Summary
In short
- Change is the primary trigger: equipment, process, product, method, role or working conditions. A recent assessment against a superseded method establishes nothing.
- Observation is the trigger most often ignored, because acting on it means acknowledging what was seen. Several standards make it explicit, including the confined space and energy control standards.
- Interval should follow skill decay and consequence. Rarely performed high-consequence tasks decay fastest and are usually given the longest intervals.
- An incident or near miss involving a task is direct evidence that the competence judgement, the task design, or both, need revisiting.
- Reassessment is an observation of the task, not a repeat of the training. Redelivering a course establishes attendance again.
- Record what has changed since the last assessment, because that is what determines whether this is a refresher or a fresh judgement.
What it is
What it is
What is competency reassessment?
Re-establishing that a person remains competent for a task, either because a defined interval has elapsed or because something has occurred that calls the earlier judgement into question.
Why do triggers matter more than intervals?
Because an interval assumes the only thing that changes is the person's retention. In practice the equipment, the process, the product and the conditions change, and each of those invalidates a competence assessment made against the previous version regardless of how recently it was performed.
When to use it
When to use it, and when not to
This re-establishes competence for a task. Initial assessment and training sit before it.
Use it for
- Following a change to equipment, process, product, method or working conditions
- After an observed deviation, near miss or incident involving the task
- On return from extended absence, or on moving between sites, shifts or areas
- At a defined interval, as a backstop for changes nobody flagged
- Where periodic inspection or audit indicates knowledge or practice is inadequate
Not for
- Initial competency assessment, which establishes capability in the first place
- Training delivery records, which evidence what was provided
- The competency framework, defining what each role requires
- Performance management, which addresses a different question
- Refresher training, which may be the response rather than the assessment
Standards
What it is built against
Reassessment triggers appear across the competence clauses and in several task-specific standards.
| Clause | Requirement | Where it lands |
|---|---|---|
| ISO 45001 cl.7.2 | Competence maintained, with the effectiveness of actions taken evaluated | Header |
| 1910.146(g)(2) | Retraining on duty change, hazard change, and where deviations or inadequate knowledge are believed to exist | Since last assessment |
| 1910.147(c)(7)(iii) | Retraining on change of assignment, machines, processes or procedures, or where inspection reveals inadequacies | Since last assessment |
| 1910.178(l)(4) | Refresher training and evaluation on accident, near miss, unsafe operation, truck type or workplace change | Since last assessment |
| 1926.503(c) | Retraining where workplace or systems change render previous training obsolete | Since last assessment |
| ISO 9001 cl.7.2 | Competence based on education, training or experience, with documented evidence retained | Result |
| ISO 22000 cl.7.2 | Competence of persons affecting food safety, including externally provided personnel | Reassessment |
| ISO 45001 cl.10.2 | Corrective action following incidents, which may include competence | Result |
What it does not cover
- Initial competency assessment, establishing capability in the first place.
- Training delivery records, evidencing what was provided.
- The competency framework, defining what each role requires.
- Performance management, which addresses a different question and should stay separate.
- Refresher training, which may be the response rather than the assessment itself.
Filling it in
Filling it in well
Record what changed, observe the task again, and make the observation trigger work.
Equipment, method, product, layout, shift pattern, or nothing. This field determines whether the reassessment is confirming retention or making a fresh judgement against a different task, and those are different exercises. A change to the method means the previous assessment applies to something that no longer exists.
Reassessment is watching the person do the job under realistic conditions against the criteria. Redelivering the course establishes attendance for a second time. Where the assessment is a knowledge check, it confirms recall, which is not what lapsed.
An observation that someone is not following the procedure is a competence finding, and several standards say so explicitly. Handling it as coaching leaves a competence record that the observation contradicts. Where the deviation turns out to be caused by an impractical method, the finding moves to the task, which is a better outcome and still requires the trigger to have been pulled.
How quickly the skill degrades without practice, and how bad failure would be. Complex, rarely performed, high-consequence tasks, emergency response above all, decay fastest and typically receive the longest intervals because practising them is inconvenient. The interval is a backstop for changes nobody flagged, not the primary mechanism.
Audit findings
Common audit findings
Reassessment findings concentrate on triggers rather than on records.
| Finding | Clause | What fixes it |
|---|---|---|
| Reassessment driven only by calendar interval. | 1910.147(c)(7)(iii) | Change and observation are the primary triggers; the interval is a backstop. |
| Observed deviation handled as coaching rather than as a trigger. | 1910.146(g)(2)(iv) | Several standards make observation an explicit trigger; the observation is evidence. |
| No reassessment after equipment or method change. | 1926.503(c) | A prior assessment against a superseded method establishes nothing. |
| Reassessment performed by redelivering training. | ISO 45001 cl.7.2 | Observe the task; redelivery records attendance twice. |
| Intervals set by convenience rather than decay and consequence. | ISO 45001 cl.7.2 | Rarely performed emergency skills decay fastest and usually get the longest intervals. |
| Incident involving a task with no competence review. | ISO 45001 cl.10.2 | The incident is evidence about the competence judgement, the task design, or both. |
| What changed since the last assessment not recorded. | ISO 45001 cl.7.2 | It determines whether this confirms retention or makes a fresh judgement. |
| Agency and contractor personnel excluded from reassessment. | ISO 22000 cl.7.2 | Competence obligations extend to externally provided personnel performing the work. |
| Return from extended absence not treated as a trigger. | ISO 45001 cl.7.2 | Both the person's retention and the workplace will have changed. |
| Reassessment record does not state the conditions observed. | ISO 45001 cl.7.2 | Competence is scoped by the conditions; record equipment, product and shift. |
Worked case
Case in point: assessed against a machine that had been replaced
An operator was reassessed as competent on a packing task, on schedule, twelve months after the previous assessment. The assessment used the site's standard criteria and was recorded correctly.
Seven months earlier the machine had been replaced with a different model. The controls were arranged differently, the guarding was interlocked rather than fixed, and the jam clearance procedure was not the same. None of that appeared in the reassessment, which used criteria written for the original machine.
The reassessment was current, documented and describing a task that no longer existed in that form. Nothing in the process asked what had changed since the last assessment, so the criteria carried forward unchanged.
Definitions
Definitions and key terms
- Reassessment trigger
- An event calling a competence judgement into question: change, observation, incident, absence or interval.
- Skill decay
- Loss of capability through lack of practice, fastest for complex rarely performed tasks.
- Observed deviation
- Seeing someone not follow the procedure, which several standards treat as an explicit retraining trigger.
- Scope of assessment
- The equipment, product and conditions the judgement applies to, which change invalidates.
- Backstop interval
- A periodic reassessment catching changes that were never flagged as triggers.
- Fresh judgement
- Reassessment against materially changed criteria, as distinct from confirming retention.
- Effectiveness evaluation
- The ISO 45001 requirement to evaluate whether actions taken to achieve competence worked.
- Externally provided personnel
- Agency and contractor staff, within competence obligations where they perform the work.
FAQ
Frequently asked questions
Why are triggers more important than intervals?+
Because an interval assumes the only variable is the person's retention. In practice equipment, methods, products and conditions change, and a competence judgement made against a previous version establishes nothing about the current one. A reassessment performed on schedule against superseded criteria is current, documented and wrong.
Is observing a deviation really a trigger?+
Several standards make it explicit. The confined space and energy control standards require retraining where there is reason to believe deviations from procedures or inadequacies in knowledge exist. Powered industrial trucks list observation of unsafe operation. In practice it produces a conversation instead, because raising it as competence feels disproportionate, which is exactly what the requirement overrides.
What should the reassessment consist of?+
Observation of the task under realistic conditions against defined criteria, including the response when something goes wrong. Redelivering the training establishes attendance a second time. A knowledge check confirms recall, which is rarely what has lapsed, and neither tests whether the person can perform the job as it is now configured.
How should intervals be set?+
From how quickly the skill degrades without practice and how serious failure would be. Complex, infrequent, high-consequence tasks decay fastest. Emergency response is the clearest case and routinely receives the longest interval because rehearsing it is inconvenient, which inverts the relationship between need and provision.
What should the record contain?+
What has changed since the last assessment, the conditions observed, the criteria applied and the result. The first field is the one usually missing and it determines what the reassessment actually did: confirmed that someone retained a skill, or made a fresh judgement about a task that has materially changed.
The agents
What the agents do with it
Reassessment re-establishes competence. What fails is a calendar without triggers and criteria describing a superseded task.
Fires reassessment on equipment, method and role changes rather than only on interval, and records what changed since the last assessment.
Turns observed deviations from inspections, permits and audits into reassessment triggers rather than coaching notes.
Connects incidents and near misses involving a task to the competence records of those performing it.
Extends reassessment to agency and contractor personnel performing the same tasks under the same changes.
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Meet KnowTrain→Sources
Sources
- ISO 45001:2018 clause 7.2, competence
- 29 CFR 1910.146(g)(2) and 1910.147(c)(7)(iii), retraining triggers, OSHA
- 29 CFR 1910.178(l)(4), refresher training and evaluation, OSHA
- 29 CFR 1926.503(c), retraining for fall protection, OSHA
- ISO 22000:2018 clause 7.2, including externally provided personnel