutting
or lack of problems (caused by a good PM program, by the way).
Incident energy is proportional to time. Double the time of exposure
and the incident energy received by a worker doubles. Improperly
maintained circuit breakers are one reason time of exposure could
increase and, since we are talking about cycles per second (0.0167
second/cycle), it doesn’t take a big delay to cause the arc rating
of your PPE to be way under what it needs to be.
More likely than not, once a Hazard/Risk Evaluation
is performed you’ll find that more arc flash protection is needed,
not less. Do you meet the definition of a qualified electrical
worker? Do you have the skills and knowledge of the equipment and
installation? Do you have the required electrical safety training to
meet OSHA’s requirements? If not, save yourself a lot of problems
and get with the program.
FSM
Jim White
is training director for Shermco Industries, an electrical services
provider in Dallas, TX. For more information, go to www.shermco.com.
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