Part 212 min

2.1 What 'qualified person' actually means

Almost every restriction in the electrical standards hangs on one word. Who may work on energized parts, who may come within a certain distance of an overhead line, who may enter a room with exposed live parts, who may verify that a circuit is dead — all of it turns on whether the person is a qualified person. It is worth knowing exactly what that word means, because it does not mean what most jobsites think it means.

1 The definition, in full

29 CFR 1910.399 defines it in one sentence: a qualified person is "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."

Three parts, and all three have to be true. Received training — someone taught them. Demonstrated skills and knowledge — they showed it, to someone able to judge. In the construction and operation of the equipment and the hazards involved — of that equipment, not electricity in the abstract.

Received training

Demonstrated skills and knowledge

On that equipment and its hazards

All three, or none

Nothing in that definition mentions a license, a card, a union book, a job title or a number of years. Those things often accompany qualification and none of them is qualification. An electrician who has never worked on 4,160-volt switchgear is not qualified on that switchgear because his license says electrician.

2 Note 1: qualified is per equipment, not per person

The definition carries two notes, and the first one is the sentence that most jobsites have never read. Note 1 to the definition in 1910.399 makes clear that whether an employee is considered a qualified person depends on the circumstances: a person can be qualified with respect to certain equipment and work methods and be unqualified for others.

So "are you qualified?" is not a yes-or-no question about a person. It is a question about a person and a piece of equipment and a task. The right version is: qualified on what? The employer answers it, records it, and reviews it when the equipment changes.

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

3 Note 2: the trainee, and the words "direct supervision"

Note 2 handles apprentices and anyone learning on the job. An employee who is undergoing on-the-job training, who in the course of that training has demonstrated an ability to perform duties safely at their 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.

Read the three conditions together, because they get separated in practice. Demonstrated ability at their level. Direct supervision by a qualified person. Qualified only for those duties. A trainee sent to a panel alone because the qualified person is on the other side of the plant fails two of the three, and is no longer covered by that note.

4 Qualified person, competent person, and why they are not synonyms

Construction has a second term that gets used interchangeably and should not be. A competent person, under 29 CFR 1926.32(f), is one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.

Two words, two different tests
	Qualified person	Competent person
Defined in	1910.399 (general industry); 1926.449 for construction Subpart K	1926.32(f)
Core test	Training plus demonstrated skills and knowledge on the equipment and its hazards	Ability to identify hazards, plus authority to correct them promptly
Authority required?	Not part of the definition	Yes — authorization to take prompt corrective measures
Where you meet it in this course	Energized work, verification, approach distances	Implementing the assured equipment grounding conductor program — 1926.404(b)(1)(iii)(B)

The practical difference: a qualified person may be the best technician on site and have no authority to stop anything. A competent person must be able to stop it. Some people are both; the standards do not assume it.

One wording detail is worth knowing, because it comes up in arguments. Construction Subpart K has its own, shorter definition at 29 CFR 1926.449: a qualified person is "one familiar with the construction and operation of the equipment and the hazards involved." The general industry definition in 1910.399 adds the part that decides most disputes — "has received training in and has demonstrated skills and knowledge". Where an employer works under both, the safer reading is the one that requires the demonstration, and it is the one every serious electrical safety program uses.

5 Three tests a jobsite can actually run

1
Name the equipment. "Qualified" with no object is a red flag. Qualified on what — this panel, this voltage class, this task?
2
Ask who watched them demonstrate it. Training alone does not meet 1910.399. Somebody had to see the skills and be able to judge them.
3
Check the three skills of 1910.332(b)(3). Can they distinguish exposed live parts, determine the nominal voltage of those parts, and state the clearance distances for that voltage? Those are the next chapter, and they are not optional extras.

Common mistake: treating a completed OSHA 10 or OSHA 30 card as qualification. Those are outreach awareness programs. They do not assess skills on equipment, they are not tied to a voltage class, and no OSHA standard treats them as making anyone a qualified person.

6 And this course does not make you one

Since the definition requires demonstrated skills on equipment, no online course can produce a qualified person, including this one. What a course can do is make you accurate about the boundary — so that when someone says "you're fine, just hold this cover", you know that the standard has already answered that question and the answer was no.

The rest of Part 2 is about that boundary from the other side: what training you are owed whether or not you are qualified, what an unqualified person is actually allowed to do, and how the distance is measured and marked.

7 Why the line is drawn there at all

It is worth understanding why OSHA restricts energized work to a demonstrated skill set rather than to a licence or a job title. Electricity gives no feedback before the injury. There is no smell, no noise, no visible change to warn a person that the part they are about to touch is energized, or that the cabinet they are about to open has line-side terminals that stay live with the main breaker off. Everything protective has to happen in someone's head, in advance.

That is exactly what 1910.332(b)(3) is describing when it requires a qualified person to be able to distinguish exposed live parts from other parts, determine the nominal voltage, and know the clearance distances for that voltage. Those three skills are the substitute for a warning the hazard does not provide. A person who has all three sees a different panel than a person who has none — same metal, entirely different information.

It also explains why the status is per equipment. The internal layout of a motor control center, the location of line-side terminals in a fused disconnect, the behavior of a variable frequency drive's DC bus after the power is off — none of that transfers from one manufacturer's gear to another's. Familiarity is what the standard is buying, and familiarity is specific.

On the job: the most quoted example is the drive that has been off for ten seconds. Its DC bus capacitors may still hold a lethal charge, which is why 1910.333(b)(2)(ii)(C) requires stored electric energy that might endanger personnel to be released, capacitors discharged, and high capacitance elements short-circuited and grounded. Somebody who does not know that a drive stores energy is unqualified on drives, whatever else they can do.

Key takeaways

1910.399: a qualified person 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: qualification is per equipment and work method — a person can be qualified for some and unqualified for others.
Note 2: a trainee under the direct supervision of a qualified person, who has demonstrated ability at their level of training, is qualified for those duties only.
A license, a job title, a card or years of service is not the test the standard uses.
Competent person (1926.32(f)) is a different word: identifying hazards plus the authority to correct them promptly. The assured grounding program needs one.
The useful question on a jobsite is never "are you qualified" but "qualified on what, and who saw you demonstrate it".

Free educational content — not OSHA-authorized training, no certificate or card issued. Follow your employer's program and the standards cited.