Both OSHA and the National Electrical Code require that only a “qualified person” perform the work. To be a “qualified person”, the worker must meet four requirements:
- Has the skills to perform the work. For example, knows how to use a DMM to verify voltage absence.
- Has the knowledge particular to that equipment. For example, understands how the robotic welder operates and how its systems interact.
- Has the safety training to recognize and avoid the hazards involved. For example, knows, among other things, how to lock out the kinetic energy sources before servicing the 40-ton punch press.
- Is authorized by the company to perform the work. For example, has a valid work order and permission from the Operations Department.
Unfortunately, it is commonly the case that the first three are merely assumed. Thus, it is often the case that the person doing the work isn’t a “qualified person.”
Skills. Very seldom is someone hired into maintenance with all the skills needed for the job. This means a skill assessment must be performed for each employee. It should include training certifications and practical demonstrations. The goal of it is not to disqualify people from working in Maintenance (though that may happen), but to determine which skills each employee has for the purpose of being a “qualified person” to perform specific work on specific equipment.
Knowledge. Having a solid general background is good, but it does not suffice. And just because a given maintenance tech has a lot of experience with various equipment in the plant does not mean they are familiar with this particular equipment. Good work procedures are helpful, but they do not explain the theory of operation or what quirks this equipment has. This knowledge does not come cheap and does not come quickly. Discussing the equipment’s operation with the operator, reading the manual, and watching the manufacturer’s videos are all part of gaining that knowledge.
Safety training. Part of this is particular to the location. Is it a Hazardous Location? Is there a chemical process nearby? Where are the emergency eyewashes and showers? What is the foot traffic? How is the lighting? Part of this is particular to the equipment. Where are the e-stops? What about safety interlocks? Much of this goes back to your safety program, and inside of that is your electrical safety program. Which, in part, means is it an Art. 120 job or an Art. 130 job?
Authorized. Did the Operations Department provide fully informed consent? Simply asking to do a PM is different from asking to do functional testing. Has Operations been advised of the scope, the safety requirements, and the expected duration? Is the authorization valid? Not if the person doesn’t meet the other three criteria. Is there an open and assigned work order for this work? If not, is there at least a verbal authorization from a supervisor who will follow up and create a work order, so the work is captured in the CMMS?
