You’ve identified fall hazards at your non-construction site and are ready to develop a fall protection program and train your team.
But then the question comes up: who can actually provide that training?
After reviewing the Occupational Safety and Health Administration (OSHA) Walking Working Surfaces standard under 29 CFR 1910 Subpart D, two requirements stand out:
- Employees must be trained before exposure to fall hazards.
- Training must be conducted by a qualified person.
So what does that actually mean in practice? Does a qualified person need a specific certification or degree?
OSHA does not prescribe specific certifications or credentials for a “qualified person.” Instead, under 29 CFR 1910.21(b), it defines that 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.” OSHA places that determination squarely on the employer.
OSHA’s August 31, 2017 Letter of Interpretation provides additional context and references American National Standards Institute (ANSI) standards as guidance on how qualifications may be established. It reinforces that individuals with sufficient subject matter expertise, training experience, and technical knowledge may meet the definition of a qualified person.
This means a certification or degree may support qualification, but it is not required. Likewise, the absence of a certification or degree does not automatically disqualify someone if their knowledge, training, and experience are sufficient and the employer has evaluated and documented that determination.
Additionally, the qualified person does not need to be a “jack of all trades.” OSHA’s expectation is that the individual is qualified for the specific hazards they are addressing.
If training includes personal protective equipment (PPE) selection, fall clearance, and fall hazard identification, the qualified person must have the knowledge, training, and experience necessary to solve or resolve problems within that scope. That does not mean they must be qualified in every aspect of fall protection. For example, a trainer may be qualified to address fall hazards and proper equipment use, but not to certify anchorage points. In those situations, they must recognize that limitation and rely on a Professional Engineer or manufacturer specifications where appropriate.
OSHA enforcement in this area typically focuses on outcomes and understanding. During an inspection, OSHA may interview employees to determine whether they understand fall protection requirements and can demonstrate safe work practices, including proper use of PPE where required. If training content is found to be insufficient, or if the trainer cannot adequately explain the requirements, citations may be issued related to training or qualified person designation. OSHA expects a high level of competency due to the severity of potential fall hazards.
So what does this mean for employers developing a fall protection program?
- Clearly define and document who is designated as a qualified person and how that determination was made.
- Align the individual’s knowledge, training, and experience with the scope of training being delivered.
- Recognize where additional expertise is needed and bring in external support.
- Ensure employees can demonstrate understanding and properly use fall protection equipment if applicable.
Fall protection training is not about checking a box or assigning a title. It is about ensuring the person delivering training is qualified for the hazards they are covering and that employees leave with the ability to work safely.
If you’re working through how to define your qualified person designations, you’re not alone. This is one of the most common areas where programs fall short under inspection. Colden regularly supports clients in aligning training programs and role designations with OSHA expectations while keeping them practical for operations.
Colden Corporation consultants can help you with all aspects of your occupational health and safety programs. Learn more about Colden’s service offerings and connect with a consultant by submitting an inquiry.
