The Responsibilities of Authorized, Competent and Qualified Persons
Category : Industry News
Like those in any field with its own esoteric language, we in fall protection often take for granted that when we use a term, everyone else knows what we are talking about. For example, if I said, “For that Fall Arrest application, you’ll need an SRL-LE – and make sure the shock-absorber is attached to your dorsal D-ring,” you’d probably understand what I meant. Other terms can get squishier. What is the exact definition of a “prompt” rescue? What is a “regular interval” of inspection? What makes using a fall protection system “infeasible?” What constitutes “supervision” of work?
Clearing the Mud
We turn our attention to three terms found throughout OSHA and ANSI regulations that have caused more than a bit of confusion amongst newcomers: the Authorized, Competent and Qualified Persons. Each of these titles defines a specific role within the world of fall protection, and there has been more than one person (including myself) who has been confused as to where one person’s responsibility ends and another begins.
Let’s start with the term that affects the greatest number of workers – the Authorized Person. OSHA 1926.500 defines the Authorized Person as, “…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.” Pretty vague, no? That definition covers just about every person at the jobsite. ANSI tightens the definition by adding that “…the person will be exposed to a fall hazard.” In a nutshell, within the fall protection world, the Authorized Person is anyone who is required by their employer to be exposed to a fall hazard. But don’t think that’s all there is to being an Authorized Person. It’s not like you show up to your first day on the job and your employer asks you to kneel and touches each of your shoulders with a 4’ level and says, “Arise an Authorized Person, and get thee to the roof!”
Before you step foot on the job as an Authorized person, your employer must ensure you are fully aware of, and know how to recognize potential dangers on the jobsite. Not only that, but you also must be trained in the proper use of fall protection equipment, from harness and lanyards, to anchors, guardrails, and ladders, including their proper maintenance and storage. After all, having the title of Authorized Person doesn’t mean much if you don’t have the knowledge to back it up.
Competency Is a Good Thing
Climbing the ladder of responsibility, we next find the Competent Person. The Competent Person’s responsibilities encompass those of the Authorized Person, but with the added duty (assigned to them by the employer) to take corrective measures to eliminate fall hazards, up to and including halting operations until the hazards have been mitigated. As a matter of fact, the latest OSHA 1910 General Industry update added this latter authorization to their definition of Competent Person. This strengthens the role, and brings it into alignment with the established 1926 Construction and ANSI standards – a good thing.
The Competent Person is a walking, talking storehouse of fall protection knowledge, who constantly monitors the jobsite for hazards, and who, in fact, must first survey the jobsite before an Authorized Person comes onsite to create both a fall and rescue plan. And once a job begins, they are the person Authorized Persons should consult when there is a question regarding the suitability or compatibility of fall protection equipment in a particular situation. The Competent Person understands and approaches fall protection from a slightly higher level than the Authorized Person, and their word carries more authority across the jobsite. And if there is an incident, guess who is right in the thick of the questioning? That’s right, the Competent Person.
In addition to situational expertise, the Competent Person is also responsible for regular inspections of fall protection equipment. It is the duty of every Authorized Person to inspect their gear every day before work, but the Competent Person, with their high-level of knowledge, is considered to have more expertise and therefore is charged with being a sort of gatekeeper in regards to equipment. Think about it this way: An Authorized Person may only deal with a limited variety of Fall Protection equipment – maybe a harness and lanyard, but the Competent Person is responsible for knowing about the full spectrum of gear, and must possess the requisite knowledge to determine whether a particular piece of gear is safe for continued use. Hint: If you would like to do something to make you immediately more knowledgeable and valuable on the job, get yourself to one of our Competent Person classes. Every jobsite needs one, why not you?
Above the Competent Person is the Qualified Person. When I say “above,” I don’t necessarily mean that the Qualified Person is an Authorized or Competent Person’s superior, or even supervisor, but that their responsibilities take on an even higher degree of technical knowledge, expertise, and in many cases, education. The most comprehensive definition of a Qualified Person is provided by ANSI, and states that a Qualified Person is:
“A person with a recognized degree, certificate, or professional certificate AND with extensive knowledge, training and experience in the fall protection AND rescue field who is capable of designing, analyzing, evaluating and specifying fall protection and rescue systems to the extent required by this standard.”
This means that a Qualified Person knows not only which fall protection system might work in a particular situation, but also show (usually through on-site testing) that the solution meets the performance standards as dictated by ANSI or OSHA. A common example is the certification of anchorages used in fall protection. OSHA mandates that anchors must be capable of supporting 5,000 lbs., but even if the anchor was installed per manufacturer’s instructions, how do we know it will? That’s where the Qualified Person comes into play.
As mentioned in the post on the updated OSHA 1910 regulations, building owners with rope descent systems must provide to the employer written certification that their anchorages have been tested and meet the strength requirements as set forth by OSHA. Only a person with specific engineering education and experience is capable of performing these tests and certifying the results in any meaningful way. In many instances, Qualified Persons will hold a technical or other engineering-based degree. Since inspecting and testing requires broad-based knowledge about structures, including their integrity and composition, it makes sense that a person who puts their name on the line has a background in physics, material strength and fatigue, and scientific testing methods.
With such specialized responsibilities, it’s quite unlikely that a Qualified Person will ever be on a jobsite full-time, day in and day out. The nature of their work really puts them in place before work commences, or if after work begins, as conditions change and a new fall protection system needs to be engineered or tested. And keep in mind, this doesn’t necessarily mean that a Qualified Person has been on every jobsite. Many jobsites never have a Qualified Person visit to certify anchor installations. To understand why this may be, you need to know about certified vs. non-certified anchors. But that’s a story in itself, so let’s leave that for another day.
What Does This Have to Do with Us?
There is one other role that also needs to be mentioned alongside our triad of Authorized, Competent, and Qualified persons, and that is the manufacturer – in this case of course, Guardian Fall Protection. What role does the manufacturer play when it comes to the responsibilities of these three jobs? In two words, a lot. Essentially, no one installing, inspecting, testing, or using fall protection could do their job until we do. Our role as a manufacturer is to first think of the needs of the worker, then engineer a product to fit that need. That sounds like a simple process, but brother, it’s not. Before we release a product to the market, it is tested (and retested…and retested) to make sure it meets all of the safety specifications from OSHA, ANSI, and ourselves. Testing is in large part a process of discovery in that we go into the lab with a certain expectation (usually they are met), but sometimes it’s the unexpected little things that throw us for a loop. Maybe it’s the number or gauge of screws that are used, or maybe it’s the thickness or composition of the substrate that we need to tweak one way or the other. No matter what comes our way though, we adjust our parts and procedures and continue our work.
Once we have a successful product, we generate documentation that spells out precisely how the product (an anchor, let’s say) should be installed for maximum strength and performance. Even the documentation goes through revision after revision to make sure it’s just right – trust me on this… It is this information that then gets passed on to the subsequent Qualified, Competent, and Authorized persons so that they can install and use properly the very equipment on which lives will rely. But don’t think that once a product is released that that is the last time it ever sees the lab, or its installation instructions are reviewed. Guardian regularly batch tests every product that comes through our warehouse, and we believe wholeheartedly that constant review and revision is the best policy for making sure our products will perform to their maximum potential when they are needed the most.
This blog is reprinted with permission from Guardian Fall Protection. Originally published April 3, 2017, on The Guardian Fall Team Blog. For more information about fall protection or other personal safety products or issues, please contact your French Gerleman account manager or e-mail firstname.lastname@example.org.