The phrases “competent person” and “qualified person” are often used in the safety industry, but confusion persists as to how the two relate to, and differ from, one another.
Compliance with OSHA standards is essential to keeping employees safe in the workplace. While most businesses strive to be OSHA compliant, some run into difficulties in doing so due to their lack of understanding the administration’s standards. Competent and qualified persons are one such area where confusion continues to persist, as OSHA’s regulations fail to get into the nitty-gritty of how each role operates and interacts with the other outside of their accepted definitions. While the competent person designation is also required under OSHA for silica and confined space applications in construction, the confusion is really between competent and qualified persons for fall protection.
Here we examine the differences and similarities between competent and qualified persons to help clear up some of the confusion that persists in their roles in the workplace.
How Does OSHA Define a Competent Person and a Qualified Person?
As defined by OSHA, a competent person is someone 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 [29 CFR 1926.32(f)].”
A qualified person, on the other hand, is someone who “by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project [29 CFR 1926.32(m)].”
While the above definitions seem straightforward enough, their vagueness can become problematic in real life application.
Who is a Competent Person?
The term “competent person” is used in many Occupational Safety and Health Administration (OSHA) standards and documents. By way of training and/or experience, a competent person is knowledgeable of applicable standards and is capable of identifying workplace hazards relating to the specific operation and has the authority to correct them and stop work if necessary. Some standards add additional specific requirements, which must be met by the competent person. Competency is demonstrated, not certified.
- Competent persons must be able to recognize hazards but also be able to mitigate them.
- One worksite can have multiple competent people or one person who is competent in multiple areas.
- Competent persons are not required to have a recognized degree, certificate, or extensive experience.
However, a lack of a degree or certification does not mean that competent persons completely forego formal training. Competent person training classes allow employers to easily designate employees into the role, and individuals working in construction or general industry may want to consider taking classes in the areas of:
- Fall protection
- Confined spaces
- Fall protection for tools
Training classes can take place in a variety of locations and will typically take one half-day to two days of in-person training to complete. 3M offers competent person training classes that can be taken on-site or at a designated 3M facility. For a complete listing of all competent person training classes currently available to take through 3M, visit the PPE Training and Education site.
Competent person status is not conferred just by completing the training classes. Employers must give their employees the authority to take corrective measures and then declare them to be a competent person. Without this authority, an individual who takes the competent person classes possesses the knowledge, but not the necessary authorization, to be a competent person.
Even after someone is given the authority to correct workplace hazards, they are not qualified to design actual solutions to fix them. Take fall protection, for example. A competent person knows that an employee not tying off to a lifeline is a safety hazard and has the authority to stop work until the person does so. They cannot, however, install the lifelines workers need to tie off to because only a qualified person can do this.
Who is a Qualified Person?
A qualified person is one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.
Example: Residential Construction
A competent person must be able to identify hazards within the construction jobsite and solve those issues or take action to stop the work until the issues can be resolved.
A qualified person has the knowledge to design and supervise the installation of the protective fall protection systems to be used on that jobsite.
It is possible for the competent person to also perform as the qualified person, but they must meet the criteria in both definitions to perform as both.
These definitions provide that a competent person must have the authority to take prompt measures to eliminate hazards at the work site and have the experience to be capable of identifying these hazards.
Who is a Qualified to Teach?
Although common, a qualified person is not the only person who can train workers on fall protection hazards and equipment. A designated competent person can also be a fall protection trainer if they meet all the qualifications for trainers and competent persons outlined in ANSI/ASSE standards. According to OSHA’s letter of interpretation to Mr. Daniel Shipp, August 31, 2017, the ANSI/ASSE construction and general industry standards have the same requirements.
Under ANSI/ASSE, competent persons are responsible for the supervision, implementation, and monitoring of fall protection programs and, for this reason, must undergo training on:
• Applicable fall protection standards and regulations;
• Surveying fall hazards;
• All equipment and practices applicable to the scope of work;
• Inspecting fall protection equipment components and systems;
• Assessing fall protection systems and components to determine whether they are safe for use; and
• Implementing fall protection and rescue procedures (ANSI/ASSE Z359.2-2017, §5.3).
As well as being competent in training techniques and methods appropriate to adult learning, ANSI/ASSE specifies that fall protection trainers are required to possess subject matter expertise, training experience, and technical knowledge in the subjects they teach through training, education, experience, and continued education (ANSI/ASSE Z490.1-2016, E5.1.1 and E5.1.2).
By fulfilling the above ANSI/ASSE requirements for competent persons and trainers, an individual is not only able train others on fall protection hazards and equipment, but is also considered to be a qualified person under OSHA’s standards.
Why Does This All Matter?
As the fall protection example above shows, competent and qualified persons have distinct roles in the workplace. While the competent person ensures the safe use of systems, the qualified person designs or installs engineered systems. The appointment of qualified and competent persons is the responsibility of employers, so it is crucial that they understand the roles and when each is needed. By better understanding the key differences and similarities between competent and qualified persons, employers can ensure that their worksite is safe and OSHA compliant.
If you still have questions about competent and qualified persons or are looking to sign up for training classes, we can help. Visit the PPE Training and Education site to learn more and request information.