Post Webinar Questions
But with that, Mike, we're going get into some questions. How does a qualified person definition apply to de-energized work?
Mike: The part that you have to be careful about here is, if it's just de-energized, it's still not considered electrically safe. You need someone who is qualified, who is knowledgeable about the equipment to deem whether or not it's electrically safe. Electrically safe means that all possible sources of energy have been identified and isolated, "locked out", to use the required term, has been properly tested to assure that it is in fact dead. There is a prescribed method or prescribed procedure that is mandated in order to verify an absence of energy. And then, last but not least, in certain circumstances, if there's ever a possibly of having voltage induced into the equipment that's being worked on by neighboring equipment that's still energized, that has to be accounted for as well, through grounding and bonding. But until it is deemed electrically safe in the set of steps that OSHA mandates, even though you've de-energized, just shut the power off, it's still required of that only qualified people work on it.
Thanks, Mike. And do you feel that all employees should take the safety training? And there was an emphasis on all employees.
Mike: I think all employees should take some degree of safety training. Obviously, if someone who's going be actually doing the electrical work is going to need a much higher degree of training, well, I think every employee in a facility should have to have at least electrical safety basic training in order to, one, if they do, in fact, come on a work area where electrical workers are working, they recognize the hazard associated with getting too close. Two, electrical workers, everybody else somewhere along the line, are going to be called upon to either interact with or work around electrical equipment in its normal status.
I mean, we do it at home when we reset a breaker. I mean, we all do that. Non-electrical workers, having been given basic training would know how to recognize when this typical equipment is in maybe an out of the ordinary state and maybe recognize a problem and not to interact with that equipment. I just think that everybody...I think everybody could benefit from it.
The next question we have, Mike, is "If electrical contractors come in and work in our facility, do they too need to show documentation that the person doing the electrical work has been through an arc flash training, for example?"
Mike: Yes. The basic rule is...what that's called is a "host contractor relationship". I always call it, you know, you have the home team and you have the out-of-town team. When the out-of-town comes in and plays ball in your ballpark, they play by your rules. Now, they're perfectly fee to have even more stringent requirements on their workers. But just because they don't work for you per se, when they're a contractor and in your facility, you're still responsible for them in your facility. There is about a dozen articles in Article 110 of the 70E document that specifically spells that out. It would even be...for me, it would be part of in the contract process when we're agreeing to have the work done. I would want some kind of verification that the people coming to work in my plant are in fact qualified. Now, it's not up to me to make that determination, it's up to their employer to do it. And that's spelled out in the 70E as well, that they have the responsibility of providing that proof.
All right. Next questions says, "Since electricians normally work together," at least they do it at this person's facility, "should the electrician still be required to learn CPR? The second electrician could be considered a first responder. Just an idea really, since I'm pushing this is in my facility?" But Mike, why don't you opine on that one?
Mike: My fallback on that one is what I said about...a little earlier there, is they've already moderated their requirements on that. And believe me, there is absolutely nothing wrong. I honestly believe anyone that does electrical work in any way, shape, or form should be CPR certified. It is not a difficult [00:59:24] to acquire. But, at the very least, you should most definitely have someone in the area. The mandate's no longer required that all of the workers carry the CPR...certification, I mean. As long as... If you do have designated first responders in the plant, they're the ones that are required to have it. If you don't have responders, then everybody doing it has to.
Mike, this next question asks simply, "What can I do to convince management that we need a QEW program?
Mike: One of the more powerful, more persuasive, arguments I've always found is the fact that, one, there's never a shortage of available statistics. And not just the fatalities, I mean, obviously fatalities carry a lot more weight, but if you look at the statistics on, say, the Bureau of Labor Statistics website or even on OSHA's website, even with all of the effort that's been put forth over the last 20 years, there's still just an unbelievable number of people getting hurt or killed in this line of work.
And when you read the reports and you see why these accidents are happening, it would be so easily avoided if there was just more attention paid to determining, does this worker, in fact, know what they need to know? I've told, I don't know how many classes over the years, you know, looking back, that one of the easiest ways to be deemed qualified was to be the only one available for what need's done.
And talk about rolling the dice with someone's health and welfare but it happens so many times. "Look, this needs done. You're the only one available. Jump in there and do it, just be careful." Well, that's not adequate.
Next question. I believe you answered this at the top of the program, Mike, but, "Is qualified defined by a specific regulatory agency that has enforcement power, or is that determination largely left to discretion of the employer and its risk management practices?" Can you clarify that a little bit?
Mike: If you look in the National Electrical Code, if you look in the OSHA's directives, and you look in the 70E document, which everything that we're talking about here today is based on, it is almost a verbatim description. In fact, the only difference, in the National Electrical Code it just says skills and knowledge. When you get into OSHA, this is when they require the demonstrated skills and knowledge. But other than that word, it is verbatim. It is exactly how I defined it, as I did here at the beginning of this course. The tricky part about it is applying the main tenets of the definition, the demonstrated skills, the knowledge. But the safety training is actually easy. I mean, the safety document itself pretty much mandates what the required safety training has to be, because that's what the person requiring safety knowledge has to consist of.
But their overall, like their trade knowledge, their work history and everything else, that is probably the most difficult one to assess, from the perspective of a supervisor, because you have to have certain knowledge of this person's work past. You know, what tasks have you seen him, witnessed him perform in the past, and based on that, can you justifiably say that he possesses the skills for what you're asking him to do? So that definition itself is very specific and it's spelled out in many places in the industry. It's the interpretation of it, or better yet the application of it, to a given employee, that gets very challenging.
Right. And it looks like the end of our questions, Mike.
Mike: That's it. Wow. Well, I hope everybody got something out of it. I know the hour went by rather quickly for me, what they always do. Use judgment. Use a certain amount of responsibility in rolling these programs out and determining these people's qualifications. It's very easy, as a worker, to want to overstate your abilities, to overstate your qualifications. It's one the reasons why workers aren't allowed to determine on their own what their qualifications are. You have to look at what they say, what they've done, or whatever the grain of salt and compare it to what it is they're being asked to do. And it's not an enviable task in any way, shape or form, but it's one that has to be assigned to someone and these determinations made. I mean, it's in the interest of people's lives and limbs.
So that being said, folks, like I say, if you need to get a hold of me, my email address is firstname.lastname@example.org. Do not hesitate to contact me. I may not respond right away. If I'm in a class or traveling somewhere in the country I may not respond right away, but I will get back to you. I understand what some of you are up against. Have a happy holiday weekend, everybody. Be safe.