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July 2005

Are You Competent?

By | OSHA Standards & Regulations, Resources | No Comments

Well, are you competent?  What if your boss asks you if you are competent?  What if you are interviewing for a job and you are asked if you are competent in what you do?  What will you answer?  I’d like to think that I am competent in what I do.  As you may know, I write an article for this magazine.  Am I competent to do so?  You read the article.  Are you competent enough to understand what I’m talking about?  Wow!  That is pretty darn presumptuous of me.  I don’t even know you; but then you don’t know me.  You’re assuming that since I wrote the article and the editor published it, I must know what I’m talking about.

Fact is, that may be a big assumption.  I appreciate the fact that you assume that I am competent.  That will make the rest of this easier.  But how do you know?  What is your understanding of a competent person?  Is it somebody that is well, competent?  I think that when an individual thinks of the competent person, he or she assumes the person is well versed in the subject matter, knows what is going on, and has some authority.  I hope you see it the same way.

Federal OSHA has a very specific definition of who a competent person is.  To paraphrase, a competent person, according to OSHA, is somebody who can recognize a hazard and has the authority to eliminate that hazard.  That’s pretty specific.  Is this important?  You bet it is.  OSHA requires that a competent person be involved with specific aspects of scaffolding.  For example, a competent person is required to inspect a scaffold prior to anybody using the scaffold.  As another example, scaffolds shall be erected, dismantled, or altered under the supervision of a competent person.  Hey. This means that scaffolds are going to erected in a perfect manner, especially since the it is understood that a competent person will recognize hazards and will do something about it.

All this is pretty cool.  But who determines that a person is competent?  Since, by definition, a competent person has authority, I believe it can be safely assumed that it is the employer that designates the competent person; it is the employer that gives an employee authority, and therefore makes the individual a competent person.  But who is it that evaluates that individual to see if the employer is correct?  This is where the situation becomes a bit difficult.  If I am to determine that you are competent, or conversely, you are to determine that I am competent, do not I and you need to be competent?  Maybe not.  I don’t need to have any authority to determine if you are competent, but I sure need to know the subject matter to know if you know what you are talking about and conversely too.  You don’t know if I know unless you know; otherwise you base your opinion on faith.  Now, I appreciate the fact that you value my opinion.  I know that I appreciate your opinion.

Herein is the rub, so to speak.  How does an OSHA compliance officer determine if I or you are competent unless he/she is competent?  I don’t know.  Competency is an understanding of the subject matter.  It is an understanding of scaffolding.  This takes training and experience.  This takes an understanding of the regulations; this takes knowledge of scaffolding.  This isn’t fair.  Let’s face it.  Money isn’t available for OSHA compliance officers to get the training they need.  Money isn’t available for scaffold erectors to get the training they need.  We don’t offer enough money to get the qualified employees we need to provide the competency expected by the regulations.  Basically, it is an unfunded requirement, established by regulation, and endorsed by the industry back in 1996, if not before.  Don’t blame OSHA.  They are just enforcing the regulations.  We are the problem.

Read the regulations.  It clearly requires that scaffolds shall be inspected by a competent person.  It clearly requires that scaffolds shall be constructed under the supervision of a competent person, qualified in scaffold erection.  That’s right; we expect scaffolds to built by guys that know what they are doing!  We expect OSHA to send people out who can properly evaluate those scaffolds.  How are we doing?