Only "qualified" persons are permitted to work on or near electrical hazards. Last week, I identified the regulations and standards that say this. The rest of this series will discuss what those regulations and standards say. This installment looks at the scope of the qualification requirement and hazards to which it applies.

The 50 - Volt Threshold

One of the triggers for qualification is voltage level. The common thread in most electrical regulations and standards is the requirement that all electrical circuits and equipment energized at 50 volts or more be guarded, covered, protected or otherwise made inaccessible, except to qualified persons. Only qualified persons, in other words, may have access to energized circuits and equipment.

The 'Exposed' Threshold

Anyone opening industrial panels containing exposed energized components must be qualified. Only qualified persons shall have access to rooms containing exposed energized components unless the components are guarded, covered or protected by barriers or equally effective means. NFPA 70E specifies a minimum approach boundary for an unqualified person of 42 inches to exposed circuits and equipment energized between 50 and 750 volts, unless continuously escorted by a qualified person.

Task Limitation

The access restrictions mean in effect that only qualified persons may perform electrical work on energized equipment. But the regulations go even further in stating that only qualified persons may perform electrical testing. Thus, only a qualified person is allowed to perform the fundamental task of voltage verification and checking to see if a circuit is deenergized.

Lockout/tagout also requires involvement of qualified persons. The person in control of the lockout/tagout procedure must be qualified. A qualified person must verify that the equipment has been properly deenergized before work begins and that it is safe to reenergize the equipment after the lockout/tagout procedure has been completed. In addition, a qualified person must conduct an audit of lockout/tagout procedures at least once a year.

Finally, there are a number of electrical installation standards that are relaxed if a facility utilizes only qualified persons to maintain and repair their electrical systems. These frequently used allowances and exceptions are common in federal regulations and the NEC.

The Bottom Line

Electrical regulations and standards require anyone (including employees, contractors and service personnel) opening a door or entering a control panel, cabinet, motor control center, panelboard, switchboard, room or vault, that exposes parts energized at 50 volts or more to contact, to be qualified.

Next week, I'll analyze which persons must be qualified and what qualification entails.

ELECTRICAL SAFETY COMPLIANCE CHECK

A 10 - Question Test

By Glenn Demby
How can you tell if you’re in compliance with OSHA electrical safety standards? To start, you might want to ask yourself the following questions:

YOU MAKE THE CALL

Workplace Safety vs. Personal Privacy

By Glenn Demby

What Happened: Two incidents occur at an Ontario construction site. The union demands a copy of the incident reports. The company refuses. The Ontario OHS Act (the provincial equivalent to the U.S. OSHA statute) gives the union the right to see the incident reports; but the reports contain personal information about a worker that’s protected by personal privacy laws. And since the company doesn’t have the worker’s consent to disclose the information, it withholds the reports. The union files a grievance.

Who Won: The union.

Explanation: The Canadian privacy law (called PIPEDA - Personal Information Protection and Electronic Documents Act) bans the collection, use and disclosure of personal information without the individual’s consent. But there are exceptions when a company doesn’t need consent. One of these is when the disclosure is required by law. That was the case in this situation. So the company had to give the union the incident reports even without the worker’s consent [E.S. Fox Ltd., [2006] O.L.R.D. No. 661].

The U.S. Perspective: If this case had happened in the U.S., the outcome would have been the same. OSHA recordkeeping rules guarantee employee representatives access to injury reports even if they contain private information about workers. The consent rule under HIPAA - the Healthcare Insurance Portability and Accountability Act is the same as under PIPEDA: You don’t need consent to make disclosures required by law.

An August 2, 2004 OSHA Interpretation Letter confirms that OSHA interprets this to apply to disclosures required under the recordkeeping standard. In other words, the employer would have to give a union injury records containing a worker’s private information even if the worker doesn’t consent to the release.

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