Just training people in a subject like health and safety representative does not make him or her competent. As you can see from the definition below, they need experience as well as knowledge. And this is a very hard thing to manage in the workplace.
The construction regulations define a ‘competent person’ as a person who:
(a) has in respect of the work or task to be performed the required knowledge, training and experience and, where applicable, qualifications, specific to that work or task: Provided that where appropriate qualifications and training are registered in terms of the provisions of the National Qualification Framework Act, 2008 (Act No.67 of 2008), those qualifications and that training must be regarded as the required qualifications and training; and
(b) is familiar with the Act and with the applicable regulations made under the Act;
Notes: a) An all-inclusive assessment should be on all four components: knowledge, training and experience, and where appropriate qualifications exist in relation to the work to be performed. Part (b) of the above definition is best reflected through demonstration of understanding of the OSH Act and its various applicable regulations.
So how do we implement this in our workplace to form part of the safety management system?
The person has one day’s training from a training provider – and there is a lot of information to take in, e.g. the act, accident and incident procedures, as well as hazard identification and risk assessment. Ideally, the senior or supervisor in the business already qualified in the subjects should provide in-post training to assist the new safety representative in his tasks.
Many companies I have dealt with send a person on a safety representative course and then expect him to do a safety practitioners job. Surely he cannot be deemed competent in doing a safety officer or practitioner’s job? He would need way more intense training as well as experience. In the same breath it is not compliant to appoint a person as a safety officer with only a theoretical qualification behind his name. Remember you as the employer have to do what is reasonably practicable in your workplace. The moral and legal liability for this person being responsible for people’s lives and health is not acceptable if he is not competent.
The same principle has to be enforced with regards to all aspects in and around health and safety. Accident investigators, permit issuers, fall protection planners etc. all need a qualification as well as experience and knowledge.
As an employer, remember to ask yourself the question: “Did I do enough to prevent this incident or accident from happening?” If the answer is, “I don’t know,” or “No,” then you need to ensure competence as well as a working health and safety management plan.
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