Is OSHA's "qualified person" for electrical work the same as a licensed electrician? For anyone working toward electrician licensing, this explainer sets out what OSHA's electrical rules say a qualified person is. It does not cover electrician licensing rules in any state. Nothing here describes a rule change.
Who may work on energized parts
In general industry, 29 CFR 1910.333(c) covers work near live parts. Paragraph (c)(1) states: "This paragraph applies to work performed on exposed live parts (involving either direct contact or contact by means of tools or materials) or near enough to them for employees to be exposed to any hazard they present." (The work-practice rules in 1910.331 through 1910.335 also have their own scope section, 1910.331, which this post does not cover.) Paragraph (c)(2) states: "Only qualified persons may work on electric circuit parts or equipment that have not been deenergized under the procedures of paragraph (b) of this section." It continues: "Such persons shall be capable of working safely on energized circuits and shall be familiar with the proper use of special precautionary techniques, personal protective equipment, insulating and shielding materials, and insulated tools."
How OSHA defines a qualified person in general industry
The definition for the electrical subpart is in 29 CFR 1910.399: "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."
The definition is built on training and demonstrated skills and knowledge. It does not mention a license.
Two notes attached to the definition matter in practice:
- Qualified is equipment-specific. Note 1 states that "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."
- Trainees can count. Note 2 states: "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 minimum training for a qualified person
The training section has its own scope. 29 CFR 1910.332(a) states: "The training requirements contained in this section apply to employees who face a risk of electric shock that is not reduced to a safe level by the electrical installation requirements of §§ 1910.303 through 1910.308."
For those employees, 29 CFR 1910.332(b)(3) says qualified persons, "(i.e., those permitted to work on or near exposed energized parts)", shall, at a minimum, be trained in and familiar with:
- "The skills and techniques necessary to distinguish 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 specified in § 1910.333(c) and the corresponding voltages to which the qualified person will be exposed."
Note 1 to that paragraph states: "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."
On the type of training, 1910.332(c) states: "The training required by this section shall be of the classroom or on-the-job type. The degree of training provided shall be determined by the risk to the employee."
Construction uses its own definition
In construction, 29 CFR 1926.449 gives the definitions for the electrical subpart (Subpart K). It states that its definitions for "approved" and "qualified person" apply "instead of the definitions given in § 1926.32, to the use of these terms in subpart K." Its definition reads: "Qualified person. One familiar with the construction and operation of the equipment and the hazards involved."
This matters because the general construction definition in 29 CFR 1926.32 is different. It says "Qualified means one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project." For Subpart K only, 1926.449 replaces that wording with its own; 1926.32 still applies to "qualified" elsewhere in Part 1926.
So is a licensed electrician automatically "qualified"?
The OSHA sections quoted here do not say so. They do not mention electrician licenses at all. Under 1910.399 and 1910.332, being "qualified" turns on training and demonstrated skills and knowledge for the particular equipment and hazards, and Note 1 says a person can be qualified for some equipment and not for other equipment.
None of these definitions mentions a license. The general construction definition in 1926.32 does list "a recognized degree, certificate, or professional standing" as one route to being qualified, but 1926.449 replaces it for the electrical subpart. These OSHA sections do not address whether a license is required to do electrical work; this post does not cover any state's licensing rules.
Study the OSHA electrical rules
Our study guides quote the OSHA electrical rules section by section: general industry electrical (Subpart S) and construction electrical (Subpart K). Electrician licensing is a planned topic on goraedu; see all certifications for its status.
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