Do your technicians have the knowledge and skills to be considered qualified electrical workers under Occupational Safety and Health Administration (OSHA) standards? If not, save yourself a lot of headache and get with the OSHA program.
Training records are among the first things the agency looks at during an audit. If you are doing on-the-job training, be sure to document that as well. If you don't document it, you cannot prove to OSHA that your organization is doing it.
While many technicians working in wind farm maintenance and operations think they're qualified, they may not be – at least according to OSHA standards. For example, OSHA requires training for any worker who is exposed to energized electrical conductors or circuit parts at 50 V or greater.
"Qualified" May Not Mean What You Think
When conducting a training program, I sometimes like to get everyone fired up by asking, "How many master and journeyman electricians are in the room? How many electrical engineers? Are you qualified?" Most of the people will answer, "Yes." In most cases, however, the respondents are not ‘qualified’ under OSHA standards.
Many people erroneously believe the term ‘qualified’ means technically competent. They are only half correct. To be qualified – according to OSHA 29CFR1910.399 – technicians must demonstrate knowledge of the construction and operation of electric equipment and installations, as well as of the hazards involved.
Some companies are taking the approach that computer-based or video-based training is adequate enough for training qualified electrical workers. It is not. Also, I've heard of some companies whose initial qualified training programs last a grand total of four to eight hours. Such training programs are simply not good enough.
However, an eight-hour training program would be sufficient as a refresher course, given once a year. Further, to keep technicians up to date on the changing requirements and updates, retraining programs – as opposed to refresher courses – should be done at a minimum of every three years in accordance with National Fire Protection Association (NFPA) 70E Article 110.2(D)(3).
An effective safety training program should also include the following:
Electrical hazard awareness. If a worker cannot recognize a hazard, he or she cannot avoid the hazard. Qualified electrical worker safety training needs to include such items as electrical hazard awareness, the applicable OSHA regulations (29CFR1910.331 through .335, .137, .147, .133 and .132, to name a few) and use of personal protective equipment (PPE).
Shift supervisors and others supervising qualified electrical workers also need the same training so they understand the problems and issues faced by working on or near exposed, energized electrical conductors and parts.
Even unqualified workers, such as painters, janitors, helpers and apprentices, need some level of safety training. Anyone who may come in contact with equipment that could be exposed and energized will require electrical safety training. In most cases, everyone is required to have training. What changes is the level of training required.
Mostly, training for unqualified employees consists of being made aware of the hazards and how to avoid them. For example, don't open cabinet doors on electrical equipment.
Knowledge of PPE – and how to use it. The term "use of" does not mean just how to pick something up and go after it. This requirement also means training on determining the following: Are the PPE and equipment being worn properly? Is it adequate for the task and hazard? Do you know how to judge that? Does it cover all ignitable clothing?
Is the clothing the right size? If you're stuffed like a sausage into your arc flash coveralls, the heat from an arc flash could burn right through your clothing.
"Use of" also includes how to inspect these items and ensure they are safe to use. Is there any damage to arc flash PPE that could cause it to be unsafe, such as cuts, rips or holes in the material or grease spots? Are there gaps in the seals that could allow heat to enter when wearing arc flash PPE? Has it been exposed to an arc flash previously? Reusing arc-flash PPE is not the way to save money.
Is the arc-rated clothing and PPE properly marked? On arc flash protective clothing and equipment, does the arc rating on the outside match the arc rating stated on the label? Arc-rated clothing and PPE must be designed and rated specifically for electrical workers as opposed to firemen or steel workers.
For example, be certain the product's label meets the requirements mandated by the NFPA (70E) and American Society of Testing and Materials (F1506).
Evaluation of hazards and risks. Work on exposed energized conductors and circuit parts increases the risk of injury or death. Performing testing and maintenance involves that type of exposure, so knowing what the hazards are and evaluating the risks is of prime importance. It does take some extra time and effort, but a few minutes completing a proper job-hazard analysis could prevent a long stay in the burn ward of a hospital.
Evaluating the hazard can be a little tricky. The nominal voltage (system design voltage) determines the glove class. If the system has had an arc flash study performed on it, it will have the arc flash protection boundary and incident energy at working distance listed on it. If not, refer to Tables 130.7 in the NFPA 70E to choose the proper type of PPE.
One last item: Per OSHA regulations 29CFR1910.332 and .333, training has to include a demonstration of skills needed to make sure the training you conduct or contract for includes documented lab sessions as part of the curricula. Also, make sure the training covers how your system operates. Schemes for electrical power systems, such as loop, radial, main-tie-main and, double-ended subs, can present unique operational hazards for personnel who are not familiar with them.
James R. White is training director at Irving, Texas-based Shermco Industries, a provider of testing, maintenance, repair, commissioning, engineering and training services for electrical infrastructure. He can be reached at firstname.lastname@example.org.