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Toolbox talk · 10 min · Electrical

Qualified Person and Energized Work

Hazards: Electrocution from working on parts that were never deenergized · Contact with a circuit re-energized by someone else · Unqualified worker performing a qualified person's task · Burns from an arc during troubleshooting

Why it matters

OSHA does not treat energized work as a normal way to work. 1910.333(a)(1): live parts an employee may be exposed to are deenergized before the work. Live work is the exception, and the employer has to demonstrate why — deenergizing would introduce additional or increased hazards, or it is infeasible because of equipment design or operational limitations.

On October 24, 2020, an electrical contractor's employee on a plant project was in the turn-on phase for exhaust fans (OSHA Accident Search, Summary Nr 130703.015). He accessed an energized 480-volt panel without arc flash rated PPE, contacted a live circuit and was electrocuted. He was an electrician. Being in the trade is not the same as being qualified on that panel, that day.

Key points

  • Dead first, every time. 1910.333(a)(1). Live work needs a demonstrated reason — added hazard or infeasibility — not a schedule.
  • "Turned off" is not "verified dead". 1910.333(b)(2)(iv): a qualified person tests the circuit and checks for induced voltage and backfeed first.
  • Qualified is per equipment. 1910.399, Note 1: qualified on one piece of equipment, unqualified on another. Ask which one you are today.
  • Qualified means three specific skills. 1910.332(b)(3): tell exposed live parts from other parts, determine the nominal voltage, and know the clearance distances of 1910.333(c) for that voltage.
  • Unqualified people still get trained. 1910.332(b)(1)-(2): the practices that pertain to your job, plus anything else needed for your safety. Not knowing is not a defense the employer has.
  • Tags mark the line. 1926.417: deenergized equipment is rendered inoperative and tagged at every point it can be energized from.

Do / Don't

Do

  • Ask who the qualified person is before the task, not during it.
  • Say out loud when a job is outside what you were trained on.
  • Test the tester, test the circuit, test the tester again.
  • Leave every tag and lock exactly where you found it.

Don't

  • Work it live because shutting down would cost the shift.
  • Assume a breaker labeled off means the conductors are dead.
  • Hold the light, hold the cover or hand tools into an open energized panel.
  • Treat "I've done it a hundred times" as a qualification.

Quick site check

  • Is any energized work planned on this site today, and is the reason it cannot be shut down written down anywhere?
  • Point at the disconnect for the equipment you are working on. Can everyone here find it?
  • Are the tags on our deenergized circuits still legible and still attached at every point of possible energization?
Discussion — ask the crew
  1. Name one task you have done on this site that you now think should have been done by a qualified person.
  2. When we say a circuit is dead, who tested it, with what, and did they test the tester first?
  3. Who here is qualified on which equipment? Are we all qualified on the same things, or only on some?
  4. What did our last energized job look like — was there a written reason the circuit could not be shut down?
  5. If a panel is tagged and you need that circuit today, who do you call, and what is the answer if they cannot be reached?
Refs: 29 CFR 1910.333(a) — Deenergized parts, the two exceptions and the 50-volt note; (b) lockout and tagging; (c)(2) qualified persons · 29 CFR 1910.332 — Training: content for unqualified persons, and the three additional items for qualified persons · 29 CFR 1910.399 — Definition of qualified person, with Notes 1 and 2 · 29 CFR 1926.416(a) and 1926.417 — Protection of employees near circuits; tagging of controls, equipment and circuits · OSHA Accident Search — Summary Nr 130703.015, event date 10/24/2020Sign-in sheet included in the printed version

Frequently asked questions

1910.399 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. Note 1 adds that a person can be qualified for one piece of equipment and unqualified for another.

Yes, but only where the employer can demonstrate that deenergizing introduces additional or increased hazards, or is infeasible due to equipment design or operational limitations, under 1910.333(a)(1). Then 1910.333(a)(2) requires other safety-related work practices, and (c)(2) limits the work to qualified persons.

1910.333(a)(1) allows live parts operating at less than 50 volts to ground to stay energized if there is no increased exposure to electrical burns or to explosion due to electric arcs. It is a narrow exception, not a general rule that low voltage is safe.

1910.332(b)(1) requires training in the safety-related work practices of 1910.331 through 1910.335 that pertain to their job, and (b)(2) adds any other electrically related practices necessary for their safety. Training may be classroom or on the job, with the depth set by the risk (1910.332(c)).

Note 2 to the definition in 1910.399 says an employee undergoing on-the-job training who has demonstrated an ability to perform duties safely at their level of training, and who works under the direct supervision of a qualified person, is considered qualified for those duties only.

Sources & references

Content checked against these sources — last reviewed August 28, 2026.

Results are estimates for planning purposes and do not replace a competent person's evaluation or an engineer's design. Follow the OSHA standards that apply to your work and your employer's written program.

By — Editorial team of SteelToeTools.com (published by LSEA SAS) Updated