Does Safety Training Qualify or Certify my Employees?
We are often asked, “does your or any other electrical safety training qualify or certify someone to work on electrical equipment”? The simple answer is no but let me explain why.
The OSHA electrical safety regulation that all general industry employers must follow is 1910 Subpart S. Many U.S. employers will also implement an electrical safety program for their workplace that complies with National Fire Protection Association standard 70E. In either case, the requirements for qualifying employees to work on or near equipment is the same and although electrical safety training is required it alone is not enough to make an employee qualified.
OSHA 1910.332 is where you find the requirements for electrical safety training. The paragraphs and subparagraphs listed in the standard discern between qualified and unqualified workers. Different levels of training are required based on the hazards the employee is exposed to. It important for the employer to be familiar with what OSHA means by qualified. This information can be obtained by reading the definition of a qualified worker located in standard 1910.339 titled Definitions Applicable To This Standard.
“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”.
Notice in the OSHA definition that workers must be competent in two areas (technical and safety) to be considered qualified. Because the electrical safety training does not address the employee’s technical abilities, it alone is not enough to qualify someone it is simply a piece of the puzzle.
OSHA also identifies a qualified person in 1910.332(b)(3) as those permitted to work on or near exposed energized parts. These employees are expected to be trained at a minimum to be able to:
- Distinguish exposed live parts from other parts of electric equipment.
- Determine the nominal voltage of exposed live parts
- Identify safe clearance distances and the corresponding voltages to which the qualified person will be exposed.
What type of training is required?
- The training required 1910.332(c) shall be of the classroom or on-the-job type.
- The degree of training provided shall be determined by the risk to the employee.
Minimum Compliance Does Not Always Ensure Safety
Remember that the degree of training needs to be determined by the risk to the employee. Simply following the minimum requirements as listed above in 1910.332(b)(3) will not be sufficient in many if not most cases. For example, employees are working in and around equipment that could produce an arc flash. We recommend employers train their qualified workers in accordance with NFPA 70E article 110.2 which requires a comprehensive level of electrical safety training that includes risk assessing and safe work practices for shock and arc flash hazards. Always consult with a reputable electrical safety training firm or organization familiar with the requirements if you are unsure or have questions.
The Employer’s Responsibility
Because the employer is familiar with the technical abilities required to perform work on their equipment, the electrical hazards involved and level of safety training required only the employer can determine who is qualified and who is not.
Why the certificate of completion?
Most electrical safety training companies provide students and employers with a certificate of completion if the student successfully completes their course. These documents simply identify that the employee has satisfactorily completed safety training. Again, this is not a qualifying or certifying document. However, these certificates could be kept with other required training records as proof employees have completed a formal electrical safety training program.
Need more information
OSHA offers a wealth of information concerning their training requirements in its handy publication Training Requirements by Standard. https://www.osha.gov/