If an OSHA compliance officer walked your site this week and asked "who's your competent person for this excavation, and how do I know they're qualified," could your foreman answer without hesitating? On multi-employer sites across NJ, NY, and PA, competent person requirements are one of the most frequently cited gaps I see — not because contractors don't have the right people on site, but because nobody documented who they are or what makes them qualified. That paperwork gap turns a defensible program into a citation.
What OSHA's Competent Person Requirements Actually Say
The definition lives in 29 CFR 1926.32(f), and it's a two-part test — most contractors only satisfy half of it. A competent person is someone who is (1) capable of identifying existing and predictable hazards in the surroundings or working conditions, and (2) has authorization from the employer to take prompt corrective measures to eliminate them. Part one is about knowledge and field experience. Part two is about authority — if your "competent person" can't stop work or order a fix without calling a superintendent first, they don't meet the standard, regardless of how many certificates they hold.
Competent Person vs. Qualified Person vs. Authorized Person
These terms get used interchangeably on job sites, and OSHA officers notice when contractors can't tell them apart. A qualified person has documented degrees, certifications, or extensive knowledge and proven ability to solve problems related to a specific subject — think a PE who signs off on a shoring design. An authorized person is simply someone the employer has permitted to perform a specific duty, like entering a controlled area. A competent person is broader and site-facing: they inspect, identify hazards in real time, and have stop-work authority. A single employee can hold all three designations at once, but each one requires its own documentation trail — you can't assume one covers the others.
Where a Designated Competent Person Is Required on Your Site
This isn't a one-standard requirement — OSHA builds it into dozens of construction rules, and it's easy to miss one on a mixed-scope job:
- Excavations and trenching — 1926.651(k), daily inspections before entry and after any hazard-increasing event
- Scaffolds — 1926.451(f)(3), inspection before each work shift
- Fall protection systems — 1926.503, oversight of training and system adequacy
- Cranes and rigging — 1926 Subpart CC, inspection and site setup
- Steel erection, demolition, and concrete/masonry — each subpart names its own competent person duties
- Fire prevention and hot work programs — fire watch and hazard identification
What You Need in Place
A written designation solves most of the exposure I see on NJ and PA sites. At minimum, contractors need:
- A written designation record naming the individual and the specific standard(s) they're competent for
- Documented training, field experience, or credentials supporting the designation — not just a completion certificate
- Written confirmation of stop-work authority from ownership or leadership
- A daily or shift-based inspection log tied to the relevant standard (excavation, scaffold, etc.)
- A process for re-evaluating the designation if site conditions or scope of work changes significantly
- Coordination language in your subcontractor agreements clarifying who provides the competent person on multi-employer sites
General contractors are increasingly asking for this documentation upfront through prequalification platforms, and OSHA officers ask for it on nearly every site visit involving excavation, scaffolding, or fall protection. Getting the designation and the paper trail right before you're asked for it is the difference between a five-minute conversation and a citation. At Blueprint Safety, we build the written programs and documentation structure that let you designate competent persons correctly and back it up when someone asks — that's the groundwork, not an afterthought.