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Topic Title: Authorised Person Competancy
Topic Summary: HV Management
Created On: 04 January 2012 09:34 PM
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 04 January 2012 09:34 PM
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iie1001114

Posts: 11
Joined: 25 July 2008

We have 5 HV motors in our plant which need to isolated regularly for mechanical maintenance. These were isolated by Authorised Persons following a detailed switching schedual. Each of these AP's previously had HV competancy training. Due to a change in staffing new engineers with no compentancy training are currently being Authorised to carry out this switching by our Electrical head of department. Currently our head of department also does this switching he also has not had any SAP training. His view is this will make the job easier for the 3 SAP's on site.

Does anyone have views on using non HV trained personel doing the switching and isolation, or is it down to what you feel you should as it is aprivate network. Make the rules up as you feel.

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Woobs
 04 January 2012 10:49 PM
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dlane

Posts: 690
Joined: 28 September 2007

It is going to depend on what the requirements of your safety rules are. Do they require switching to be carried out by authorised personnel and who do they make responsible for sanctioning authorisations and the training identified for them?

Our safety rules specifically require any high voltage switching or testing for dead to be carried out by authorised persons only. Our procedures behind this identify the authorisation process and the initial and refresher training required in order to become and stay authorised. Our authorisations also need to be sanctioned by more than one senior site person, the AP also has to sit an authorisation interview.

It also depends on an assessment of what competency is required to carry out the switching actions and the how to recognise and avoid danger when it arises. In the UK any HV incident is reportable to the HSE, and one of the first questions they will ask is regarding training and competency to carry out the task.

Authorisation of an Electrical Engineer can sometimes create some issues. Some will see it as a challenge to their skill level and don't see why they should undergo authorisation training when it is them that will go and work on the switchgear.

As a site electrical engineer I was never authorised for carrying out HV switching and racking on energised circuits but when a breaker got stuck in one of the housings, it was me that had to go and free it up after quite an interesting conversation!

As I am now in a more senior position covering multiple sites I have actually let all my authorisations lapse and I cannot hold any permits or caary out any isolations or switching.

Kind regards

Donald Lane
 05 January 2012 12:00 AM
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Dave69

Posts: 447
Joined: 16 July 2011

surely the method statements will detail who can carry out these tasks and the risk assessments will show what training the AP needs to have in order to reduce the risk to a minimum.

The person authorising the engineers to carry out such tasks when they have not received the correct training is on a sticky wicket but that is no consolation to anyone involved in an incident as more than often HV doesn't give you a second chance
 05 January 2012 05:52 AM
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sfchew

Posts: 589
Joined: 10 December 2002

Competency is the ability to carry out the work efficiently and safely. In countries where it is legally required to carry out electrical work only by the competent person there is no possibility for anyone else to do it.

People who are not competent should not perform the tasks that require competency.

Some people are technically competent but do not possess legal competency qualifications. Management has to deal with such cases.

Regards
Chris Chew
 05 January 2012 09:18 AM
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westonpa

Posts: 1771
Joined: 10 October 2007

Originally posted by: sfchew

Competency is the ability to carry out the work efficiently and safely. In countries where it is legally required to carry out electrical work only by the competent person there is no possibility for anyone else to do it.

People who are not competent should not perform the tasks that require competency.

Some people are technically competent but do not possess legal competency qualifications. Management has to deal with such cases.

Regards

Chris Chew


Companies and people have to comply with the requirements of the relevant laws which apply, so it is not about should this or should that. With regards to UK H&S laws the 1974 Health and Safety at Work Act would set out the general requirements in this case and the Management of Health and Safety at Work Regulations 1999 would require a risk assessment. However motors are equipment and so the Provision and Use of Work Equipment Regulations 1998 would apply with regards to maintenance and isolations etc. The Electricity at Work Regulations 1989 would apply if the person was going to work in an electrical panel or on live equipment etc., however if the HV motor is properly isolated and locked off then it is primarily equipment, as it no longer has an electrical supply.

With regards to isolating The Electricity at Work Regulations 1989 require 'No person shall be engaged in any work activity where technical knowledge or experience is necessary to prevent danger or, where appropriate, injury, unless he possesses such knowledge or experience, or is under such degree of supervision as may be appropriate having regard to the nature of the work.'

The HSE state '10.The EAW Regulations contain no specific requirement for the written authorisation of competent persons, although authorisation may be required when necessary to avoid danger.'

The EAW1989 also provide for defence and state that 'it shall be a defence for any person to prove that he took all reasonable steps and exercised all due diligence to avoid the commission of that offence.'

The HSE prosecute based on the law and judges make their decisions based on what they interpret the words to mean.....note 'no specific requirement for the written authorisation of competent persons'.

The HSE guidence for Technical knowledge or experience for EAW1989 Reg 16. is:

'The scope of 'technical knowledge or experience' may include:
(a) adequate knowledge of electricity;
(b) adequate experience of electrical work;
(c) adequate understanding of the system to be worked on and practical experience of that class of system;
(d) understanding of the hazards which may arise during the work and the precautions which need to be taken;
(e) ability to recognise at all times whether it is safe for work to continue.'

It is for the relevant company to decide who is competent for this activity and providing they do this in a reasonable way there will be no accident and no prosecution. If that person cannot prevent danger or injury then they are not competent whereas if they can then they are competent. Competency has nothing at all to do with efficiency in this particular work activity.

Regards.
 05 January 2012 12:36 PM
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iie1001114

Posts: 11
Joined: 25 July 2008

Thanks for the information on different aspects, these all need to be looked at in greater detail with how we operate safely on site.

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Woobs
 05 January 2012 10:22 PM
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dlane

Posts: 690
Joined: 28 September 2007

Originally posted by: westonpa

The HSE state '10.The EAW Regulations contain no specific requirement for the written authorisation of competent persons, although authorisation may be required when necessary to avoid danger.'

The EAW1989 also provide for defence and state that 'it shall be a defence for any person to prove that he took all reasonable steps and exercised all due diligence to avoid the commission of that offence.'



I agree with your comments however, for a company large enough to have their own private HV network would it not be considered a "reasonable step" for them have a written authorisation scheme?

Kind regards

Donald Lane
 06 January 2012 09:41 AM
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westonpa

Posts: 1771
Joined: 10 October 2007

Originally posted by: dlane
I agree with your comments however, for a company large enough to have their own private HV network would it not be considered a "reasonable step" for them have a written authorisation scheme?
Kind regards
Donald Lane

Of course it could be but also it could be that other methods are also a 'reasonable step'. If a person is opening a panel and going inside and it's live then they would need to be more competent than someone required to turn off an isolator and lock it off, from the outside, because one is significantly more exposed to the hazard. Any person, who passes their driving test, can drive a potentially lethal piece of equipment on the road and which is capable of killing or seriously injuring people. The driving licence authorises people to drive the car but it does not make them competent to drive, that comes from training, assessment and then experience. The law requires a driving licence and that's the difference. It does not ask for written authorisation in the stated example in H&S because it also accepts that other methods can be 'reasonable'.

Take a look at the case 'Langridge v Howletts & Port Lympne Estates [1996]' and note what one of the highest courts in the UK decided and for something which most people would argue should not be allowed to happen. The defendant argued that it was reasonable to do what they did and the court decided in their favour and the decision was/is binding on all lower courts.....to this day! If a 'competent' person makes the relevant isolations and the relevant company took reasonable steps to ensure the person was competent in relation to the hazards and risks involved, then in this case they have complied with the requirements of the law....and that is the highest opinion which counts.

Regards.
 23 January 2013 02:20 PM
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rogerbrand

Posts: 26
Joined: 22 March 2002

Although this thread was last active 12 months ago it remains important since Competence is essential in all activities where there is danger (risk of injury).

The original question was associated with the mechanical maintenance of HV motors. The basic requirement here is to make sure that nothing can move that could cause injury whilst the work is being done. This will mean switching off, applying safety locks and caution notices at the point of isolation and possibly applying mechanical constraints such as locking bars. The person taking these measures needs to be Competent for the activities involved. Apart from operating the isolator, there should be no danger from electricity if nothing is exposed and the level of electrical competence required is relatively low.

Electrical maintenance presents a completely different set of criteria. Anyone working on or near electrical equipment must have sufficient technical knowledge or experience to avoid danger from burn, shock, arcing, fire and explosion. This will require a much higher level of electrical competence than that required for mechanical maintenance and will include the additional need to prove dead and in the case of HV equipment, apply earths and issue an electrical permit to work (PTW).

Both tasks require competence and it is important that this is assessed beforehand by someone qualified to do so. Written appointments then make clear what an individual can and cannot do as well as providing an important record.

Regards
Roger Brand

Edited: 23 January 2013 at 02:59 PM by rogerbrand
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