Who is qualified to relamp an LED?

[kwired]

I don't think there is any such thing as light electrical work. It's not a defined term. If there is no permit required then why would a licensed individual be required to do the work?

This has the smell to me of some jurisdictional fight using safety as the wedge. If all they are doing is changing light bulbs, I just don't see that as a big issue. You can teach people to use ladders or whatever they are using to get to the fixtures, and electricians are going to have to be trained in that as well as janitors. The electricians that do the work are going to have to be trained to do the work just like the janitors would be. It is about being trained enough that you can do the work safely. It's not about what job title you have, but that might be something in the union contract, if there is a union involved.

By the way, were the electricians ever trained to use a broom? Maybe the janitors should complain that electricians are being under trained in cleanup tasks.

That is just it, from OSHA point of view it is about knowing the risks and safety procedures involved in pretty much any task, whether it be working live in some electrical apparatus, welding live pressurized natural gas piping, working with highly toxic materials, or sharpening pencils.

Requirements for licensing are usually local or even state government entity requirements and can cover anything from giving hair cuts to health care to the construction related tasks.

Who is allowed to do certain specific tasks also can be a union thing, though OSHA and local government requirements also still apply to said union members.

 

[jim dungar]

You started off by talking about revamping an LED, now you are talking about 'light' electrical work.

You need to decide what exact tasks need to be performed, then you can decide what training is needed to complete those tasks, finally you can determine what prior qualifications may be needed.

Spell checker strikes again. I meant to say relamping.

 

[jim dungar]

Actually never said revamping, my original post was just about relamping, big difference. Someone else used ther term "light" electrical work but it goes along the same lines. Who gets to determine who is qualified and while were at it who determines what "light" electrical work is?
I know there is no answer to these questions, just frustrating, might be easier to just go with the Sergeant Schultz response... I see nothing

My typo. I meant to stay you started with relamping.

But my point was what specific tasks do you want accomplished.
Changing a medium base screw in lamp in a desk fixture is not the same as changing 8ft tubes above a suspended ceiling grid 20ft in the air.

Over the years, OSHA and other agencies have made it clear that it is your employer's job to determine who is qualified to perform a task.

 

[mayanees]

We're going through something similar right now within our company. We do arc flash Studies and need to open energized panels for data collection. What qualifies a person to open energized panels?? Is it that they be a licensed electrician? How about a PE? We're a consulting engineering firm, so there are PEs here who believe they're qualified to open an energized panel.
What I think we're going to end up with is the requirement for folks to become Certified by NFPA as either a Certified Electrical Safety Compliance Professional (CESCP), Certified Electrical Safety Worker (CESW), or a Certified Electrical Safety Technician (CEST). This along with being observed by a "qualified" person so they can become qualified in the process. I'm a PE and a Master Electrician and a CESCP so I'll be responsible for the observation part.
So I think you can train folks to do relamping, but there will need to be a "qualification" process that includes an observation component.

 

[kwired]

We're going through something similar right now within our company. We do arc flash Studies and need to open energized panels for data collection. What qualifies a person to open energized panels?? Is it that they be a licensed electrician? How about a PE? We're a consulting engineering firm, so there are PEs here who believe they're qualified to open an energized panel.
What I think we're going to end up with is the requirement for folks to become Certified by NFPA as either a Certified Electrical Safety Compliance Professional (CESCP), Certified Electrical Safety Worker (CESW), or a Certified Electrical Safety Technician (CEST). This along with being observed by a "qualified" person so they can become qualified in the process. I'm a PE and a Master Electrician and a CESCP so I'll be responsible for the observation part.
So I think you can train folks to do relamping, but there will need to be a "qualification" process that includes an observation component.

Kind of a complex mess isn't it?

Would we ever advanced technologically to where we are right now if there was same rules (and everyone actually complied with them) on all this stuff back at the beginning of industrial revolution?

 

[nietzj]

We're going through something similar right now within our company. We do arc flash Studies and need to open energized panels for data collection. What qualifies a person to open energized panels?? Is it that they be a licensed electrician? How about a PE? We're a consulting engineering firm, so there are PEs here who believe they're qualified to open an energized panel.
What I think we're going to end up with is the requirement for folks to become Certified by NFPA as either a Certified Electrical Safety Compliance Professional (CESCP), Certified Electrical Safety Worker (CESW), or a Certified Electrical Safety Technician (CEST). This along with being observed by a "qualified" person so they can become qualified in the process. I'm a PE and a Master Electrician and a CESCP so I'll be responsible for the observation part.
So I think you can train folks to do relamping, but there will need to be a "qualification" process that includes an observation component.

Well I'm glad I'm not the only one dealing with this type of dilemma. There are all kinds of examples of folks working near or directly with electrical equipment with little or no experience. OSHA leaves the door wide open to this and just has a CYA statement that says must be "Qualified"
It would be nice if OSHA gave a little more direction to things such as:

*Who determines when an individual is qualified?
*Who does the training and what are the parameters?
*Is supervision required?

 

[kwired]

Well I'm glad I'm not the only one dealing with this type of dilemma. There are all kinds of examples of folks working near or directly with electrical equipment with little or no experience. OSHA leaves the door wide open to this and just has a CYA statement that says must be "Qualified"
It would be nice if OSHA gave a little more direction to things such as:

*Who determines when an individual is qualified?
*Who does the training and what are the parameters?
*Is supervision required?

But where does it stop?

Who trains the trainer?

Who supervises the supervisor?

IMO the intent is to address safety issues and have a plan how to deal with them. Nothing wrong with using already publicly available standards such as 70E for electrical safety. In fact AFAIK OSHA doesn't require use of 70E as your standard, but they won't really question it's content if you are using it vs if you wrote your own safety standard.

Somewhere that supervisor or trainer will be considered the designated person for such task. Is still possible to have unsafe conditions if they are doing a poor job of it, and that can still come under scrutiny by OSHA if poor management and poor training leads to injuries or deaths in the workplace.

 

[mayanees]

That brings us back to my question, is there any language in the NEC, OSHA somewhere that supports this quote, otherwisw it's just an opinion and that's the problem. If the janitor gets injured changing an LED lamp I'm guessing the lawyers would like to know who deemed this as safe for a non-licensed person to do this work. I would love to see something in writing to support this eiither way.

nietzj,
This all comes back to the OSHA General Duty clause that says the company must provide a safe place to work for employees, and employees must follow company rules. If your company were to have a fatal electrocution, OSHA would be on your doorstep tomorrow. OSHA would look to you for definition of your Electrical Safety Program (ESP) and whether or not it was followed. If you're not using 70E, the focus will be on whatever standard you're using and how it stacks up to 70E.
70E is definitive as to what needs to be done. I think it's currently over-the-top in terms of energized work limitations, given that it's only allowed if it's more dangerous to turn the bus off. But it is what it is, and it is improving with each edition.
I've worked for industrials who followed 70E, like Scott Paper, DuPont, P&G, General Foods, and they were always compliant. The electrical system was maintained on a regular basis, Power Studies were updated every five years, equipment was arc-flash labelled, trainings occurred every three years for everyone relative to their exposure. There's allot of cost for compliance, but it was always done.
Your company sounds big, actually huge with 25k employees, and they need to be in compliance with 70E at each facility, and as the disclaimer goes, or some standard that applies for electrical safety..
I have an NFPA LINK subscription and I searched some of the topics that apply, like licensed... zero results. Qualified.. there are 54.
A qualified person is defined as: One who has demonstrated skills and knowledge related to the construction and operation of electrical equipment and installations and has received safety training to identify the hazards and reduce the associated risk. The other mentions are mostly that a qualified person is used to ...
I preach that 70E compliance starts with completion of the Power Study, at which point maintenance is performed and arc-flash labels are applied. But that's what I do for a living! .. so I'm gonna say just that!

 

[nietzj]

70E is definitive as to what needs to be done. I think it's currently over-the-top in terms of energized work limitations, given that it's only allowed if it's more dangerous to turn the bus off. But it is what it is, and it is improving with each edition.

My old Safety Director and I would often argue this policy. He would say is it safer to de-energize and I would say it's safer to stay in bed, can we meet somwhere in the middle. Shutting down power in a lab research or hospital is very problematic.

 

[jim dungar]

Shutting down power in a lab research or hospital is very problematic.

If shutting off power is problematic, I hope the system is on a UPS. We have no control over when a weather or traffic event may cause an outage.
Inconvenience is not a reason not to not deenergize. Maintainability should be part of design requirements.

 

[Fred B]

If work is limited within a facility and not for external customers, many times it is treated same as a homeowner doing there own work. Only difference is involvement of OSHA or other health and safety regulatory agencies. When Employees are acting on behalf of an employer there is stricter safety consideration than would be for a homeowner, not that it is anymore risky, just responsibility for coverage in event of an incident.

Another consideration when a facility is that large is sometimes it becomes a union shop and it will have a say in who can do what sort of work. Even if not a Union shop, large facilities usually have very specific task divisions and by subjugating a task to a "cheaper" employee that is in most ways less qualified will cause an uproar. Particularly if the task is one that is coveted as an "easy job" comparatively speaking.

AFA a janitor, replamping I see that as different than changing a bulb, and requires more than just get a ladder and give it a twist. As others have made mention of there is more skills needed both for safety and for recognition of installation variables.

 

[GoldDigger]

If work is limited within a facility and not for external customers, many times it is treated same as a homeowner doing there own work. Only difference is involvement of OSHA or other health and safety regulatory agencies. When Employees are acting on behalf of an employer there is stricter safety consideration than would be for a homeowner, not that it is anymore risky, just responsibility for coverage in event of an incident.

Another consideration when a facility is that large is sometimes it becomes a union shop and it will have a say in who can do what sort of work. Even if not a Union shop, large facilities usually have very specific task divisions and by subjugating a task to a "cheaper" employee that is in most ways less qualified will cause an uproar. Particularly if the task is one that is coveted as an "easy job" comparatively speaking.

AFA a janitor, replamping I see that as different than changing a bulb, and requires more than just get a ladder and give it a twist. As others have made mention of there is more skills needed both for safety and for recognition of installation variables.

It has been getting harder.
It used to be almost anything with an Edison base screw socket was 120V, with very rare exceptions, and all fluorescent tubes were bi-pin with filaments at each end. Hard to go wrong.
Then the linear fluorescents separated into rapid start, high efficiency, single pin, etc which made relamping more complex and depended on someone ordering the correct replacement lamps for the fixtures in question. High efficiency lamps were not recognized as suitable for dimmable fixtures, for example.
Now we have at least four flavors of linear fluorescent LED replacements with different modifiications to the luminaires. At this point relamping is only a job for a general purpose janitor/maintenance worker if someone appropriately skilled has identified the correct replacement lamp for each fixture. (Mitigated somewhat by the hope that relamping will never be required!)

 

[nietzj]

It has been getting harder.
It used to be almost anything with an Edison base screw socket was 120V, with very rare exceptions, and all fluorescent tubes were bi-pin with filaments at each end. Hard to go wrong.
Then the linear fluorescents separated into rapid start, high efficiency, single pin, etc which made relamping more complex and depended on someone ordering the correct replacement lamps for the fixtures in question. High efficiency lamps were not recognized as suitable for dimmable fixtures, for example.
Now we have at least four flavors of linear fluorescent LED replacements with different modifiications to the luminaires. At this point relamping is only a job for a general purpose janitor/maintenance worker if someone appropriately skilled has identified the correct replacement lamp for each fixture. (Mitigated somewhat by the hope that relamping will never be required!)

This is exactly my thoughts as well, even for a seasoned electrician replacing lamps is no longer simple. Concerning safety, if power is off when changing lamps the worst that could happen is the new lamp or possibly the luminaire is damaged when reenerigized.

 

[kwired]

It has been getting harder.
It used to be almost anything with an Edison base screw socket was 120V, with very rare exceptions, and all fluorescent tubes were bi-pin with filaments at each end. Hard to go wrong.
Then the linear fluorescents separated into rapid start, high efficiency, single pin, etc which made relamping more complex and depended on someone ordering the correct replacement lamps for the fixtures in question. High efficiency lamps were not recognized as suitable for dimmable fixtures, for example.
Now we have at least four flavors of linear fluorescent LED replacements with different modifiications to the luminaires. At this point relamping is only a job for a general purpose janitor/maintenance worker if someone appropriately skilled has identified the correct replacement lamp for each fixture. (Mitigated somewhat by the hope that relamping will never be required!)

But most those changes you mentioned still didn't have much impact on how dangerous the task might be to the employee changing the lamp.

Wrong lamp selection might mean damage that is not easily repairable to the lamp or ballast/driver but not really much of a difference in any dangers to the employee changing the lamp. OSHA won't care if it cost you the price of that damaged lamp, they do care if the employee is going to be injured if they don't know how to protect themselves from hazards to themselves involved with the task.