OSHA-required training for non-electrically qualified workers
On May 17, 2002, Mr. Carl VanDusen, safety manager for Cable Constructors, Inc., Iron Mountain, MI, wrote OSHA asking for an interpretation the following question:
Question: Does the OSHA interpretation letter (June 9, 1999) that provided guidance on training non-electrical workers for entry and work within restricted areas such as generating stations and substation also apply for training employees who open restricted equipment for visual inspection only?
Reply: Yes. As explained in the referenced interpretation letter, employers may train workers as qualified employees for the purpose of entering and performing non-electrical work within generating stations, substations, manholes, vaults or similar restricted areas.
The employees you identified are assumed to be non-electrically-qualified workers who will open electrical equipment within restricted areas for visual inspection only. Since these visual inspections would require the removal of enclosures or guards, workers could be exposed via proximity to electric equipment that is energized at levels greater than 50 volts. All employees with direct access to the type of equipment or installations covered by 1910.269 must be trained as required by 1910.269(a)(2)(i) and (ii) in order to meet the definition of a qualified person contained in 1910.269(x).
The training outlined in the referenced interpretation letter specifically addresses employees who are not electrical workers but whose work activity would require exposure to electrical hazards associated with the generation, transmission, or distribution of electrical power. Therefore, the minimum acceptable training for the workers described in your scenario would include the training outlined in the June 1999 letter. Those requirements are provided below for your reference:
1. They must know what is and is not safe to touch in the specific areas they will be entering [paragraph 1910.269(a)(2)(ii)(A)].