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Qualified Workers and Risk Assessments

By Lee Marchessault - Published on August 3, 2016 7:55 pm

There are two levels of general hazard assessment to consider: a general hazard assessment for PPE requirements as outlined in 29 CFR 1910 Subpart I, Section .132, and a pre-work personal hazard assessment or “job briefing”. Qualified workers must also have the skills and techniques necessary to distinguish exposed live parts from other parts of electrical equipment, determine the nominal voltage of exposed live parts, know the clearance distances for the various nominal voltages (NFPA Restricted Approach Boundary) and also understand several specific precautions related to capacitors, CT’s, lighting requirements, gradient potential (medium voltage or higher), PPE requirements and emergency response related to electrical contacts.

These issues are part of a qualified worker’s daily work and require that an assessment is done prior to beginning work as an electrician, facilities maintenance worker, or production line worker performing electrical tests. The level of this “job briefing” depends on the level of risk of injury to the employee and if the work is routine or non-routine. With this requirement, each qualified worker should determine the shock hazard by identifying the exposure to electrical parts, the nominal voltage of those parts, and shock PPE required for adequate protection within the determined minimum approach (or restricted approach – NFPA70E) boundary. Protection from arc flash/blast hazards are determined by examining arc flash labels or by referring to their company’s written electrical safety program criteria where the arc flash hazard level has been determined by the employer.

A personal protective equipment assessment shall be performed by all employers. Electrical PPE requirements are broad and do not contain specific PPE particularly related to arc flash hazards. OSHA will cite companies based on non-compliance with this regulation 29 CFR 1910.132, or go to the Subpart S, 1910.335(a)(1) or 1910.269 for work related to generation, transmission or distribution of electricity (usually associated with medium and high voltage). To cite specific electrical PPE requirements, OSHA has cited NFPA70E under the General Duty Clause in excess of 30 times.

In our next blog post, we will discuss Shock Protection.

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Written by: Lee Marchessault, CUSA, CUSP

Lee Marchessault has nearly 30 years of experience in the Electric Utility Industry. He is now a Safety Consultant and the President of Workplace Safety Solutions, Inc. where he continues to work with many utilities and general industry in and outside the United States.

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