Are Your Employees Qualified? By Quad State Instructors Group

29 CFR 1910.269 It is not uncommon for boards of directors, CEO’s, GM’s and others to take tours of new or existing substations and other facilities. This raised the question, can these people safely enter (according to the rules) these locations, just to “Take a Tour or look around”?

29 CFR 1910.269 In doing so, each cooperative must ask itself two questions. Do employees/or others at your cooperative enter secure areas, such as substations, switchyards, generating stations, or open pad-mounted equipment? Are all of these people qualified to enter substations, switchyards, generating stations, pad- mounted equipment?

Electric Power Generation Transmission & Distribution When the 1910.269 standard was published. It created some confusion concerning the rules and caused many questions to be asked. Review Federal OSHA interpretations. Reviewing these OSHA interpretation letters revealed a situation that each cooperative should investigate to ensure compliance with 1920.269.

Interpretations Three refer directly to this question June 23, 1997 May 17, 2002

Where are Qualified Workers Required “Cleanup operations at electric power generation, transmission, and distribution facilities are not covered by 1910.269, unless one of the following conditions is met: (2) The operation is performed in rooms or spaces that contain exposed energized parts or electric power generation, transmission, or distribution equipment.”

Why are they required “Electric power generating stations and transmission and distribution substations typically have areas containing energized electric lines and equipment. Unless the energized lines or equipment are guarded sufficiently, it is unsafe for unqualified persons to enter these spaces.”

Why are they required “With exceptions, electric power generating stations and transmission and distribution substations are restricted to entry by qualified persons.” In order for them to be qualified, they must be trained

What kind of Training “Paragraphs 1910.269(u)(4)(i)(A) through (C) and 1910.269(v)(4)(i)(A) through (C) set forth the conditions for spaces within substations and generating stations, respectively, under which unqualified persons may not enter.” Section (u) Substations Section (v) Power Generation

What has to be in the training? These "qualified" (non-electrical) employees must have the following training: (1) They must know what is safe to touch and what is not safe to touch in the specific areas they will be entering (paragraph 1910.269(a)(2)(ii)(A)); (2) They must know what the maximum voltage of the area is (paragraph 1910.269(a)(2)(ii)(B));

What has to be in the training? (3) They must know the minimum approach distances for the maximum voltage within the area (paragraph .269(a)(2)(ii)(c)); and (4) They must be trained in the recognition and proper use of electrical protective equipment that will be used to provide protection for them and in the work practices necessary for performing their specific work assignments within the area.

Anything else? Until these "qualified employees" have demonstrated proficiency in the work practices involved, they are considered to be employees undergoing on-the-job training and must be under the direct supervision of a qualified employee (qualified person) at all times. According to the definition of "qualified employee (qualified person)," the employee also must have demonstrated an ability to perform the work safely at his or her level of training.

Is there more? It is expected that an orientation familiarizing the employee with the safety fundamentals given here will be conducted before an employee undergoing training is allowed to enter a restricted area.”

OK, but do I need to train everyone? An employee must have the training required by paragraph (a)(2)(ii) of Section 1910.269 in order to be considered a qualified person. A qualified employee is defined as one who is knowledgeable in the construction and operation of the electric power generation, transmission, and distribution equipment involved in his or her job, along with the associated hazards.

What about lineman? Having power line workers go through an apprenticeship training program may not provide all the training required under paragraph 1910.269(a)(2)(ii). The employer must ensure that the program used includes all applicable training elements required under paragraph 1910.269(a)(2)(ii) and work practices throughout 1910.269.”

How extensive of training? Would an in-house basic electrical safety training program covering (a)(2)(i) and (a)(2)(ii) for the expected conditions in the Switchyards be sufficient training in order to perform the tours when escorted by a Utility representative? While the training for these employees must meet paragraph 1910.269(a)(2)(ii), such training need not be as comprehensive as the training provided normally to a qualified electrical worker.

What does all this Mean? Each cooperative should provide or ensure that all employees entering these locations have this training or have had it during an apprenticeship or previous training. That the employee is knowledgeable and proficient to perform their work in these locations. OSHA also states that the training requirements they listed in the two previous interpretations is “the minimum acceptable training”.

What to Do! Develop and provide employees a training class that covers all of the basics and also some electrical fundamentals. Take trainee’s on a field trip to a substation to point out different equipment, energized conductors, possible hazards and more. Open various pad-mounted equipment for visual inspections.

What to Do! At the end of the training, each student is given a test to verify knowledge about the training they just received. Each employee is required to demonstrate proficiency in the safety procedures and practices they learned in the class. Supervisors should be the person that is in charge of verifying that proficiency.

Questions?