Does competent person training automatically designate an individual qualified as such within OSHA’s regulatory umbrella?
Competent person training does not determine or bestow qualifications within OSHA’s regulatory umbrella. Designations and directives relating to it are issued by and at the company level to certain employees who the company officers and officials believe have sufficient training, knowledge and on-the-job experience to warrant such an appointment. OSHA does not mandate, approve, endorse, or create specific criteria that defines who qualifies as the designated individual.
All of the criteria are based upon the personal comfort level and judgment of the individuals at the company responsible for deciding who will best fulfill this important role within the company. This essentially boils down to said person’s ability to keep a jobsite and personnel safe based on a combination of their training, common sense and many years of on-the-job experience.
According to OSHA, a “competent person” is defined 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” [29 CFR 1926.32(f)]. By way of training and/or experience, a competent person is knowledgeable of applicable standards, is capable of identifying workplace hazards relating to the specific operation, and has the authority to correct them. Some standards add additional specific requirements which must be met.1
Generally, companies tend to start with the most obvious credentials, such as competent person training or other specific fall protection training courses. However, many other companies should, and sometimes do, create more stringent criteria that evolving around previous safety record, official field observance, specific jobsite training, etc., in order receive a title and appointment to the position. In conclusion, this designation and its resulting responsibilities should not be taken lightly. Companies can look to OSHA in the form of an individualized Letter of Interpretation that will look at their individual company designees to determine if OSHA believes that sufficient criteria has been met for the designation, and if not, what can be improved upon.
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1 OSHA Safety and Health Topics | Competent Person