OSHA Training: Competent vs Qualified

by Karen

In the healthcare world, physicians must be licensed to practice. A physician’s license documents the fact that the person holding the license has obtained a certain type of knowledge and has been able to demonstrate that knowledge.

But in many other professions, things aren’t always as cut and dried. Licenses aren’t required for many types of jobs, even those that are high-risk. This can make it harder to determine if someone actually has the skills, knowledge, experience and qualifications necessary to perform a task.

Employee safety is one of these areas. The Occupational Safety and Health Administration (OSHA) does not issue licenses. Instead, to be compliant with various regulations, they require certain types of employees to be “competent” or “qualified” to perform various tasks.

When OSHA regulations require an employee to be competent or qualified, employers need to ensure and document that that person actually does have the skills, training and understanding necessary to keep themselves and others safe.

Having a college degree in safety or a professional safety certification isn’t always enough to deem a person competent or qualified for every task. For example, even a certified safety professional may still need to gain more specific knowledge in a particular subject area to be considered competent or qualified under a given standard.

Who Is A Competent Person?

Within the general industry regulations, OSHA has competency requirements in 19 of their standards. OSHA defines “competent person” four ways. Each definition is similar with the common thread among all four being that a competent person can identify hazardous conditions. Depending on the specific definition that is referenced, a competent person also has the skills, knowledge, experience, training and authorization specific to a condition to take corrective measures.

Training and experience are two ways that a person can become competent, but, simply sitting through a training session isn’t enough. To be competent, an employee also needs to be able to demonstrate their capabilities to their employer.

Regulations that Require A Competent Person

1910.28	Safety requirements for scaffolding	Scaffolds must be erected, installed and relocated by competent, experienced personnel.
1910.66	Powered platforms for building maintenance	"Competent person means a person who, because of training and experience, is capable of identifying hazardous or dangerous conditions in powered platform installations and of training employees to identify such conditions.” Competent persons must inspect building support structures at least every 12 months. A competent person must perform platform maintenance inspections and tests at least every 30 days and following the manufacturer’s procedures. Governors, secondary brakes and suspension wire rope must be inspected by a competent person to verify the integrity of the products before use. Employees who will operate and inspect working platforms must be trained by a competent person.
1910.66	Personal fall arrest systems	"Qualified person means one with a recognized degree or professional certificate and extensive knowledge and experience in the subject field who is capable of design, analysis, evaluation and specifications in the subject work, project, or product." Qualified persons must test, design and install personal fall arrest systems including anchorages and horizontal lifelines.
1910.66	Personal fall arrest systems	"Competent person means a person who is capable of identifying hazardous or dangerous conditions in the personal fall arrest system or any component thereof, as well as in their application and use with related equipment."
1910.94	Ventilation	A competent, designated person must inspect limit switches weekly and manlifts at least every 30 days.
1910.109	Explosives and blasting agents	Competent persons must be in charge of magazines, responsible for the enforcement of safety rules, examine fire extinguishers periodically, ensure that explosives recovered from blasting misfires are segregated until the manufacturer determines a disposal method, and supervise warehouses where blasting agents are stored.
1910.111	Storage and handling of liquefied petroleum gases	A competent attendant must remain at the LP-Gas dispensing station while LP-Gas is transferred into the fuel container of a vehicle.
1910.119	Process safety management of highly hazardous chemicals	A competent on-scene incident commander and command staff must lead responders who work under very hazardous conditions.
1910.120	Hazardous waste operations and emergency response	"Competent means possessing the skills, knowledge, experience, and judgment to perform assigned tasks or activities satisfactorily as determined by the employer.” Training instructors must complete a training course or have appropriate credentials, be competent in instructional skills and knowledgeable in subject matter.
1910.156	Fire Brigades	Fire brigades must have competent leadership and supervision to be effective in hazardous and stressful situations.
1910.178	Powered industrial trucks	Operators of powered industrial trucks must successfully complete training and evaluation and be competent to operate a powered industrial truck safely.
1910.179	Overhead and gantry cranes	Defective crane hooks may only be repaired or reshaped only under competent supervision. The hook must be then tested to determine load requirements prior to ruse.
1910.183	Helicopters	A competent person must inspect cargo hook prior to each day’s operations to ensure that electrical and mechanical release functions operate properly.
1910.184	Slings	A competent person must inspect slings, fastenings and attachments for wear, defective welds, deformation and increase in length daily before use. They must also remove any defective slings from service.
1910.255	Resistance welding	Resistance welding equipment operators must be trained and judged competent before operating welding equipment.
1910.268	Telecommunications	A competent person must inspect personal protective equipment including safety belts, safety straps and lanyards; ladders; material handling devices and other mechanical equipment; protective devices and special tools before each day’s use to ensure that they are in safe working order. Vehicle brakes and operating systems must be tested at the beginning of each shift by a competent person. Derricks and associated equipment must be inspected by a competent person as recommended by the equipment manufacturer, or at least annually.
1910.269	Electric power generation, transmission, and distribution	Employees, including unqualified line-clearance tree trimmers must be competent in skills and techniques to distinguish live parts; determining nominal voltage of exposed live parts; approach distances; the use of precautionary techniques, personal protective equipment, insulating and shieling materials; and recognizing electrical hazards.
1910.272	Grain handling facilities	A competent contractor must design and properly install dust emission systems.
1910.304	Wiring design and protection	One or more competent persons must be designated to implement the written wiring design and protection program.
1910.399	Electrical	"Competent Person. One who is capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees and who has authorization to take prompt corrective measures to eliminate them."

Who Is A Qualified Person?

Like a competent person, a qualified person is able to identify or recognize a hazardous condition. However, a qualified person also has additional training, experience or instruction that allows them to perform tasks that an unqualified person would not be able to do safely. OSHA requires qualified personnel in 32 different regulations.

A good of example of the need for qualified personnel is electrical work. Whereas a competent person would be able to identify electrical components and have a general knowledge of electrical hazards, a qualified person would have the additional knowledge, skills and training to be able to do specialized electrical work tasks.

In some cases, a degree or certification may be required as part of a qualification. In other cases, it may involve a combination of tenure and training. Like declaring competency, employers must also determine if a person meets the criteria to be considered qualified in regards to a hazard.

Regulations that Require A Qualified Person

1910.7	OSHA recognition process for nationally recognized testing laboratories	On-site reviews of testing laboratories will be based on protocols established in national consensus standards and conducted by qualified individuals.
1910.29	Manually propelled mobile ladder stands and scaffolds (towers)	Registered professional engineers, scaffold manufacturers or qualifed, designated agents must errect or supervise the errection of scaffods exceeding 50 ft in height.
1910.66	Personal fall arrest systems	"Qualified person means one with a recognized degree or professional certificate and extensive knowledge and experience in the subject field who is capable of design, analysis, evaluation and specifications in the subject work, project, or product." Qualified persons must test, design and install personal fall arrest systems including anchorages and horizontal lifelines.
1910.103	Hydrogen	When mobile hydrogen supply units are being unloaded, a qualified person must be present.
1910.106	Flammable liquids	Tank venting devices less than or equal to 12 inches must be tested by an outside agency. The manufacturer of the vent may also test it, if certified by a qualified impartial observer.
1910.109	Explosives and blasting agents	A qualified person must determine if the systems used with expolosives and blasting agents will adquately dissipate static electricity. If expolosives or blasting agents must be transferred from a disabled vehicle, local first responders should be informed and the transfer must occur under the direction of a qualified person.
1910.110	Storage and handling of liquefied petroleum gases	Only qualified manufacturers may make repairs or modifications involving welding of DOT cotnainers.
1910.119	Process safety management of highly hazardous chemicals	Employees performing emergency shutdown operations must be qualified to ensrue that they can perform their duties safely and in a timely manner.
1910.120	Hazardous waste operations and emergency response	"Qualified person means a person with specific training, knowledge and experience in the area for which the person has the responsibility and the authority to control." Qualified persons must evalute site characteristics and select appropriate personal protection equipment and engineering controls. Persons conduting HAZWOPER trainings and/or 8-hour refresher trainings must be qualified and competent.
1910.134	Respiratory protection	The administrator of the respiratory protection program must be qualified by "appropriate training or experience that is commensurate with the complexity of the program."
1910.146	Permit-required confined spaces	Technically qualifed professionals (e.g., OSHA consultation service, or certified industrial hygienist, registered safety engineer, certified safety professional, certified marine chemist, etc.) should evalute confined space atmospheres and develop acceptable entry conditions and procedures.
1910.156	Fire Brigades	Fire brigade training instructors should be qualified, and able to demonstrate communication skills and motivate trainees.
1910.179	Overhead and gantry cranes	Crane operators must be qualified to perform their duties. Crane modifications must be performed by the manufacturer or a qualified engineer. If two or more cranes are used to lift a load, a qualfied person must analyze the positioning, rigging and movements; and must supervise the operation.
1910.180	Crawler locomotive and truck cranes	Employers must assign duties to designated, qualified operators.
1910.181	Derricks	Employers must assign duties to designated, qualified operators.
1910.184	Slings	Employers must assign duties to designated, qualified operators.
1910.217	Mechanical power presses	Safety systems for mechanical power presses must be validated by qualfied personnel.
1910.254	Arc welding and cutting	Personnel installing and operting arc welding equipment must be properly trained and qualified. Periodic inspections and repairs to arc welding equipment must be made by qualfied personnel.
1910.255	Resistance welding	Personnel installing and operting resistance welding equipment must be properly trained and qualified. Periodic inspections and repairs to resistance welding equipment must be made by qualfied personnel.
1910.265	Sawmills	Installation, inspection, maintenance, repairs and testing of ropes, slings, cables, chains, socketing, splicing and seizing of cables must be performed by qualfied persons.
1910.268	Telecommunications	"A qualified employee may work alone in a manhold where engertized cables or equipment are in service for a brief period of time to conduct an inspection, perform housekeeping, obtain a tank reading or do similar work if it can be performed safely. Line clearance tree trimmers must be qualified. If tree-trimming work is performed near an electrical hazard of more than 750V, a second qualfied individual must be within normal communciation distance to the qualfied person performing the work. "
1910.269	Electric power generation, transmission, and distribution	“Qualified employee (qualified person): An employee (person) knowledgeable in the construction and operation of the electric power generation, transmission, and distribution equipment involved, along with the associated hazards.” Employees must be qualified to perform line-clearance tree trimming operations or work on power generation, transmission, and distribution installations. Qualified employees climbing or changing location on poles, towers, or similar structures must use fall protection equipment unless the employer can demonstrate that climbing or changing location with fall protection is infeasible or creates a greater hazard than climbing or changing location without it.
1910.303	Electrical	Only qualified persons may access vaults, rooms, closets or other spaces with live (energized) parts.
1910.305	Wiring methods, components, and equipment for general use	Only qualified persons may access switchboards, panelboards and terminations enclosures with exposed live parts.
1910.306	Specific purpose equipment and installations	Only qualified personnel may open access doors and covers of indoor signs or outdoor lighting exceeding 600V. These devices must be protected with interlock switches to prevent unqualified persons form accessing the areas.
1910.307	Hazardous (classified) locations	A qualified, registered professional engineer must classify areas, select equipment and choose wiring methods.
1910.308	Special systems	Only qualified persons may access open runs of Type MV cables, bare conductors, open mounted circuit breakers, energized switching and control parts, and bare busbars.
1910.331	Eectrical: safety-related work practices	To be qualified to work on or near exposed, energized parts; a person must be trained and familiar with the skills and techniques necessary to distinguish exposed live parts from other parts of electrical equipment, know how to determine voltage of a live part and know exposure clearance distances.
1910.333	Electrical: Selection and use of work practices	Circuit elements and electrical parts must be tested and de-energized by a qualified person. Qualified persons must verify that equipment cannot be restarted; and must perform an inspection before equipment can be re-energized. If an employee is absent, only a qualified person may remove their lock or tag. Only qualified personnel may work on enrgized parts.
1910.334	Electrical: Use of equipment	Only qualified persons may temporarily defeat an electrical safety interlock to work on equipment. They must re-enable the interlock when work is completed. Test work on electrical circuits or equipment must be performed by qualified individuals.
1910.399	Electrical	“Qualified person. One who has received training in and has demonstrated skills and knowledge in the construction and operation of electric equipment and installations and the hazards involved.”

Getting employees to these levels involves more than making them attend a mandatory training session and issuing a certificate of attendance. When employees understand this concept and truly work to gain the higher levels of knowledge necessary to become competent or qualified in regards to a work hazard, they will be better able to prevent incidents and make their workplaces safer.

TAGS: Safety

Who Is A Competent Person?

Who Is A Qualified Person?

Karen

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