An explanation of the term “Competent Person” and its relation to scaffold user training and scaffold competent person training.
Can a scaffold user be a competent person? Does it require a competent person to be a scaffold user? And what if you are incompetent—does that mean you cannot be a scaffold user? Is there a difference between being competent and being a competent person? And if you have user safety, does that make you a competent person? These are some of the questions that arise when it comes to scaffold training. So, what are the answers, assuming there are answers?
Well, here are the answers:
Can a scaffold user be a competent person? Sure, he or she can; she or he can even be competent.
Does it require a competent person to be a scaffold user? No.
And what if you are incompetent—does that mean you cannot be a scaffold user? No, there are plenty of scaffold users who are incompetent.
Is there a difference between being competent and being a competent person? Yes.
If you have user safety, does that make you a competent person? Probably not.
There you have it, answers to the questions. Too bad those answers suck. Perhaps a bit more explanation is in order. There is a difference between “user safety training” and “competent person training,” but guess what? There is no such thing as “competent person training” although there are plenty of people offering this type of training. In fact even the Scaffold Industry Association offers “competent person training.” Of course there is nothing wrong with this claim as long as you understand that you will not be a competent person when you are finished with the training! How’s that for “competent person training?” As for user safety training, that does exist. In fact everyone who uses a scaffold must have this training.
I suspect additional explanation would be helpful. Here is how it all works out. First, the Federal OSHA standards require that anyone involved with scaffolds be trained. OSHA has split the interested parties into two groups, users and “each employee who is involved in erecting, disassembling, moving, operating, repairing, maintaining, or inspecting scaffolds.” [29 CFR 1926.454(b)] (There is also a third category that addresses retraining. This retraining is for those who have forgotten what he or she learned in the training.)
Second, it is necessary to understand the definition of a “competent person” as it is used by OSHA. OSHA defines a competent person as “one who is capable of indentifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them.” [29 CFR 1926.450] Note the two key words of this definition, identifying and authorization.
It is also helpful to understand the definition of “qualified person” as it is used by OSHA since training shall be conducted by a qualified person. OSHA defines a qualified person as “one, who by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his/her ability to solve or resolve problems related to the subject matter, the work, or the project.” [29 CFR 1926.450] The key phrase here is “has successfully demonstrated his/her ability to solve or resolve problems.” To put it bluntly, a qualified person is an individual who knows what he or she is talking about.
As a scaffold user, your training shall be done by a qualified person, again somebody who knows what he or she is talking about. This training shall include “The nature of any electrical hazards, fall hazards and falling object hazards.” The training shall also include “The correct procedure for dealing with electrical hazards and for erecting, maintaining, and disassembling the fall protection systems and falling object protection systems being used; the proper use of the scaffold; the proper handling of materials on the scaffold; the maximum intended load and the load-carrying capacities of the scaffolds used; and any other pertinent requirements of this subpart.” [29 CFR 1926.454(a)] Remember, this training is for scaffold users.
That brings us to “competent person training.” Since there is no such thing as “competent person training” what exactly does this type of training provide? If it is high quality training, the course will provide the information that is necessary for you, the potential competent person, to utilize to identify hazards. DH Glabe’s courses for Competent Person Safety Training provide this type of training. Assuming you have successfully completed the training, it is still not enough to make you a competent person. In fact, there is no way the SIA, or OSHA for that matter, can make you a competent person for the simple reason that they cannot give you the authority. Only your employer can give you that authority. This doesn’t mean the training is worthless. The competent person definition requires an ability to identify the hazard and this is where the training fits into the picture; the qualified instructor, one who knows what he/she is talking about, provides you with the information to identify the hazard. Your boss gives you the authority. Once you have the magic combination you become a competent person!
In summary, the user receives training in hazards associated with the use of scaffolding. The competent person’s training not only includes the user training but also includes training so that he/she is knowledgeable about the requirements of the OSHA scaffold standards. This means that experience may not be enough to become a competent person and of course, just knowing the standards will not be enough. You must know more. For example, you must know the importance of bracing, you must know the allowable load capacities of the scaffold, you must know the purpose of a sill and base plate, and you must know the applicable standards. So, the next time someone tells you he will make you a competent person, it better be your boss!