Question Time...
OSHA’s new respirable crystalline silica regulation requires that job sites be inspected “frequently and regularly” by a “competent person”. In order to be considered a “competent person" how many hours of training must this person have before they can perform inspections?
a) 40 hours
b) 30 hours
c) 24 hours
d) 10 hours
e) None of the above
Hopefully, the answer is obvious, especially after reading the remainder of this post. But the correct answer is given below, just in case.
I’m frequently asked if Costello Safety Consulting offers “competent person training”. We do, however, there’s a qualifier. There’s really no such thing as competent person training per se. In other words, there’s no amount of training that will transform a person into a “competent person”.
The new respirable crystalline silica defines a “competent person” as “an individual who is capable of identifying existing and foreseeable respirable crystalline silica hazards in the workplace and who has authorization to take prompt corrective measures to eliminate or minimize them. The competent person must have the knowledge and ability necessary to fulfill the responsibilities set forth in paragraph (g) of this section.”
Here’s the point; No amount of training will make a person competent if that person doesn’t have the authority to take prompt, corrective actions to eliminate or minimize silica hazards, up to and including issuing stopping work orders. A Harvard educated toxicologist with 30 years of experience studying the effects of silica would not be considered a "competent person" if he/she doesn’t have the authority to order employees to wear a respirator. Conversely, a job superintendent with no formal training whatsoever would likely be considered competent as long as he/she is knowledgeable about the hazards and has authority to order employees to use wet cutting methods.
With all this being said, Costello Safety Consulting does indeed offer training that many people would consider to be "competent person" training. We’ve provided this training to many individual employers, trade associations, unions, and other types of organizations.
Depending on the client’s needs, we can provide training of 16 hours, eight hours, four hours, two hours, and one hour. The most popular option, by far, is 4 hours.
If your company, trade group, association, union or other type of organization has questions about this topic, I invite you to call us directly, at (832) 786-8814 or email us (info@costellohse.com) for a no-pressure consultation.