Understanding where your workers fit in when it comes to electrical safety classification and compliance
Creating an electrical safety program can be a complicated endeavor, not to mention a confusing one when you try to address all of the essential elements, such as fire-resistant (FR) clothing, insulated tools, training, and hazard analysis — just to name a few. Although focusing on one component at a time seems to be the best approach, deciding which area to tackle first is often the hardest part. Fortunately, the best first step is the most important and least expensive. This involves performing a self audit of your employees to classify “where they fit in.” Simply put, you must determine what level of exposure to electrical hazards each employee has as well as what “qualifications” they possess with respect to that level of exposure.
To help this process along, let's start with the definition of a “qualified person.” Article 100 of NFPA 70E (2009 edition) defines a qualified person as, “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.” Because this definition is very broad, you need to look at all of your different groups of employees and what hazards they are exposed to in order to not only classify them properly, but also to adequately prepare them.
All companies — no matter what their business — could have the same three groups of qualified persons: qualified (authorized), qualified (task-specific), and unqualified. It's vital to understand what qualities and qualifications are synonymous with each of these three groups before establishing your electrical safety program.
Qualified (authorized) group
This group represents your top-of-the-line, most technically skilled employees. In many cases, this includes the subcontractors you hired to do the more involved electrical work. These individuals have the highest exposure level to energized electrical equipment and need comprehensive training curriculum and skill sets (Photo 1).
NPFA 70E lays out a detailed list of requirements for those individuals who are at the highest level of exposure (click here to see Chart). Under 110.6(D), entitled Employee Training, parts (a) and (b) offer the following guidance as related to a qualified person:
“(1) A qualified person shall be trained and knowledgeable of the construction and operation of equipment or a specific work method and be trained to recognize and avoid the electrical hazards that might be present with respect to that equipment or work method.
Such persons shall also be familiar with the proper use of the special precautionary techniques, personal protective equipment, including arc flash, insulating and shielding materials, and insulated tools and test equipment. A person can be considered qualified with respect to certain equipment and methods but still be unqualified for others.
Such persons permitted to work within the Limited Approach Boundary of exposed energized electrical conductors and circuit parts operating at 50V or more shall, at a minimum, be additionally trained in all of the following:
The skills and techniques necessary to distinguish exposed energized electrical conductors and circuit parts from other parts of electrical equipment.
The skills and techniques necessary to determine the nominal voltage of exposed energized electrical conductors and circuit parts.
The approach distances specified in Table 130.2(C) and the corresponding voltages to which the qualified person will be exposed.
The decision-making process necessary to determine the degree and extent of the hazard and the personal protective equipment/job planning necessary to perform the task safely.”
We can simplify this reference with a quick “litmus test” as to the exposure of someone categorized in this group. Individuals who fit this category are expected to perform the following tasks:
Use a multimeter to troubleshoot a problem in an electrical device.
Use an approved voltage reading device to do a zero energy check in an effort to create an electrically safe work condition for themselves or for someone else to perform a needed repair or related work.
Any other task that would cause the individual to be exposed to energized or presumed energized parts of an electrical device.
Although this is not a complete list of tasks for this level, it should be fairly easy for you to whittle down the list of your employees who do not qualify for inclusion in this group. As you go through these steps, also be advised that you may quickly realize you have maintenance staff or mechanics doing work they really shouldn't be doing.
Qualified (task-specific) group
Those employees who do not meet the requirements above should be re-evaluated to see if they belong in the less involved “task-specific” group. Just as the group name suggests, these individuals can be broken down into quite a large number of subgroups, because now you're dealing with specific needs in training, procedures, and protection methods. Membership in this group does not include exposure to energized electrical parts, which narrows it down to those individuals interacting with electrical equipment that is energized or assumed energized, specifically operating a circuit breaker or the handle on a disconnect switch.
This group's primary hazards are arc flash and arc blast. A welder, for example, might fit into this category, because he would need to turn off the power to the outlet that feeds his welding equipment. Whether it is a breaker or disconnect switch, this person would still require training on how to protect himself from an arc flash that could occur when interacting with a disconnect device during the opening/closing of the switch handle as well as what personal protective equipment (PPE) and other protection (boundaries, tools, etc.) are needed for the task.
An employee working on an assembly or process line — who might need to stop the machine for component setup or changes or minor repairs — might also need to perform a similar task. Qualified task-specific employees might perform a lockout tag procedure to ensure movable parts are isolated while the needed repairs are made. Again, because the primary hazard in this situation is arc flash and arc blast, this person would still need to be trained in how to determine what level of PPE and other related safe work practices are appropriate for specific tasks.
The last group consists of all remaining in-house as well as outsourced employees — from custodians and painters to secretaries and engineers (Photo 2), all of which are not listed in the first two groups. In other words, these people are not skilled, trained, or equipped to do any of the tasks discussed above (e.g., operate a switch, breaker or be exposed to energized or presumed energized parts).
Setting a plan of action
Once you have classified all of your employees and determined who is interacting with what type of electrical equipment, determine if the scope of their job really requires them to operate a disconnect switch or “flip” a breaker. If you really can't see a good reason for their involvement with this type of device, then don't let them interact with it — it's that simple. This strategy will allow you to ignore all of the detailed and required training that comes into play with qualified workers. If an individual must truly interact with an electrical device as noted above, then you have two options:
Provide that individual with the proper training, PPE, and other necessary support to protect them when operating the device, or
If it is not a frequently performed task, confirm to them their status as a nonqualified person and instruct them to get a qualified individual to operate the device, making it electrically safe before they proceed with the task(s) at hand.
Determining how often the device needs to be opened (i.e., daily, weekly, monthly, etc.) will help determine if it's more cost effective to get someone more qualified involved or to engage in training and secure protective equipment for a larger group of individuals.
Completing a self audit of your employees and determining what group they fit into allows you to more accurately and efficiently manage your safety program. Although your ultimate goal is to provide a safe work environment for all employees, you should also strive to not waste extra money on excessive training and PPE for employees who don't really need it — or shouldn't have electrical exposure in the first place.
Abbott is president of Stark Safety Consultants, Canton, Ohio. He can be reached at firstname.lastname@example.org.