OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

September 9, 1993

Mr. Steve Trawick Director,
Occupational Safety and Health
United Paperworkers International Union
P.O. Box 1475
Nashville, Tennessee 37202

Dear Mr. Trawick:

This is in response to your May 6, letter requesting interpretation of Occupational Safety and Health Administration's (OSHA's) electrical standards. Specifically, you requested clarification on employee training requirements to perform work on electrical equipment including servicing and maintenance in the workplace. Please accept our apology for the delay in responding.

The electrical standards at 29 CFR 1910 Subpart S include employer requirements for employee safety with respect to electrical hazards in general industry workplaces. According to subsection 1910.332(a), employees who face a risk of electric shock or other electrical hazards that are not reduced to a safe level by the electrical installation requirements of sections 1910.303 through 1910.308, must be trained in electrical safety- related work practices as required by sections 1910.331 through 1910.335. By subsection 1910.332(a), employees are delineated as either qualified persons or unqualified persons when working on or near exposed energized parts. Qualified persons have training, whereas unqualified persons have little or no training, in avoiding the electrical hazards of working on or near exposed energized parts. Training requirements for "qualified persons" and "unqualified persons" are contained in section 1910.332.

According to paragraph 1910.333(c)(2), only qualified persons may work electric circuit parts or equipment that have not been deenergized under the lockout/tagout provisions of subsection 1910.333(b). These qualified persons shall be capable, as determined by their electrical knowledge and skills, of working safely on energized circuits. This capability includes familiarity with the proper use of special precautionary techniques, personal protective equipment, insulating and shielding materials and insulated tools. Also, this capability includes familiarity with the construction and operation of the equipment and the electrical hazards involved, in accordance with the definition of qualified persons in section 1910.399.

By paragraph 1910.334(c)(1), only qualified persons may perform testing work on electric circuits or equipment. As noted in the preceding paragraph, these qualified persons shall be capable of performing work safely on energized circuits.

Thank you for your interest in Occupational Safety and Health. If we can be of further assistance, please contact us.


Roger A. Clark, Director
Directorate of Compliance Programs