I need to chime in here as I deal with OSHA on a daily basis. There are many situations in which OSHA (or MSHA) states "...only qualified persons..." may perform such and such task. Very few cases do they demand a "certified" or "licensed" individual. This is simply because they leave it up to the employer to determine what it means to be "qualified".
It is usually left to facility management (whatever form that takes where you are) to make this determination. There is a reason for this...those that install, own, upgrade, operate or otherwise use equipment are in the best position to decide what "qualified" means.
There are instances when electricians are necessary and extremely valuable. There are other instances when only a limited amount on training is necessary to "qualify" an individual to perform certain tasks. Part of being "qualified" involves that person recognizing when the task demands someone with more training...again, to be "qualified" means to understand how far they can go.
Likewise, do not assume that an operator is unfamiliar with LOTO. In fact, if the machine LOTO'd is in their area, they BETTER be at least familiar with what it means...even if they're not "qualified" to perform the LOTO.
In our facilities, because of the requirement for operators to perform so many maintenance and adjustment tasks on our equipment, all of them are more than qualified to perform LOTO. At the least, they understand it's function and that they are not to tamper with LOTO'd machines.
You need to decide if your workers are qualified or if they can be trained properly to perform ANY task. It's part of any good Job Hazard Analysis (JHA).
Just MHO...
