IEEE TRANSACTIONS ON INDUSTRY APPLICATIONS, VOL. 54, NO.
1, JANUARY/FEBRUARY 2022
Identifying the Requirements for Qualified,
Unqualified, and Competent Persons
Electrical Safety Training
Dennis K. Neitzel
Abstract—This paper provides an understanding of what con-
stitutes a qualified person, an unqualified person, and a compe-
tent person. Also included are the training requirements for each
classification. The principles for performing a needs assessment, a
job/task analysis, and job hazard analysis are addressed as they
relate to the information gathering needed for the development of
an effective training program. This gathered information applies
to all personnel who are, or may be, exposed to electrical hazards,
and who may work on, near, or interact with the electrical systems
and equipment.
Index Terms—Competent person, electrical safety, electrical
safety program, maintenance, Occupational Safety and Health
Administration (OSHA), qualified person, regulations, skills and
knowledge, standards, training and unqualified person.
I. INTRODUCTION
HERE seems to be a misunderstanding in industry of what
T constitutes a qualified person, an unqualified person, and
a competent person, along with the training that is required for
each. A needs assessment and a job/task and hazard analysis
must be performed and the data are used to identify training
requirements for all personnel who are, or may be, exposed to
electrical hazards, and who may work on, near, or interact with
the electrical systems and equipment. Also identified are the
training requirements for the skills and knowledge that must
be considered for a person to be qualified. Training require-
ments for unqualified or nonelectrical personnel who may be ex-
posed to electrical hazards are also addressed. Properly trained
and qualified workers are required for performing maintenance
on electrical equipment. This paper provides an insight into
these training requirements and how this can reduce the risk of
employee injuries and fatalities.
II. QUALIFIED, UNQUALIFIED, AND COMPETENT PERSONS
One specific requirement that must be noted first, before any
training can be accomplished, is the definitions of qualified,
unqualified, and competent persons. The Occupational Safety
Manuscript received February 13, 2017; accepted July 11, 2017. Date of
publication August 16, 2017; date of current version January 18, 2018. Pa-
per 2017-CSC-0127, presented at the 2017 Industrial and Commercial Power
Systems Conference, Niagara Falls, ON, Canada, May 6–11, and approved for
publication in the IEEE TRANSACTIONS ON INDUSTRY APPLICATIONS by the
Codes and Standards Committee of the IEEE Industry Applications Society.
The author is with AVO Training Institute, Inc., Dallas, TX 75237 USA
(e-mail: dennis.neitzel@avotraining.com).
Digital Object Identifier 10.1109/TIA.2017.2741445
0093-9994 © 2022 IEEE. Personal use is permitted, but republication/redistribution requires IEEE permission.
See http://www.ieee.org/publications standards/publications/rights/index.html for more information.
5
, Senior Member, IEEE
and Health Administration (OSHA) in 29 CFR 1910.399 [1],
definitions, defines a “qualified person” for use with all electrical
safety regulations. This definition is provided here so there will
be no misunderstanding of what constitutes a qualified person
in industry. Unqualified and competent persons are also defined.
A. Qualified Person
One who has received training in and has demonstrated skills
and knowledge in the construction and operation of electric
equipment and installations and the hazards involved.
Note 1 to the definition of “qualified person”: Whether an employee
is considered to be a “qualified person” will depend upon various
circumstances in the workplace. For example, it is possible and,
in fact, likely for an individual to be considered “qualified” with
regard to certain equipment in the workplace, but “unqualified” as to
other equipment. (See 1910.332(b)(3) for training requirements that
specifically apply to qualified persons.)
Note 2 to the definition of “qualified person”: An employee who
is undergoing on-the-job training and who, in the course of such
training, has demonstrated an ability to perform duties safely at his
or her level of training and who is under the direct supervision of
a qualified person is considered to be a qualified person for the
performance of those duties.
The National Fire Protection Association (NFPA) 70E has
a similar definition of a qualified person; however, it expands
on the training part of the definition by stating: “has received
safety training on the hazards involved” [2].
B. Unqualified Person
1) One who is not qualified [2].
2) A person who is lacking the skills and experience needed
for a particular job [3].
3) A person not officially recognized as a practitioner of a
particular profession or activity through having satisfied
the relevant conditions or requirements [4].
4) Not competent or sufficiently knowledgeable to do some-
thing [4].
5) Lacking the proper or required qualifications: unqualified
for the job or task [5].
C. Competent Person
One who is capable of identifying existing and predictable hazards
in the surroundings or working conditions which are unsanitary,
hazardous, or dangerous to employees, and who has authorization to
take prompt corrective measures to eliminate them [6].
6 IEEE TRANSACTIONS ON INDUSTRY APPLICATIONS, VOL. 54, NO.1, JANUARY/FEBRUARY 2022
Understanding the difference between these classifications is
valuable when identifying training requirements and job func-
tions. The training requirements will be addressed later in this
paper.
III. TRAINING PROGRAMS
The question is often asked, “How do I develop an effective
training program?” This has always been a mystery, especially
to someone who has not been formally trained in curriculum
development. This paper addresses some of the basic concepts
for developing a training program and provides a good starting
point for most companies. There are literally volumes of material
and information on how to develop effective training programs
on the market today. This paper is not attempting to address
all of the philosophies surrounding curriculum development,
however, does address most of the basic concepts.
The typical method utilized for an effective training program
is the “Systematic Approach to Training” or SAT, which uti-
lizes the “Instructional Systems Design” or ISD methodology
for performing the analysis, design, development, implementa-
tion, and evaluation for a training program to meet the specific
needs of a company. The SAT is a methodology for managing
training programs. It is an orderly, logical approach to deter-
mining what people must know and do at a particular job or
in a specific profession. The systematic approach to training
ensures that people are prepared for their work by having the
necessary knowledge, skills, and attitudes to do their job. The
ISD provides a systematic procedure for identifying the job-
related skills and knowledge necessary for performance-based
training.
IV. NEEDS ASSESSMENT
This section addresses the first element of the analysis phase
of the ISD. Before any significant training can be developed and
implemented, an assessment must be conducted to determine
what is needed. The needs assessment involves relevant com-
pany personnel who are aware of the job requirements and all
applicable codes, standards, and regulations. Information that
is collected will provide insights into any past or present perfor-
mance problems that must be addressed in the training program.
This process can also be used to determine whether or not train-
ing is the solution to any problems that may exist. Other factors,
which affect performance, must also be recognized and consid-
ered. These other factors could include the quality of procedures,
human factors, management style, and work environment. Any
one or all of these factors may affect job performance.
The needs assessment will provide the starting point for the
job/task and hazard analysis and ultimately the design, develop-
ment, implementation, and evaluation of the training program
that meets the specific needs of a company.
V. JOB/TASK AND HAZARD ANALYSIS
This section addresses the final two elements of the analy-
sis phase of the ISD. Establishing proper job procedures and
training programs is one of the benefits of conducting job/task
analysis (JTA), as well as a job hazard analysis (JHA). To
do this, carefully study and record each step of a job, iden-
tify the tasks and elements that make up the job, identify ex-
isting or potential job hazards, and determine the best way
to perform the job along with reducing or eliminating the
hazards.
It is important to note that the JTA and the JHA information
listed below does not necessarily include all steps for every job in
the industry. It is also important that these analyses be conducted
for every job function in a company in order to identify all of the
steps necessary to work efficiently and safely, as well as develop
and implement the required training programs.
The typical steps for conducting a JTA are as follows.
1) Review available job information using existing standards,
reports, procedures, etc., to identify the general nature of
each job/task.
2) Write an initial job description for all affected personnel.
The most difficult part of the job description to develop is
a task inventory, which is comprised of a list of all tasks
that make up the job.
3) Identify the tasks. A task is defined as an observable,
measurable unit of work.
4) Organize task lists. The person evaluating the tasks may
sometimes find it helpful to categorize groups of tasks into
duty areas or specific job functions. The tasks performed
in a given duty or work area would comprise a job.
5) Select tasks that require specific training and/or detailed
analysis.
The typical steps for conducting a JHA are as follows.
1) Select jobs for analysis and prioritize them by type of
work and potential hazards.
2) Before beginning this analysis, look at the general condi-
tions under which the job is to be performed and develop
a checklist.
3) Most jobs can be broken down into a series of steps.
4) After the job steps have been recorded, examine each step
to determine potential hazards that might occur.
5) Determine the probable cause of the hazards.
6) Identify safety procedures and personal protective equip-
ment (PPE) for each hazard.
7) Revise the JTA as necessary based on the hazards.
A JHA can do much toward reducing accidents and injuries
in the workplace, but it is only effective if it is reviewed and
updated periodically. The frequency of review and update will
vary, depending on work condition changes, as well as revisions
to standards and regulations. OSHA identifies several areas to be
considered that would require review and update, new technol-
ogy, new types of equipment, or changes in procedures. Even if
no changes have been made in a job, hazards that were missed in
an earlier analysis could have been detected. It is recommended
that at least an annual basic review be conducted; in fact, OSHA
requires several annual audits, such as for energy control pro-
cedures in 1910.147 [7] and for work on electric power genera-
tion, transmission, and distribution lines and equipment found in
1910.269. [8] NFPA 70E, 110.1(I) requires the Electrical Safety
Program to be audited every three years due to the revision of
the standard every three years. It also requires an annual field
NEITZEL: IDENTIFYING THE REQUIREMENTS FOR QUALIFIED, UNQUALIFIED, AND COMPETENT PERSONS ELECTRICAL SAFETY TRAINING
work audit to verify that the principles and procedures of the
program are being followed. [2]
Any time a JTA or JHA is revised, training in the new job
methods, procedures, or protective measures must be provided
to all employees affected by the changes. A JTA or JHA can
also be used to train new employees on job steps and hazards.
The goal of any training program is to develop and maintain
an effective and safe work force. Utilizing the SAT and ISD
methodology can accomplish this goal.
Another important point is that effective training is not an
option; it is mandated by the OSHA in almost every regulation
dealing with all types of industry. As an example one specific
training requirement is from OSHA 29 CFR 1910.269(a)(2)(i),
which states the following [8].
(i)(A) Employees shall be trained in and familiar with the safety-
related work practices, safety procedures, and other safety require-
ments in this section that pertain to their respective job assignments.
(i)(B) Employees shall also be trained in and familiar with any other
safety practices, including applicable emergency procedures (such
as pole top and manhole rescue), that are not specifically addressed
by this section but that are related to their work and are necessary
for their safety.
(i)(C) The degree of training shall be determined by the risk to the
employee for the hazard involved.
This section also requires the following under paragraph (ii).
(ii) Each qualified employee shall also be trained and competent in:
A) The skills and techniques necessary to distinguish exposed live
parts from other parts of electric equipment,
B) The skills and techniques necessary to determine the nominal
voltage of exposed live parts,
C) The minimum approach distances specified in this section cor-
responding to the voltages to which the qualified employee will be
exposed.
D) The proper use of the special precautionary techniques, PPE,
insulating and shielding materials, and insulated tools for working
on or near exposed energized parts of electric equipment, and
E) The recognition of electrical hazards to which the employee may
be exposed and the skills and techniques necessary to control or
avoid these hazards.
NOTE: For the purposes of this section, a person must have this
training in order to be considered a qualified person.”
OSHA also requires the training to establish proficiency,
which would require hands-on training in order to be effective.
This requirement is also found in 1910.269(a)(2) in paragraphs
(vi) and (vii) below: [8]
(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 and shall introduce the
procedures necessary for compliance with this section.
(viii) The employer shall ensure that each employee has demon-
strated proficiency in the work practices involved before that em-
ployee is considered as having completed the training required by
paragraph (a)(2) of this section.
7
NOTE: Though they are not required by this paragraph, employment
records that indicate that an employee has successfully completed the
required training are one way of keeping track of when an employee
has demonstrated proficiency.
Performing a needs analysis, a JTA and a JHA will identify
the elements of an effective training program. These analyses
may indicate the need for a training program that is as simple
as computer-based or video training, or a training program as
complex as a combination of classroom and hands-on, or on-
the-job instruction. The more extensive the training program,
the better qualified the employee. It has been proven that the
most effective training programs available include a combina-
tion of lecture and hands-on instruction because the employee
has actually performed the task as part of the training.
VI. TRAINING QUALIFIED AND UNQUALIFIED EMPLOYEES
After completing the needs analysis, JTA, and a JHA, the next
challenge is to provide training to all employees, qualified, and
unqualified, to ensure that they understand the hazards of elec-
tricity, the regulations and standards that govern electrical safety,
how to control the electrical hazards, know and understand the
electrical safety program and procedures, and the proper PPE
that must be used. The information and data obtained through
these assessments and analyses are needed to develop training
programs for training qualified persons.
In addition to the requirements stated in these definitions,
NFPA 70E, Section 110.2, training requirements, states that
employees are required to be “trained to understand the specific
hazards associated with electrical energy,” “the safety-related
work practices,” and procedural requirements. These training
requirements are necessary to help protect employees from the
“electrical hazards associated with their respective job or task
assignments” as well as to “identify and understand the relation-
ship between electrical hazards and possible injury.” Training
in emergency procedures is also required when employees are
working “on or near exposed energized electrical conductors
or circuit parts.” OSHA goes on to state that “employees shall
be trained in and familiar with the safety-related work prac-
tices . . . that pertain to their respective job assignments” [9].
A. Qualified Persons
At a minimum, OSHA requires qualified persons to be trained
in and familiar with the skills and techniques necessary to distin-
guish exposed live parts from other parts of electric equipment,
the skills and techniques necessary to determine the nominal
voltage of exposed live parts, and the clearance distances speci-
fied in 1910.333(c) and the corresponding voltages to which the
qualified person will be exposed.
Note 1: For the purposes of 1910.331 through 1910.335, a person
must have the training required by paragraph (b)(3) of this section
in order to be considered a qualified person.
Note 2: Qualified persons whose work on energized equipment in-
volves either direct contact or contact by means of tools or materials
must also have the training needed to meet 1910.333(C)(2) [9].
8
In addition to these requirements, the NFPA 70E goes on to
state that qualified persons must be familiar with: [2]
1) special precautionary techniques;
2) PPE, including arc-flash;
3) insulating and shielding materials;
4) insulated tools and test equipment.
OSHA 1910.269 established a detailed training requirement
for qualified persons. Qualified persons must be trained and
competent in the following: [8]
1) safety-related work practices;
2) safety procedures;
3) other safety requirements;
4) applicable emergency procedures;
5) avoidance of the electrical hazards of working on or near
exposed energized parts;
6) the skills and techniques to distinguish exposed live parts
from other parts;
7) the skills and techniques to determine the nominal volt-
age;
8) specified clearance distances by voltage;
9) working safely on energized circuits;
10) demonstrate familiarity with:
a. proper use of special precautionary techniques;
b. PPE;
c. insulating and shielding materials;
d. insulated tools.
11) first aid and cardio pulmonary resuscitation (CPR) as
applicable;
12) hazards of flames and electric arcs, including the proper
clothing for these hazards.
OSHA and NFPA 70E further require the employer to de-
termine through regular supervision and through inspections
conducted on at least an annual basis that each employee is
complying with the safety-related work practices. Retraining is
required if the annual inspection indicates that the employee
is not complying with the safety-related work practices; there
is new technology, new types of equipment, or changes in pro-
cedures; or if the employee must employ safety-related work
practices that are not normally used. OSHA and NFPA 70E also
consider tasks that are performed less often that once per year
to necessitate retraining before the performance of the work
practice involved [2], [8].
B. Unqualified Person
An unqualified person is a person that does not meet the
training requirements of a qualified person. However, there are
a large number of unqualified or nonelectrical persons, who
may be exposed to electrical hazards or who use cord- and plug-
connected portable equipment and extension cords that would
require a level of electrical safety training. Electrical safety
training is not restricted to only electrical workers. Statistics
show that there are more nonelectrical people electrocuted ev-
ery year than electrical. The OSHA Directorate of Compliance
Programs, STD 1-16.7, Inspection Procedures and Interpreta-
tion Guidelines states,
In addition to being trained in and familiar with safety-related
work practices, unqualified employees must be trained in the in-
herent hazards of electricity, such as high voltages, electric current,
arcing, grounding, and lack of guarding. Any electrically related
safety practices not specifically addressed by Sections 1910.331
through 1910.335 but necessary for safety in specific workplace
conditions shall be included.
This requirement will cause an employer to evaluate the work-
place hazards of every employee to determine if there are any
other hazards that were not addressed in this standard. [10]
C. Competent Person
By way of training and/or experience, a competent person is
knowledgeable of applicable standards, is capable of identifying
workplace hazards relating to the specific operation, and has the
authority to correct them. Some standards add additional specific
requirements, which must be met by the competent person.
Competency is demonstrated, not certified.
1) Competent persons must be able to recognize hazards but
also be in a position to mitigate them.
2) One worksite can have multiple competent people or one
person who is competent in multiple areas.
3) There is no one who must have a recognized degree, cer-
tificate, or extensive experience and ability to solve the
identified problem—including possibly technical or engi-
neering knowledge.
D. Supervision and Management
Supervision and managements are also required to receive
electrical safety training because management ultimately bears
the burden of effectively administering the electrical safety pro-
grams. Their involvement in the development and implementa-
tion of an electrical safety program and the technician training
programs is vital to the success of these programs.
E. Safety Officers
Safety officers, including safety managers and inspectors,
require the same training as managers and supervisors because
they are essentially managing the overall safety programs of a
facility.
VII. SUMMARY
There must be a thorough understanding of what constitutes a
qualified person, an unqualified person, and a competent person,
along with the training that is required for each. A job/task and
hazard analysis must be performed and the data used to iden-
tify training requirements for all personnel who are, or may be,
exposed to electrical hazards, and who may work on, near, or in-
teract with the electrical systems and equipment. Also discussed
were the training requirements for the skills and knowledge that
must be considered for a person to be qualified. Training re-
quirements for unqualified or nonelectrical, as well as competent
personnel who may be exposed to electrical hazards was also
addressed. Properly trained and qualified workers are required
for performing maintenance on electrical equipment. This pa-
NEITZEL: IDENTIFYING THE REQUIREMENTS FOR QUALIFIED, UNQUALIFIED, AND COMPETENT PERSONS ELECTRICAL SAFETY TRAINING
per provided an insight into these training requirements and how
this can reduce the risk of employee injuries and fatalities.
This paper also included advice that is relevant to managers,
supervisors, and safety officers who are or may be involved in
the design, specification, selection, installation, commissioning,
maintenance, safety, or operation of electrical equipment. Some
organizations have industry-specific rules or guidance for safe
work practices, but they should ensure that all aspects electrical
safety are adequately covered and kept up-to-date. Other orga-
nizations that do not have this guidance will need to apply the
principles contained in the standards and regulations noted in
this paper, and develop training programs and safe work prac-
tices relating to their specific circumstances and activities.
REFERENCES
[1] Occupational Safety And Health Administration (OSHA), Electrical Stan-
dards, 29 CFR 1910, Subpart S, Feb. 14, 2007.
[2] Standard for Electrical Safety in the Workplace,” National Fire Protection
Association, NFPA 70E, 2015.
[3] Cambridge Academic Content Dictionary. Cambridge, U.K.: Cambridge
Univ. Press, 2016. [Online.]
[4] Oxford Dictionary, London, U.K.: Oxford Univ. Press, 2016. [Online.]
[5] The Free Dictionary by Farlex. [Online.]
[6] Occupational Safety and Health Administration (OSHA), 29 CFR 1926,
Subpart C, General Safety and Health Provisions, 1926.32 Definitions,
Jun. 30, 1993.
[7] The Control of Hazardous Energy (Lockout/Tagout), Occupational Safety
and Health Administration (OSHA), 29 CFR 1910.147, Sep. 1, 1989.
[8] Electric Power Generation, Transmission, and Distribution, Occupa-
tional Safety and Health Administration (OSHA), 29 CFR 1910.269, Jan.
31, 1994.
[9] Electrical Safety-Related Work Practices, Occupational Safety and Health
Administration (OSHA), 29 CFR 1910.331-.335, Aug. 6, 1990.
[10] Electrical Safety-Related Work Practices—Inspection Procedures and In-
terpretation Guidelines,” OSHA Directorate of Compliance Programs,
STD 1-16.7, Jul. 1, 1991.
9
[11] D. K. Neitzel and T. L. Gauthier, “Meeting electrical safety challenges,”
in Proc. IEEE IAS Elect. Safety Workshop, 2014, Art. no. ESW2014–28.
[12] D. K. Neitzel, “The basics of effective training,” PEARL News,
Spring 2003.
[13] D. K. Neitzel, “Identifying the requirements for qualified, unqualified,
and competent persons electrical safety training,” in Proc. IEEE/IAS
53rd Ind. Comm. Power Syst. Tech. Conf., 2017, pp. 1–6, doi:
10.1109/ICPS.2017.7945088.
Dennis K. Neitzel (SM’05) received the bachelor’s
degree in electrical engineering management in 1986
and the master’s degree in electrical engineering ap-
plied sciences in 1991.
He is currently the Director Emeritus with AVO
Training Institute, Inc., Dallas, TX, USA. He has
over 50 years of experience in the electrical industry
in various capacities, specializing in electrical equip-
ment and systems maintenance, testing, engineering,
inspection, and safety. He is a co-author of the Electri-
cal Safety Handbook, (McGraw-Hill, 2005). He has
authored, published, and presented numerous technical papers and magazine
articles on electrical safety, maintenance, and technical training.
Mr. Neitzel is a member of the American Society of Safety Engineers (ASSE),
the Association for Facilities Engineering (AFE), the International Association
of Electrical (IAEI), the Society of Naval Architects and Marine Engineers
(SNAME), and the National Fire Protection Association (NFPA). He is a certi-
fied Plant Engineer, certified Electrical Safety Compliance Professional, and a
certified Electrical Inspector—General. He is a past Chair of the IEEE-Industry
Applications Society Electrical Safety Workshop in 2012. He is a Principle
Committee Member as a Special Expert for the NFPA 70E, Standard for Elec-
trical Safety in the Workplace; Working Group Chair of IEEE Std. 3007.1-
2010 Recommended Practice for the Operation and Management of Industrial
and Commercial Power Systems, 3007.2-2010 Recommended Practice for the
Maintenance of Industrial and Commercial Power Systems, 3007.3-2012 Rec-
ommended Practice for Electrical Safety in Industrial and Commercial Power
Systems, and 45.5-2014 Recommended Practice for Electrical Installations on
Shipboard–Safety Considerations.