Does a competent person for fall protection require a training card?
Some trainers advertise “certified competent person” classes, while others issue competent person training cards. A few even claim their training cards are required by OSHA.
Some of these courses are quite valuable, especially for new employees. Fortunately for contractors with skilled employees and safe sites, this additional training is entirely optional. OSHA won’t force you to send employees to a “competent person” course and you won’t have to compile formal training documentation to prove that you have competent persons on site.
But before you write off these training courses altogether, let’s go over what a competent person is and who can benefit from these courses.
Who Counts as a Competent Person?
OSHA defines a competent person as:
“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.”
In other words, a competent person for fall protection is anyone who has knowledge of the job and the ability to reliably identify and correct fall hazards. The definition applies mostly to foremen, but any employee with those capabilities can be qualify as a competent person.
(Learn about 5 Fall Protection Hazards Many Workers Aren't Aware Of)
There’s no mention of certification in OSHA’s definition, and that’s because it’s not required. A worker can learn what they need to become a competent person by taking a course, but it’s not a status that’s achieved through a certificate or training card.
In fact, when OSHA evaluates the effectiveness of job safety training during an inspection, it will do so by observing the work procedure and interviewing employees. Training documentation plays no role in the assessment. If inspectors find uncorrected hazards, they assume that the contractor did not provide effective safety training. And they take the same approach to competent persons. If sufficiently knowledgeable personnel are available to correct hazards but are not doing so, no amount of training documentation will make up for that fact.
Moreover, a competent person doesn’t need expertise in all areas of fall protection. They only need to know the ones that are relevant to the work they do. An employee for a contracting company that only works on flat roofs and uses guardrails on every project could be a competent person on that contractor’s site even if they are not trained in personal fall arrest systems (PFAS).
(Find out more in Fall Protection and Leading Edges)
Now suppose that same company takes on a project that will require a few employees to wear a PFAS. Now, applied training with those devices is needed to be considered a competent person. Thankfully for our hypothetical company, many manufacturers of fall protection equipment will provide this training at no cost (provided you buy from them). After all, it’s in their best interest to have their products used safely and properly.
Getting the Right Fall Protection Training
When selecting fall protection training, make sure the contents of the course meet your needs. If it doesn’t, it’s a waste of your resources. If you’re not sure what a training program contains, you can ask questions or get a course description from the instructor.
And remember that a general fall hazard seminar might be ideal for new safety administrators in construction, but it’s not sufficient for employees who need to learn how to use shock absorbing lanyards for the first time.
At the end of the day, the goal is to ensure a construction site free of uncorrected hazards. Training will help you achieve that, but a third-party certification or training card is not required. If proper hazard controls are in place at all times, then a competent person must be present. And with that level of control, you’ll have a construction site any competent person would be proud to be a part of.
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