MUTLIPLE OVERALL SCORES = 4.0, 8.0 AND 6.0 AS LISTED IN THIS

ITEM DESCRIPTION SCORE COMPLIANT

YES NO IMP

2.1A QUALIFIED PERSON PROGRAM 4.0 X

2.1B QUALIFIED ELECTRICAL WORKER PROGRAM 8.0 X

2.2 ELECTRICAL SAFETY TRAINING

6.0

X

2.3 ELECTRICAL SAFETY RETRAINING X

2.4 EMERGENCY FIRST RESPONDER TRAINING X

2.5 EMERGENCY FIRST RESPONDER RETRAINING X

2.6 LOCKOUT / TAGOUT TRAINING X

2.7 JOB TASK TRAINING X

2.8 SKILL & KNOWLEDGE OBSERVATION X

2.9 QUALIFIED PERSON AND WORKER DOCUMENTATION

X 2.10 QUALIFIED PERSON AND WORKERANNUAL

INSPECTION

X

2.11 LIMITED TASK QUALIFIED PERSON TRAINING X

2.12 LIMITED TASK DOCUMENTATION X

2.13 UNQUALIFIED PERSON TRAINING X

2.14 UNQUALIFIED PERSON DOCUMENTATION X

2.15 HAZARDOUSE LOCATION TRAINING X

2.16 CONTRACTOR & VISITOR PROGRAM X

IMP= In Place, but Needs Some Improvement

Section 2 Overview

CalOSHA, OSHA and NFPA 70E requires that only a “Qualified Person” may work on or around exposed energized equipment and defines a “Qualified Person” as “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.”

Persons may be Qualified for one task, but not another. Qualified training as well as observation of skills and knowledge should be documented.

Section 2 Summary

Implementing a Qualified Person and / or Qualified Electrical Worker program is a confusing task for most employers. OSHA and CalOSHA tell you “what” to do, but not “how” to do it.

Implementing a Qualified Person / Qualified Electrical Worker program is up to each employer and there is no specific way to accomplish this. Because corporations and

organizations have a difficult time translating what OSHA or CalOSHA is stating, and because there are no specific written guidelines, few corporations or organizations have proper

Qualified Person / Qualified Electrical Worker programs in place. POLA is strong in some parts of this area, which only minor adjustments to be made. Other parts of this area are completely lacking by POLA at this time, but getting up to speed should be relatively easy as the core structures are already in place.

POLA C&M has implemented a Qualified Electrical Worker program for high voltage. The high voltage program meets nearly all points and only needs minor improvements.

While there is a high voltage program in place, there is no low voltage “Qualified Person”

program in place.

One problem that POLA has is the improper use of the term “Qualified Electrical Worker”, which is misapplied and leads to confusion for those that are most familiar with electrical safety requirements. POLA has used “Qualified Electrical Worker” as a status for someone who can demonstrate knowledge on high voltage switchgear and therefore, can work on all electrical equipment. Because POLA uses QEW as a status term, Qualified Person and low voltage programs have been comparatively ignored.

The phrase “it’s just low voltage” was heard multiple times, and cautions are dropped by many when working on low voltage equipment. Some PEMs and supervisors expressed that low voltage electrical work simply isn’t a big hazard or much to be too concerned about. While high voltage accidents are more deadly, the reality is that the low voltage equipment is the most likely place that an electrical accident will happen at the port, and the workforce doesn’t recognize this or always take the proper precautions.

Also as a result of a focus on high voltage and QEW as a general status term, individuals can be assigned to work on equipment they may not actually be a Qualified Person for, or that they should not be working alone. Some QEWs may have experience with high voltage switching on particular equipment, but may have no knowledge on working with Variable Frequency Drives (VFDs) or Programmable Logic Controllers (PLCs). Qualified Person and Qualified Electrical Worker programs need to be specific to equipment and tasks. Not all PEMs have been

thoroughly cross-trained on all electrical equipment.

POLA does a very good job of making certain that their PEMs receive the base training that they need. What is missing is some specific equipment or task specific training and the continuation of the cross-training. In particular, new equipment is installed at POLA and training on the new equipment is either not provided or is not deep enough. PEMs with electrical backgrounds almost universally stated that this is their number one need.

PEMs as a whole had the following gaps in their training:

• Not enough / deep enough equipment specific training.

• Emergency release methods and proper understanding of arc flash in electrical safety training.

• Boom Truck electrical safety training and Lift Truck electrical safety training.

• NEC / Los Angeles Electrical Code for maintenance technicians.

• Application of grounding and bonding on low voltage systems.

• Training on Hazardous Locations.

• Cross-Training is incomplete for some PEMs.

In addition to the Qualified Person and Qualified Electrical Worker programs for the PEMs, the C&M division needs to implement a program for Limited Task Qualified Persons and Unqualified Persons. HVAC technicians, janitors, gardeners, security guards and other similar personnel work on or around electrical equipment and need to either be a Qualified Person for the specific task they perform (i.e. closing breakers) or they need to be considered an

Unqualified person that is trained on how to recognized electrical hazards, but isn’t allowed to go within the limited approach boundary or arc flash hazard boundary to perform any work.

2.1 A QUALIFIED PERSON PROGRAM OVERALL SCORE = 4.0

Hazard Risk Rating

Item # Description of Deficiency

2 2.1A

2.1A Observation

The QEW program that C&M has implemented is specific only to high voltage and ignores low voltage >50v to 600v. There is no process in place to assure or document that workers are Qualified Persons when it comes to low voltage equipment. Without documentation, there is no evidence to indicate whether or not PEMS are Qualified Persons for particular pieces of low voltage equipment or for particular tasks concerning low voltage equipment.

References:

CalOSHA 2300

CalOSHA defines a Qualified Person as “a person, designated by the employer, 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”.

These persons have experience related to the construction and operational elements of electrical equipment/systems and routinely receive training on the specific hazards and precautions necessary to work safely on and around energized electrical equipment. Qualified Persons are intended to be only those who are well acquainted with and thoroughly conversant in operation and maintenance of electrical equipment/systems and the hazards associated with related work.