We see the phrase “qualified person” in the OSHA regulations and in various standards, such as the NFPA 70, National Electrical Code and NFPA 70E, Standard for Electrical Safety in the Workplace. NFPA 70E defines a qualified person as: “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 and avoid the hazards involved.” [Art. 100]. But what does this mean? And does the meaning matter?
Sometimes, a person performing a task on equipment will make a mistake that proper training for that task on that equipment would have prevented. Sometimes, that mistake results in a poorly done job. Sometimes, that mistake results in an injury or fatality. Sometimes, several people are injured or killed.
It’s not always the senior or most knowledgeable person who is “qualified.” A highly skilled crew assigned to a task might not have a single “qualified person” to do that task.
Suppose the task is to rebuild a circuit breaker. Jim has 20 years of experience as an electrician. Does that make him qualified to rebuild that breaker? Sam has been trained on rebuilding another manufacturer’s breakers, so is he qualified?
In either case, the answer is no. Jim’s 20 years of experience isn’t a qualification for this task. As for Sam, there is enough difference between different models of breakers (even those of the same manufacturer) that qualification in rebuilding one does not automatically translate to qualification in rebuilding the other.
An example of being qualified
Suppose the task is to replace and align a 100-hp motor that is still operable but (per ultrasonic testing) has damaged bearings. Bill works for an electrical services firm. He’s replaced dozens of motors this size. Now he arrives at a manufacturing plant to replace and align a 100-hp motor. Is he qualified? It depends.
In addition to his verified competence at changing and aligning motors, several requirements must be satisfied before Bill is qualified to replace that motor. For example, he must:
• Be authorized by his company (a given, here) and by the client company. He must also be authorized by the person directly responsible for the equipment the motor is part of. That person would probably be the production manager over that equipment.
• Understand the process. What happens if he shuts off the motor? Will that create a dangerous condition or shut down a critical process? How long can the equipment be out of service to permit changing out that motor?
• Know the plant’s lockout/tagout procedure and have the appropriate devices to implement that.
• Obtain and understand the electrical drawings.
• Identify and lock out all energy sources to that equipment, as needed to prevent inadvertent operation or other safety problems.
• Operate the lift truck or other equipment for moving the motors, or work with an equipment operator from the plant.
That’s quite a list, isn’t it? And that’s before we even get to the NFPA 70E job briefing requirements — or Bill’s helper.
How does Bill know he is qualified? The following may answer that:
• His boss gives him the work order. He speaks with the client’s representative (e.g, plant engineer) before starting work. He confirms his plan with the production supervisor in the area.
• He has reviewed the system operation with the plant engineer and an operator.
• The plant safety manager provided a short training session on the plant’s lockout/tagout system.
• He’s got the electrical drawings and has “walked through them.”
• One of the plant maintenance people locked out a hydraulic system and other energy sources, then walked Bill through the lockout so he could add his own locks and tags to those.
• Sandy is his assigned lift truck driver, and they’ve walked through her part together. She obtained the correct lifting equipment to work with the motor lifting eyes.
However, Bill won’t know that he’s qualified until the client agrees that he’s qualified. So how does the client determine whether Bill is qualified? That is mostly a matter of communication. Bill needs to review with the plant engineer (his primary contact at that plant) how he’s met all the criteria just mentioned. If the client doesn’t think Bill is qualified, then there are some things to clarify.
The client’s safety director might not sign off until Bill provides a hands-on demonstration of using the appropriate PPE as part of proving his safety qualifications. He also may need to prove, for example, that he:
• Understands the hazards and precautions involved in this specific job.
• Knows the emergency procedures related to this job. For example, he’ll have to point out the eyewash station plus explain what to do in case of fire.
• Knows how to ensure the relevant energy sources are locked out and tagged out.
• Has the correct personal protective equipment (PPE) for the job.
Four examples of not being qualified
As you can see, a person must meet many criteria to be truly qualified. It’s important to understand that qualification in one area does not make you qualified in another. Similar and equal are not the same thing. The examples below help illustrate this point.
An electrician is certified to operate the plant’s scissor lifts, and he’s always operated them inside the plant. Now he’s assigned a job to upgrade outdoor pole lighting from HID to LED. He is careful to apply his scissor lift safety training. But the scissor lift doesn’t have a bucket on an articulating arm.
An electronics technician assists an electrician by programming a control module in the shop and then installing it in the field to replace a bad one. He notices the output terminals are disconnected on the field side, so, to be helpful, he reconnects those. But he didn’t know what that module was controlling.
An electrician with commercial office building experience takes a job at a manufacturing plant. His new boss tells him to de-energize several breakers for maintenance. At 2,000A and 480V, the danger factor for opening a breaker under load is considerably more than what this electrician encountered with the 120V lighting and receptacle circuits he was familiar with.
A maintenance crew is replacing a dry-type transformer that was struck by a lift truck. That’s the third replacement in the past year. So, the plant engineer asks if they can get a coring drill and install some bollards. They say sure, they can figure it out. They lost track of how many holes they’ve drilled into cabinets and other enclosures, so what are a few holes in the floor to them? The first hole “takes forever” so they hire a contractor to finish this work. They are surprised when the contractor brings a big water hose and wet vac.
Certification isn’t qualification
Suppose you have a certificate showing you completed Level II thermography training. Does this make you a qualified thermographer? Not by the standard set by the American Society for Nondestructive Testing (ASNT). You must complete a certain number of hours of practical work, the same as a pilot must fly a certain number of hours before getting a pilot’s license.
Furthermore, even if you have the certificate and the hours, you still might not be qualified. The employer must agree that you are qualified. One reason for that requirement is the particulars of safety and process differ from plant to plant. Working in a glass plant is quite different from working in a box factory. An inadvertent shutdown could cause the box factory to ship late, but an inadvertent shutdown at the glass plant will probably cause massively expensive damage.
Your supervisor knows the skills and experience needed to do a job and, after looking at your record, determines you’re not qualified to do it. That was probably a good outcome.
Suppose you are assigned a job because your supervisor believes you are qualified. During the briefing, however, you discover you’re not qualified to do parts of this job. Do you try to impress your boss by “winging it” and saving him the hassle of finding a qualified person, or do you let him know you’re not a qualified person?
There is only one correct answer to that question, and your boss will appreciate your honesty. That answer may be the one that saves someone’s life, too.
Lamendola is an electrical consultant located in Merriam, Kan. He can be reached at [email protected].
