What training do “non-electrical” utility employees need?

“Non-electrical” employees such as loss control representatives are not considered “qualified persons” under 29 CFR 1910.269. 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.

According to an OSHA interpretation letter dated June 9, 1999, however, employers may train “non-electrical” employees as qualified employees for the purpose of entering and working within restricted areas of generating stations and substations. For example, representatives conducting loss control tours would need this training. While the training for these employees must meet section 1910.269(a)(2)(ii), it would not need to be as comprehensive as the training normally provided to a qualified electrical worker.

These qualified “non-electrical” employees must have the following minimum 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 (1910.269(a)(2)(ii)(A)),
2. They must know what the maximum voltage of the area is (1910.269(a)(2)(ii)(B)),
3. They must know the minimum approach distances for the maximum voltage within the area (1910.269(a)(2)(ii)(C)), and
4. They must be 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. (Note: only fully qualified electrical employees may install insulating equipment on energized parts.)

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 person at all times.