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OSHA Electric Power Training Rules Qualified vs. Unqualified Employees
Pam Tompkins, CSP, CUSP President/CEO SET Solutions, LLC
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Objectives Electric Power- covered work processes
All employees vs. qualified employees Training requirements Type of training required Retraining
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Are your employees performing work on or near electric power generation, transmission or distribution facilities?
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Answer If yes, whether they are performing electrical or nonelectrical work, electrical training is required.
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Covered Work Work areas with electrical system hazards.
Electric Power Generation Construction work- No electrical systems Electric Power work- Start-up and commissioning of electrical and other covered systems. Electric Power Transmission and Distribution
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Generation Work
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Distribution Work
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Critical Training Requirements
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Risk Assessment Training is based on risk assessments.
Risk to the employee for hazard involved. Employee must be able to recognize hazards and take reasonable measures to avoid or adequately control the hazards.
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OSHA Requirements Employees must demonstrate proficiency in their work practices before training is considered complete.
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Who is required to be trained?
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OSHA Requirements All Employees Qualified Employees
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All Employees Nonelectrical work
If an employee does not need to access areas, or perform tasks, restricted to qualified employees, all employee training requirements apply. If an employee needs to access areas, or perform tasks restricted to qualified employees, the qualified employee training requirements also apply.
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“Qualified” Nonelectrical Employees
Employees must have the following minimum training: Know what is safe to touch and what is not safe to touch in the specific areas they will be entering. Know what the maximum voltage of the area. Know MAD for the maximum voltage within the area, and the skills and techniques necessary to maintain those distances Trained in the recognition and proper use of 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, and Trained to recognize the electrical hazards to which they may be exposed and the skills and techniques necessary to control or avoid those hazards.
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All Employees Each employee shall be trained in:
Safety related work practices, Safety procedures, Other OSHA safety requirements that pertain to the job, Applicable emergency procedures.
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Safety Related Work Practices
Distribution Transformer Connections
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Safety Procedures Placing a URD elbow on a parking stand to test and install a ground.
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Emergency Procedures
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Qualified Employee Definition of qualified employee
One 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.
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Qualified? Skills
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Qualified? Safety Requirements
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Qualified Employees Distinguish exposed live parts,
Determine the nominal voltage, Know Minimum Approach Distances (MAD), Know how to maintain MAD, Know special precautionary techniques, Know how to use PPE, insulating and shielding and insulated tools, Be capable of recognizing electrical hazards with the exposure risk, and Know how to control or avoid electrical hazards.
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Qualified vs. Unqualified
Employees can be qualified for some tasks and unqualified for other tasks.
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Same or different hazards?
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Who Qualifies the Qualifier
The employer has the responsibility to develop an effective process to evaluate whether employees comprehend training instruction and can perform the necessary work practices proficiently. The process normally includes assigning qualified managers, supervisors, training staff, etc., as the qualifying entity.
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What type of training is required?
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Safety Meetings Do they qualify as training?
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Classroom Training? OSHA Interpretation
OSHA has found classroom and on-the-job training to be the most effective forms of training because those training methods provide workers an opportunity to ask questions and have the trainer respond to them.
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Computer Based Training
Must be as effective as traditional classroom training. Must be interactive and participatory; workers must have an opportunity to ask questions, and have the trainer respond to the questions, during the training program.
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New Hire Training The employer may determine that the employee has demonstrated the proficiencies required by: Confirming that the employee has the training required. Using an examination or interview to make an initial determination that the employee understands the relevant safety-related work practices before he or she performs any work By supervising the employee closely until that employee has demonstrated the proficiencies required.
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Supervision & Annual Inspections
A review at least annually that each employee is complying with the required safety related work practices.
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Retraining Retraining or additional Training (new) is required when:
Employee has not completed the job task within one year; Employee is not complying with safe work practices; New technology or new equipment is introduced into the workplace; or Employee must engage in work practices not normally used during his or her regular job duties.
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Retraining Retraining would be required: OSHA Preamble Page #20349
When an employee is expected to administer CPR in the event of an emergency and he or she has not used those emergency practices over the course of the previous year. When an employee needs to climb a pole and it has been more than a year since he or she has used pole climbing practices.
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Questions?
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Pamela (Pam) T. Tompkins, CSP, CUSP CUSA
President 710 East Main Street Lexington, SC (803) Mobile (803)
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