• The existing OSHA 1910.132(d) Hazard assessment and equipment selection.

(1)The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). Paragraph (f) of 132 requires the employer to provide training to each employee who is required by this section to use PPE. OSHA also requires the employer to verify that each affected employee has received and understood the required training through a written certification that contains the name of each employee trained, the date(s) of training, and that identifies the subject of the certification.

• The existing requirement of 1910.269(a)(2) that requires employees to be trained in and familiar with the safety-related work practices, safety procedures, and other safety requirements in this section that pertain to their respective job assignments. Employees are also required to be trained in and familiar with any other safety practices, including applicable emergency procedures, that are not specifically addressed by this section but that are related to their work and are necessary for their safety. This section also requires the employer to certify (document) that each employee has received the training required. This certification (documentation) is required to be made when the employee demonstrates proficiency in the work practices involved and must be maintained for the duration of the worker’s employment.

New & revised requirements

The new requirement for training per 1910.269 and 1926 Subpart V is as follows:

Paragraph (2) Training. (i) All employees performing work covered by this section shall be trained. OSHA then outlines all of the training and retraining requirements for qualified persons. Although OSHA does not specifically state that training must be documented, they do state the following:

• (vi) The training required by paragraph (a)(2) of this section shall be of the classroom or on-the-job type.
• (vii) The training shall establish employee proficiency in the work practices required by this section and shall introduce the procedures necessary for compliance with this section.
• (viii) The employer shall ensure that each employee has demonstrated proficiency in the work practices involved before that employee is considered as having completed the training required by paragraph (a)(2) of this section.

The only way to provide evidence of training and demonstrate proficiency is to properly document that it has occurred.

The revised OSHA 1910.269 contains several new or revised requirements for employees working with electric power generation, transmission and distribution lines and equipment. All existing training programs must be updated to include these new or revised requirements.

The revised OSHA 1926 Subpart V is a complete revision of the old regulation, therefore, training programs would be required to be updated to include these new requirements. This training would also need to include the new 1926.97 Electrical Protective Equipment requirements for construction.

Update your training

With the new and revised 1910 and 1926 requirements for hazard assessments, which now include arc flash, personal protective equipment, and electrical safety programs and procedures, updating training programs to include these requirements is vital to the protection of employees working on or near exposed energized lines and equipment.