All employers and their supervisory representatives are responsible for monitoring workers at a frequency that ensures workers are working in accordance with safe work practices. (Supervisory representatives include health and environmental safety personnel, foremen, lead-hands, designated operators, and anyone else responsible for supervision of workers.) To ensure worker competency, employer representatives need to monitor workers performing these safe-working practices. Best practice dictates that this monitoring (such as observations and internal audits) be programmed or incidental and be documented.

This documentation should be at frequency that satisfies external scrutiny such as regulatory authorities and corporate auditors. In order to perform these audits, employer representatives need to have a level of safe work practice competency.

Best practice also dictates that unless an employer’s representative is already competent in the safe work practice the best way to attain that competency is to attend the same training as the workers. This way, the employer’s representative can apply the safe work practice criteria as a part of his or her programmed or incidental observations. This is the only way to ensure worker competency on the jobsite, anything less is just a “compliance safety certificate.”