To answer the question, the training that OSHA specifies is really specific to your industry. If we are looking at General Industry, OSHA’s 1910 standards state that the training has to be conducted by a Qualified Person. If you look at the 1926 standards it tells you that the training has to be conducted by a Competent Person.
Those terms are sometimes skewed or interchanged when they shouldn’t be, because there are certain things that a Competent Person can do that a Qualified Person cannot and vice versa. When you get into a Qualified Person that’s very specific to the type of equipment, type of tasks that you’re doing, so it’s a little bit more focused. A Competent Person has a general knowledge and a little bit more authority, but they will have a generally broad knowledge. Again, 1910 says Qualified Person, 1926 says Competent Person.
ANSI also has their own standards, C359, and they give you a little more details. What they require is a course before you are exposed to any kind of fall hazard. You have to have some kind of training based on what you are going to be doing. If you are going to be using fall arrest systems, fall restraint systems, or just working in the area that is going to have guardrails, you have to be trained on that particular type of fall protection in your area.
ANSI C359 standard recommends refresher training every 2 years. OSHA doesn’t really specify a certain time frame, but they do require you to have training in addition to every 2 years if there are any kind of changes in the workplace. For example, if you change policies or procedures, if you’ve changed fall protection equipment that is now something new or different than what you used to use, and also a “catch all” statement that is if you’re seen doing something that shows that your skills or training is inadequate.
There are a lot of companies that decide with any kind of incidents, they’ll send them through refresher training, but just keep in mind that post refresher training is not a catch all source for fixing all of your issues, but it is a part of that.
The biggest mistake I see safety professionals making is not knowing their resources and not knowing the differences between a Competent Person and Qualified Person. They may use those roles interchangeably. They might send someone through a Competent Person course, but they may not be qualified to supervise a horizontal lifeline installation. Things that are specific to certain types of tasks or issues are not being looked at as to who can do those particular things.
Another thing they might not take a look at is compatibility. There are some manufacturers that say you can’t really mix and match equipment. For example, you take a harness from Company A with a lanyard from Company B. A lot of companies say as long as a Competent Person evaluates those compatibility issues and says that it’s OK based on their training and experience then you can go ahead and do that. Some companies decide to take that out of the equation and say you have to use the same company. They are making sure that no one has to worry about compatibility issues.
Safety professionals not understanding their resources and how they can benefit them is another problem I see a lot. There are times you need to outsource things to a third party, other times you can do it in house. Just making sure they know the difference between a Competent Person and Qualified Person along with OSHA standards say is very, very important.
That answer is going to vary from industry to industry. So, in my experience, the construction industry is a little bit harder to document. Some of the out in the field training does not constitute formal training. You are still going to have to send them at some point through a little more advanced and longer Authorized User training.
Typically, if you go into general industry or manufacturing it’s a little bit easier to get a training done because you have people in one spot. We say across the board “if it’s not documented, it didn’t happen”. If an OSHA investigation does occur, they are going to want to see records of things and if you don’t have records of that, it’s essentially going to be your word against theirs. You’ll have to prove to OSHA that you did in fact do that training. The more details the better. I’ve been involved with OSHA investigations as a consultant helping a company, and the more documentation they have such as pictures of the training, agenda of the training, roster of attendees, etc., the better. You don’t want to go overkill, but you do want to make sure you have several different pieces of documentation from the training.
ANSI’s C359 standard does give you a lot of good references for what you need to put on that documentation as far as general industry standards or construction industry standards. Simply putting fall protection doesn’t tell anyone if you trained them on 4 foot standards or 6 foot standards, who did the training, etc. Make sure you put what standards they were trained against, that will help you if there is an investigation, external or internal.
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