Wednesday, September 6, 2017

Understanding Authorized, Qualified and Competent Persons


Throughout the newly revised Subpart D, as well as the new standard for fall protection PPE, OSHA uses terms to describe various types of employees who may be assigned responsibilities based on their knowledge, abilities and qualifications. I’ve had a number of questions from clients asking about the terms and under what circumstances such designated persons should be assigned. While there is nothing new about OSHA’s use of these terms, it can be a bit confusing trying to keep the terms separate and remember whom should do what. This post is intended to help sort out and simplify that requirement.

Authorized Person
An authorized person is an employee whom the employer assigns or grants authorization to perform a specific type of duty, or allows in a specific location or area.

Loading rack, loading dock, or teeming platforms: There may be circumstances, while working on loading racks, loading docks, or teeming platforms, under which fall protection systems (equipment, device, or system that prevents an employee from falling from an elevation or mitigates the effect of such a fall) is not feasible. If the employer can demonstrate the infeasibility of such systems then they need only meet the following requirements:
  • The work operation for which fall protection is infeasible is in process;
  • Access to the platform is limited to authorized employees; and,
  • The authorized employees are trained in accordance with §1910.30. [1910.28(b)(1)(iii)]
Repair pits, service pits, and assembly pits less than 10 feet in depth: OSHA does not require the use of fall protection around repair pits, service pits, and assembly pits which are less than 10 feet deep as long as, in addition to other requirements, only authorized employees are allowed within six feet of the pit edge. The authorized employees must have received training as required under 1910.30.

[1910.28(b)(8)(i)]

Slaughtering facility platforms: There may be times when a guardrail or travel restraint system is not feasible. In such circumstances, the work may be done without those systems provided:
  • The work operation for which fall protection is infeasible is in process;
  • Access to the platform is limited to authorized employees; and
  • The authorized employees are trained in accordance with §1910.30.
[1910.28(b)(14)(ii)]

Qualified Person
A qualified person is a person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience has successfully demonstrated the ability to solve or resolve problems relating to the subject matter, the work, or the project.
Knots in lanyards or vertical lifeline: To ensure lanyards or vertical lifelines meet minimum qualifications described in 1910.140(c)(4) and (5), a competent person or qualified person must inspect each knot in a lanyard or vertical lifeline before any employee uses them. [1910.140(c)(6)]

Horizontal lifeline: Each horizontal lifeline shall be designed, installed, and used under the supervision of a qualified person. [1910.140(c)(11)(i)]

Anchorages: Anchorages, except window cleaners’ belt anchors covered by 1910.140(e), must be designed, installed, and used, under the supervision of qualified person, as part of a complete personal fall protection system that maintains a safety factor of at least two. [1910.140(c)(13)(ii)]

Rope descent system:
Before any rope descent system is used, the building owner must inform the employer, in writing that the building owner has identified, tested, certified, and maintained each anchorage so it is capable of supporting at least 5,000 pounds, in any direction, for each employee attached. The information must be based on an annual inspection by a qualified person and certification of each anchorage by a qualified person, as necessary, and at least every 10 years. [1910.27(b)(1)(i)]

The rope descent system shall be used only in accordance with instructions, warnings, and design limitations set by the manufacturer or under the direction of a qualified person; [1910.27(b)(2)(ii)]

Training: The employer must ensure that each employee is trained by a qualified person. [1910.30(a)(2)]

Correction or repair of walking or working surfaces:
When any correction or repair involves the structural integrity of the walking-working surface, a qualified person shall perform or supervise the correction or repair. [1910.22(d)(3)]

Competent Person
A competent person is a person who is capable of identifying existing and predictable hazards in any personal fall protection system or any component of it, as well as in their application and uses with related equipment, and who has authorization to take prompt, corrective action to eliminate the identified hazards.

Knots in lanyards or vertical lifeline: To insure lanyards or vertical lifelines meet minimum qualifications described in 1910.140(c)(4) and (5), a competent person or qualified person must inspect each knot in a lanyard or vertical lifeline before any employee uses them. [1910.140(c)(6)]

If any component of a personal fall protection system is subjected to impact loading, it must be removed from service immediately and not used again until a competent person inspects the system or components and determines that it is not damaged and is safe for use for employee personal fall protection. [1910.140(c)(17)]

Hopefully, this will clarify understanding. If you should have questions or desire assistance, please feel free to visit the EI Group, Zack Academy's training partner.

Guest Post written by Bill Taylor, CSP from the EI Group.

No comments:

Post a Comment