By Dennis K Neitzel, CPE

There are quite a number of good reasons to have effectively trained and qualified maintenance employees. One of the most important is the employee’s safety. Another important reason is to be able to maintain electrical systems and equipment in a safe, reliable condition. Although training is mandated by OSHA, this should not be the driving force behind providing adequate training for employees. Training should be done because it is the right thing to do.

Would you take your car to a mechanic who had not been trained in auto repair? Would you have a house built by unskilled labor? Would you fly in a plane piloted by someone who was not a trained and skilled pilot? Even worse, would you have open heart surgery performed by a dentist? Of course you wouldn’t do any of these things. Why then would anyone want to perform electrical work without being trained and qualified, or why would you hire anyone to perform electrical work, that is not qualified to do so?

The “school of hard knocks” is all too often the method for training technicians. This method is adequate for some things but it is a very poor substitute for formal training, especially when dealing with electrical safety.

The proven method for effective training is a combination of lecture, demonstration, and hands-on. In fact OSHA, in 29 CFR 1910.269(2)(vii) requires an employee to “demonstrate proficiency” before the employer can “certify” that the employee has been trained. The most effective way to accomplish this is by incorporating hands-on training.

Qualified Employees

The National Electrical Code Ò (NEC) 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 on the hazards involved. ” In addition to this definition OSHA states that: “qualified persons are intended to be only those who are well acquainted with and thoroughly conversant in the electric equipment and electrical hazards involved with the work being performed.”

As stated earlier, there are many benefits to having well trained and qualified employees. Two major benefits, expressed by the industry, are the reduction of unscheduled down time and the safety of each of their employees.

The more extensive the training program the better qualified the employee. It has been proven that the most effective training programs include a combination of lecture and hands-on instruction. As an example; an employee attends a class on circuit breaker maintenance and testing using the following agenda: (1) the instructor explains the components and operation of the circuit breaker, as well as the maintenance and testing techniques; (2) the instructor then demonstrates those techniques on a circuit breaker; and (3) the employee performs hands-on maintenance and testing of the circuit breaker using the techniques that were presented and demonstrated. In this example, employees, on average, would retain at least 90% of what they were taught. This method of training has proven to be the most effective means for qualifying employees.

OSHA has provided the industry with several requirements for the training and qualification of employees. The following information is provided so the reader can better determine whether or not a person is qualified.

As stated earlier, one of the three qualification requirements is being trained in safety on the hazards of the equipment, this must be addressed specifically. OSHA has provided strict guidelines for safety training that go hand-in-hand with the qualification of an employee. The following references are provided in order to inform the reader of the OSHA mandates for training employees in the electrical field.

 

• 29 CFR 1910.332, Training. This is part of the Electrical Safety-Related Work Practices regulation for general industry.
• 29 CFR 1910.132(f), Training. This is part of Subpart I, Personal Protective Equipment (PPE) and requires the employer to provide training to each employee who is required to use PPE.
• 29 CFR 1910.269(a)(2), Training. This reference is part of the Electric Power Generation, Transmission, and Distribution regulation.

OSHA has explicitly required the employer to train their employees in electrical safety with respect to the employee’s specific job responsibilities.

OSHA 29 CFR 1910.269(a)(2) ”Training.(i) Employees shall be trained in and familiar with the safety-related work practices, safety procedures, and other safety requirements in this section that pertain to their respective job assignments. Employees shall also be trained in and familiar with any other safety practices, including applicable emergency procedures (such as pole top and manhole rescue), that are not specifically addressed by this section but that are related to their work and are necessary for their safety.

OSHA continues with this requirement by requiring qualified employees to be trained and competent in:

 

• The skills and techniques necessary to distinguish exposed live parts for other parts of the equipment
• The skills and techniques necessary to determine the nominal voltage of the circuits and equipment
• The minimum safe approach distances to exposed live parts
• The proper use of:
• Special precautionary techniques
• Insulating and shielding materials
• Insulated tools and test equipment
• Job planning

In addition to this OSHA states that a person must have this training in order to be considered a qualified person. The employer is also required, through regular supervision and annual inspections, to verify that employees are complying with the safety-related work practices. Additional training or retraining may also be required if:

The supervision or annual inspection indicate non-compliance with or lack of understanding of the work practices

• New technology
• New types of equipment are installed
• Changes in procedures
• Employee is required to use work practices that they normally do not use

OSHA also considers tasks that are performed less often than once per year to necessitate retraining before the performance of the work practices involved. This retraining may be as simple as a detailed job briefing prior to the commencement of the work or it may require more in-depth classroom instruction along with on-the-job training.

The OSHA Electrical Safety-Related Work Practice regulation, 29 CFR 1910.331-.335, as well as NFPA 70E-2004, Section 110.6 “Training Requirements” provides the same basic requirements as 1910.269 for training qualified persons. As can be seen by the above statements, proper training is a vital part of the worker’s safety and proficiency, as well as being a mandated OSHA requirement.

Training Programs

The training requirements have been established, by OSHA and NFPA, now it is up to the industry to comply. However, before any significant training can be developed or implemented, an assessment must be conducted to determine what is needed. This process is generally referred to as a needs analysis. The needs analysis will involve relevant company personnel who are aware of the job requirements and all applicable codes, standards, and regulations. Information that is collected will help provide insights into any past or present performance problems that must also be addressed in a training program. This process can also be used to determine whether or not training is the solution to any problems that may exist. Other factors, which affect performance, must also be recognized and considered. These other factors could include the quality of procedures, human factors, management style, and work environment.

Once the needs analysis has been completed, the next step would be to perform a job/task analysis and then a job/task hazards analysis. By performing these analyses, the employer can determine what their employees are expected to do in their jobs, determine the hazards associated with the job and tasks, determine the proper personal protective equipment, and then determine what training would be needed.

A proven method for developing a good training program is called the “Systematic Approach to Training” or SAT, which utilizes the “Instructional Systems Design” or ISD methodology for performing the analysis, design, development, implementation, and evaluation for a training program. The ISD provides a systematic procedure for identifying the job-related skills and knowledge necessary for performance-based training.

As was mentioned earlier, safety is a major issue when training and qualifying employees. Performing a job/task hazard analysis is not an option. OSHA 29 CFR 1910.132(d)(1) requires that: “The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE).”

NFPA 70E refined the OSHA requirement, for conducting a hazard analysis, by specifically identifying the electrical hazards. NFPA 70E-2004, Section 110.8(B)(1) requires a “Shock Hazard Analysis” and a “Flash Hazard Analysis” be performed to determine what the electrical hazards are and establish the shock protection boundaries as well as the flash protection boundary in order to select the proper personal protective equipment for employees that may be exposed to these hazards.

In addition to this assessment, OSHA also requires under 1910.132(f)(1) that: “The employer shall provide training to each employee who is required by this section to use PPE.” Employers cannot assume that employees know the proper use and care of PPE; they must be trained.

Conclusion

Electrical systems reliability and employee safety are two of the most important reasons why employees must be qualified through an effective training program. The reliability of protective devices, controls, instrumentation, and interlock systems demand that technicians maintain a high technical skill level. Safety and operating procedures utilized in working on these systems are equally as complex requiring technicians to be expertly trained in all safety practices and procedures.

OSHA and NFPA require employers to document that employees have demonstrated proficiency in electrical safe work practices as well as tasks. Employers must “certify” that their employees have been trained and that this certification is maintained for the duration of the employee’s employment.

Dennis K. Neitzel , CPE, is the Director of AVO Training Institute, Inc., Dallas, Texas and is a Principle Committee Member for the NFPA 70E, Standard for Electrical Safety in the Workplace. He is also co-author of the Electrical Safety Handbook, McGraw-Hill Publishers. Please contact Mr. Neitzel at dennis.neitzel@avotraining.com for more information.