Safety Training and Responsibility Levels

Affected employees are exposed or potentially exposed to a hazard but they do not have more than basic knowledge of the hazard and the associated task.  Awareness and affected employee training imparts high-level, non-technical training that informs an employee of the hazards of a given situation, the consequences of exposure to those hazards, how to avoid the hazards and the limitations of their actions.  It is a do this, but not that, go-no-go type of training.  Awareness-level and affected employee training informs employees what they can and can’t do but generally do not dive deeply into the topic at hand.

For example, affected employee lockout/tagout training informs the employee that when he observes a lock and tag with specific colors and text on an energy source, the employee should not remove that lock and tag and should not start the equipment.  Awareness-level confined space training educates an employee on confined space hazards, how to recognize permit-required confined spaces and that they may not enter a permit-required confined space.

Awareness and affected employee training is generally shorter and less technical.

Employers authorize employees to perform designated job functions.  Authorized person training is topical, user-level training that provides specific knowledge on the topic at hand.  At the successful completion of training, the employee is prepared to perform one or more specific activities.  29 CFR 1926.32(d) from OSHA provides us with a definition:

“Authorized person means a person approved or assigned by the employer to perform a specific type of duty or duties or to be at a specific location or locations at the jobsite.”

For example, authorized person fall protection training allows an employee to work at heights and use personal fall arrest systems.  Authorized person lockout/tagout training allows an employee to shut down equipment, relieve residual energy and then lock and tag all energy sources.

The competent person concept appears frequently in OSHA construction regulations but it is not specifically called out in general industry regulations.  Competent person training imparts a higher level of knowledge than authorized person training.  Competent person training is still topical, but it dives deeper into the material and enables the competent person to make informed decisions about controlling hazards and providing technical assistance to authorized employees.  A competent person must also have authority to correct unsafe situations and halt unsafe operations.  OSHA defines a competent person from an overarching perspective in 29 CFR 1926.32:

“…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.”

Trainers provide “competent person” knowledge but only the employer can designate and assign a “competent person.”

For example, when an Anfeald instructor provides competent person fall-protection training to an employee, and the employee appropriately demonstrates her knowledge, meets all class requirements and successfully completes the class, she is eligible to work as a competent person in fall protection within the limitations of their training and knowledge.  However, she can’t actually work as a competent person with a specific employer unless the employer delegates this responsibility to her together with stop-work-authority and the authority to correct workplace safety hazards.

Qualified persons (employees) are defined by OSHA in a general sense in 29 CFR 1926.32:

“Qualified means one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.”

A qualified person generally has specific topical knowledge at a higher level than a competent person and must possess a specific related educational background and/or extensive job experience.  In many cases, a qualified person has a degree, certification or other professional standing. The specific requirements a qualified person must meet are clarified in the applicable OSHA regulation.

Using fall-protection as an example:  A competent person must monitor work performed when using alternative fall protection plans under paragraph (k) of 29 CFR 1926.502 while a qualified person is likely required to engineer specialized fall protection systems in use during that work.

ELECTRICAL SAFETY AND THE QUALIFIED PERSON

Many regulations in construction and general industry reference the term “qualified person.” The definitions within each of the respective regulations essentially the same and are consistent with the definition provided in this article.  However, when it comes to electrical safety, the definition within the regulation is specific.

29 CFR 1926 Subpart K, the electrical work in construction standard, defines a qualified person as one who is “…familiar with the construction and operation of the equipment and the hazards involved” while 29 CFR 1910 Subpart S, the electrical work in general industry standard, defines a qualified person as “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.”

Qualified person status under electrical standards is all about understanding the topic and demonstrating sufficient knowledge to ensure the proper selection and application of safe work practices, personal protective equipment and other related areas.  A degree or certification is not necessarily required but extensive knowledge is required.

Finally, it is important to note the electrical safety regulations allow for a person to be qualified in one aspect of electrical work but unqualified in others.  This means that it is the employer’s responsibility to define the tasks that the employee performs and ensure that the employee is qualified to perform those tasks.