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Does a competent person for fall protection require a training card?

Maurizio Delcaro
Profile Picture of Maurizio Delcaro

Maurizio’s interesting career experiences have convinced him that a strong commitment to operational efficiency at all levels is the greatest factor in maximizing safety and productivity. He has been an EHS administrator, construction safety consultant, college instructor, ergonomics specialist, project manager at environmental remediation sites involving radioactive materials, and has worked for OSHA. He has served on boards of directorship and committees and speaks frequently at conferences and conventions.

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Q:Does a competent person for fall protection require a training card?

Some trainers advertise “certified competent person” classes. Others issue competent person training cards and a few among them may even claim their training cards are required by OSHA. Some of these courses are quite valuable, especially for new employees. But, fortunately for contractors with skilled employees and safe sites that don’t feel additional training is a need, OSHA does not force them to send employees to a competent person course to receive formal training documentation.

A competent person is identified by job knowledge and reliable correction of fall hazards; this status is not achieved by way of a training certificate or card. Defined by OSHA, a competent person 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.” OSHA’s definition applies mostly to foremen, but any sufficiently capable employee can be deemed a competent person.

When OSHA evaluates the effectiveness of job safety training during an inspection, the evaluation is based on observations of work procedures and employee interviews; training documentation itself plays no role. If employees are exposed to uncorrected fall hazards, then OSHA can justifiably assume that the contractor did not provide effective safety training. And, this same treatment applies to those considered competent persons; are they correcting hazards? If sufficiently knowledgeable personnel are available to correct hazards, but are not doing so, then there is a management deficiency that no amount of training documentation can correct!

A competent person for fall protection doesn’t need expertise with all things fall protection; there is no need to master techniques that will never be utilized. If XYZ Contracting works only on flat roofs and always uses guard rails, then competent persons at XYZ’s sites don’t need familiarity with personal fall arrest systems (PFAS).

But, let’s say XYZ has an upcoming project that requires a few employees to wear PFAS. In this scenario, applied training with the devices selected for the project is a definite need. I always advise contacting the manufacturer because many will provide this training at no cost when you buy their products; it is in their best interest when their products are used properly and safely.

When selecting fall safety training, generally, ensure the content meets your needs. If it does not, then corporate resources will be wasted. Ask questions and obtain a course description from the instructor. A general fall hazards seminar may be ideal for a new safety administrator in construction, but it would be insufficient for employees who need to learn how to properly utilize shock absorbing lanyards for the first time.

At the end of the day, a construction site free of uncorrected hazards is the goal. And, it’s why OSHA adopted their standard definition of a competent person. But, a third-party certification or training card is not required. If proper hazard control is taking place at all times, then by definition there must be a competent person present. And, we’ll have a construction site that any competent person would be proud to be a part of.

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