How to Comply with “Qualified Persons” Requirements

Date First Published on SafetySmart Compliance: January 3rd, 2012
Topics: Electricity |

In the world of operations, maintenance, service and construction, employees must be “qualified” if they’re going to be exposed to electrical hazards capable of injuring, disabling or killing them. Here’s a summary of what the qualification regulations require.

Electrical Safety Qualification Regulations

Qualification regulations differ slightly by industry. But the general thrust and intent is the same: to ensure that employees, contractors and service personnel are competent to work on or near electrical hazards.

In the U.S., the primary source of regulation is federal. There are at least 3 parts of the Code of Federal Regulations (CFR) that set standards of qualification for electrical work:

  • Title 29 Part 1910 for General Industry including Electric Utilities (under OSHA);
  • Title 29 Part 1926 for the Construction Industry (under OSHA); and
  • Title 30 Part 75 and 77 for Coal Mines (under the Mine Safety and Health Administration (MSHA)).

In addition to regulations, there are electrical safety standards promulgated by non-governmental standards organizations addressing qualifications for persons who work on or near electrical hazards. The standards that affect most companies in the U.S. are the National Fire Protection Association NFPA 70 – National Electrical Code.

The “Qualified” Person Danger Zone

The general principle is that only qualified persons are allowed to perform tasks in the zone of danger. But the point separating the danger from the safety zone—the qualified from the unqualified zone, if you will—can vary:

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 are allowed to 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 the CFR and the NEC®.

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.

What Makes a Person ‘Qualified’

To be qualified, a person must be familiar through training or experience with the construction and operation of electrical equipment and trained to recognize and avoid the hazards involved. Some regulations and standards specify that the qualified person must be capable of working safely on energized circuits and be familiar with the proper use of special precautionary techniques, personal protective equipment/clothing, insulating/shielding materials and insulated tools.

Three points of clarification:

  • Training can be classroom, on-the-job or a combination of both;
  • An employee who in the course of on-the-job training demonstrates an ability to perform duties safely at his level of training and who is under the direct supervision of a qualified person is considered to be qualified to perform those duties; and
  • An employee may be qualified to use certain kinds of equipment and methods but unqualified to use others.

Additional Requirements

Some regulations and standards impose additional requirements. For example, MSHA—the U.S. Mines Safety Health Administration–requires a person to pass an MSHA-approved electrical exam and receive electrical safety retraining annually thereafter.

Many states, Canadian provinces, counties and cities require persons performing electrical work, primarily contractors and contract electricians, to be licensed. This generally means the person must have documented electrical experience and have passed an electrical exam.

Qualifications in a Nutshell

Plainly stated, to be qualified, a person must either:

a. Be licensed or certified by a recognized entity such as the IBEW (International Brotherhood of Electrical Workers), MSHA or another government agency or jurisdiction (the person should also be trained in CPR if medical help is not readily available in the workplace); or

b. Have documented proof of:

  • Safety training on understanding, recognizing and avoiding electrical hazards;
  • Training to determine the nominal voltage and safe working distance around electrical equipment;
  • Training in the selection, use, and care of personal protective equipment, clothing, insulating tools, test equipment, barriers, etc. necessary to perform the task(s);
  • Knowledgeable of the equipment operation and electrical installation;
  • Training to perform task(s) safely; and
  • Training in CPR if medical help is not readily available in the workplace.

Qualified Person vs. Qualified Electrician

There’s a difference between being a qualified person and being a qualified electrician. Qualified electricians must have:

  • A good general understanding of electricity;
  • A broad base of technical electrical training, electrical safety training and actual experience performing electrical tasks;
  • The capability to perform a wide variety of electrical tasks related to their work environment;
  • Appropriate PPE to guard against the electrical hazards they encounter in the workplace and the knowledge of how to use and care for it; and
  • Training on the capabilities of their test equipment and how to use and care for it.

A qualified person, by contrast, need only be trained to perform a limited number of tasks safely—possibly This person must be safety trained to understand, recognize and avoid the electrical hazards associated with the specific task, understand their limitations in performing the task, equipped with the proper PPE and test equipment for the task, and know when and how to use and care for the PPE and equipment.

Qualification to Perform Specific Tasks

There’s only one regulation that specifically requires work to be done by a qualified electrician: the installation of resistance welders under Section 1910.255 of the OSHA electrical safety standard. Other electrical tasks can be performed by either a qualified person or electrician. There are, in other words, many electrical tasks around a workplace that a non-electrician employee can perform as long as the employee is a qualified person. OSHA identifies the kind of employees who are most likely to be asked to perform these tasks (and who will thus at least need the training required of a qualified person):

Blue Collar Supervisors Electricians
Electrical and Electronic Engineers Mechanics and Repairers
Electrical and Electronic Equipment Assemblers Painters
Industrial Machine Operators Riggers and Roustabouts
Material Handling Equipment Operators Stationary Engineers
Electrical and Electronic Technicians Welders

The Role of Management

Determining the qualification of an employee is the responsibility of management, not of the government. Management must determine the scope of work expected of each employee and assess the workplace for hazards the employee may encounter. Once these assessments are complete, management should establish a minimum skill and knowledge level necessary to complete the scope of work safely and effectively. The employee’s personnel file should reflect the employee’s experience and technical training as well as the safety training to perform the task safely and effectively.

Plainly stated, documentation, documentation, and documentation is critical in supporting your decision to secure qualified person status for an employee. The employee’s personnel file should include documentation of:

  • Formal electrical training;
  • Years of experience in performing similar tasks;
  • Training on electrical equipment and circuits;
  • Electrical safety training;
  • Training on the applicable regulations and standards; and
  • Training on PPE.

Retraining and documentation of retraining are equally important. Some conditions that indicate the need for retraining include changes in the workplace, in the equipment, in the PPE, in the regulations and standards, or deficiencies in actual task performance.

A Suggested Approach

First, an important caveat: Some employers assume that proof of attendance at a one-day training session on NFPA 70E is enough to qualify your employees to perform electrical work. This is not true. Although NFPA 70E training is definitely recommended, if not required for your qualified employees, it is only a single component of a much broader-based training program.

Step 1: JTA. Prepare a list of the task(s) on or near exposed energized parts that the qualified person or electrician is expected to perform; often referred to as a job/task analysis (JTA).

Step 2: JHA. Perform a job hazard analysis (JHA) and prepare a description of the skill and knowledge required to perform the job safely; this must include the training requirements discussed previously.

Step 3: Comparison Check. Now compare these requirements to the knowledge, skills, and training of the person expected to be qualified to perform the task(s). This comparison should identify the areas of weakness and be a guide to developing a training schedule to address these weaknesses.

Training budgets are limited, so concentrate on the weakest areas first and keep training until you have addressed the needs of the employee to perform the task(s) safely.  Try to develop a 3 year plan, which will coincide with updates to the regulations and standards.  Schedule a minimum of 2 to 5 days of training annually for each qualified employee.

The following is a suggestion of training for qualified persons:

1 NFPA 70E 1 day 1 day
LOCKOUT / TAGOUT 1/2 day 1/2 day
2 – 3 ELECTRICAL SAFETY 1 day 1/2 day
LOCKOUT / TAGOUT 1/2 day 1/2 day

* Practical Electrical Training may include training on:

  • National Electrical Code®;
  • Programmable Logic Controllers (PLC);
  • Variable Speed Drives (VSD/VFD);
  • Electrical Troubleshooting;
  • Air Conditioning and Refrigeration; and
  • Grounding and Bonding.


Remember that “qualified person” requirements aren’t suggestions or recommendations. They’re the law. Ultimately, it is the employer’s responsibility to ensure that workers who work with or near electrical hazards are qualified to perform the work safely and effectively. Turning workers into qualified persons requires training, either on-the-job or in the classroom, and preferably both. The training should be diverse and include technical, regulatory, and safety subjects. Finally, document all training! Like the lawyers say, if it isn’t document, it never happened.