Is a “Qualified Person” Always an Engineer?
By Kevin Denis, Director of Special Projects
I’m confused! Is a “Qualified Person” always an Engineer?
This is a question that I (and many people) frequently get when trying to determine who can function as a qualified person. I am not going to dissect the definition bit by bit, but rather try to explain the intent and purpose of the “qualified person” term. The term “qualified person” is used by OSHA in many safety regulations and simply put, it refers to a subject matter expert. If you have a problem or issue, get a “qualified person” (aka, subject matter expert) to solve it. A qualified person has the expertise (by way of education, professional standing, experience) to solve problems relating to the subject matter. Let me explain with a couple of examples.
Example #1. I have a pallet of bricks that shows up and must be moved into the warehouse. My “problem” is the pallet of bricks lying in the parking lot. The “expert” that can solve my problem is my forklift operator because she has the education (forklift license) and hours of experience to move the pallet safely. This is a corny example, but the key to understanding a qualified person is to first look at the subject matter and the problem before considering education and certifications.
Example #2. I have 100 fall protection harnesses ranging in age and wear that need to be inspected. My “problem” is determining the function and condition of fall protection PPE. The “expert” that can solve my problem could be a couple different people. It could be the manufacturer of the harnesses because they have the “ability to solve the problem” relating to function on the condition of their product. A safety professional, experienced with equipment-inspection could also be considered “qualified” to solve this problem. First, looking at the problem and who has the subject matter expertise to solve it is key in determining who is “qualified”. In this case, you certainly wouldn’t need an engineer to inspect your harnesses because their subject matter expertise doesn’t correlate to the problem.
Example #3. I need to install a couple of permanent anchors for my maintenance staff to tie-off to on the roof of my building. My “problem” is figuring out how to rip up the roof and install 5000 lbs. anchors into the structure. The subject matter expert in this situation would be a structural engineer because they have the “ability” to determine the strength of all the parts and determine how to safely attach the anchor without adversely affecting the rest of the building (degree in engineering, licensed with a state, experience, etc.). This is a common situation and an example where an engineer would be required as a “qualified person” because the problem is directly related to their expertise. It is also common to have several different qualified people work on an issue. Using the roof anchor example; a safety professional is qualified to select the PPE for compliance with OSHA (fall distances, compatibility, arresting force), the engineer is qualified to design the anchor to interact with the building, and the contractor is qualified to install it.
Fall protection regulations (federal and state) mention a qualified person when designing a horizontal lifeline, determining factors of safety on the strength of anchors and writing fall protection plans when other means of fall protection is infeasible. The first two examples involve subject matter that is clearly within the engineering community, but other qualified people could write fall protection plans. Determining that fall protection is infeasible when placing roof trusses on a residential construction site is subject matter that isn’t necessarily specific to engineering. A safety professional with the general contractor likely has the subject matter expertise and ability to resolve the problem, write the fall protection plan, and determine the safest way to do the job without fall protection.
Addressing the strength of anchors (2:1 FOS, horizontal lifelines, single/fixed), and designing how that anchorage interacts with the structure is the number one task of qualified people within the fall protection industry. Anytime the subject matter is dealing with the strength of materials, analyzing loads, modifying the structure, and designing how fall arrest systems interact with a structure, the qualified person should be an engineer. State law prohibits lay people from practicing engineering for a reason, even if they are subject matter experts in fall protection. I believe this is where much of the confusion surrounding a qualified person exists. There are a host of fall protection training courses (Gravitec included) that offer a “Qualified Person” certificate or credential. Most of these courses deal with selection and analysis of fall protection systems, including; selection of PPE, clearance calculations, energy dissipation calculations, rope stretch, design, and analysis of horizontal lifelines and factors of safety. Engineers are comfortable with this information because it aligns with their expertise. However, safety professionals, salespeople, trainers, and other interested parties also take these courses to improve their level of knowledge. Keep in mind that none of these courses allow the person to practice engineering.
There are certainly problems in the fall protection industry that do not require engineering. Inspection of equipment, selecting PPE, training, procedure writing, policy development, program management, and rescue planning are examples of tasks where a person “qualified” does not need to be an engineer. Many people have the subject matter expertise, education, training, and ability to work on these fall protection problems and be considered qualified to do so. However, professional engineers should be utilized when the fall protection issue enters into the design, interaction, and modification of structures and work under the jurisdiction of state engineering laws (legally required in some situations).
So “does a qualified person need to be an engineer?”….. if they are practicing engineering, they sure do.
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ABOUT THE AUTHOR
Kevin Denis has been in the fall protection industry for over 20 years and has had significant involvement in the continuing education of workers at height. As the training manager and project coordinator for Gravitec Systems, Inc., Mr. Denis is a member of the Z359 Accredited Standards Committee and various Z359 subcommittees that develop the Z359 Fall Protection Code. Mr. Denis has authored nationally recognized training standards for the telecommunication industry and developed training programs for government agencies as well as privately and publicly held companies. Mr. Denis manages a team of professional instructors that log over 50,000 student fall protection and rescue training hours per year.