The Periodic Examination and Competent Person
The regulatory context of the European standards on Personal Protective Equipment (category 3 - mortal danger) against falls from a height and, in particular, standard EN 365:2004, requires the manufacturer to provide the following information:
‘The manufacturer shall provide the instructions for use, maintenance instructions and instructions for periodic examinations for each PPE item or other piece of equipment, in the official languages of the recipient country.
NOTE: The instructions for use, maintenance instructions and instructions for periodic examinations may be separate documents from one another. ’
The following paragraphs provide details for each part:
§ 4.2 Instructions for use: clauses (a) to (z)
§ 4.3 Maintenance instructions: clauses (a) to (d)
§ 4.4 Instructions for periodic examinations: clauses (a) to (e)
Concurrently, this same EN 365:2004 standard defines the competent person as follows:
§3 Terms and definitions:
§3.3 ‘Competent person for periodic examination:
Person who is knowledgeable of the current periodic examination requirements, recommendations and instructions issued by the manufacturers applicable to the relevant component, subsystem or system.
NOTE 1: This person should be capable of identifying and assessing the significance of defects, should initiate the corrective action to be taken and should have the necessary skills and resources to do so.
NOTE 2: A competent person may need to be trained by the manufacturer or his authorised representative on specific PPE or other equipment, e.g. due to its complexity or innovation, or where safety critical knowledge is needed in the dismantling, reassembly, or assessment of the PPE or other equipment, and may need to have that training updated due to modifications and upgrades.
NOTE 3: A person may be competent to carry out periodic examinations on one particular model of PPE or other equipment or may be competent to examine several models’.
We believe it is important to clarify certain concepts:
EN 365:09-2004: §3.3
‘A competent person for periodic examination is a person who is knowledgeable of the current periodic examination requirements, recommendations and instructions issued by the manufacturer applicable to the relevant component, subsystem or system. ’
EN 365:09-2004: § 4.4.b and c
‘[The manufacturer’s] recommendation shall include a statement to the effect that the periodic examination frequency shall be at least every 12 months.
[A warning shall be included] to emphasize that periodic examinations are only to be conducted by a competent person for periodic examination and strictly in accordance with the manufacturer’s periodic examination procedures. ’
EN 365:09-2004: § 4.7
‘Manufacturers shall provide all the necessary information and equipment e.g. instructions, checklists, spare parts lists and special tools etc., to enable periodic examination to be carried out by a competent person.
Manufacturers may provide training for persons to become competent or for updating competency in the periodic examination of PPE or other equipment, or make arrangements for authorized organisations or persons to be made available. ’
As a result of this regulation, the competent person is therefore:
a trained person, or a person whose knowledge and skills have been verified by a competent person.
In all cases, this is a person to whom an inspection training certificate was issued in their name. The scope of product skills must be defined in the training certificate. The training certificate must be valid.
It follows from the above:
- that any person trained in the visual inspection of PPE against falls from a height by KRATOS SAFETY or an authorized representative of KRATOS SAFETY is a competent person;
- that any person trained in the visual inspection of PPE against falls from a height by a person trained by KRATOS SAFETY is a competent person, subject to strict compliance with KRATOS SAFETY periodic examination procedures, and subject to such person being able to produce a training certificate drawn up by the person trained by KRATOS SAFETY;
- that any person trained in the visual inspection of PPE against falls from a height by a European manufacturer or by an approved training organisation (knowledge of PPE regulations and European standards being essential) is a competent person, subject to strict compliance with KRATOS SAFETY periodic examination procedures and provided that this person is able to present a training certificate as defined above.
Note: In cases 2) and 3), KRATOS SAFETY will carry out a positioning test in order to ensure the knowledge and skills of the person, before issuing a certificate recognising an equivalence of skills as a competent person.