The Competent Person and Daily Trench Inspections

OSHA could have written a rule for every possible trench condition. Instead, Subpart P relies on a competent person who understands soil, protective systems and site hazards, and who has the authority to act. On an excavation job, this is the most important safety role.

What makes someone a competent person

OSHA defines a competent person (1926.32(f)) as one who is:

1. Capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous or dangerous to employees, and
2. Authorized to take prompt corrective measures to eliminate them.

Both parts matter. A knowledgeable laborer without authority to stop work is not the competent person, and neither is a foreman with authority who can't recognize the hazards. For excavations, OSHA expects the competent person to be knowledgeable about soil analysis, the use of protective systems and the requirements of Subpart P. The employer designates the competent person. A training certificate alone doesn't create one.

Duties Subpart P assigns to the competent person

• Classify soil using visual and manual tests, and reclassify when conditions change (Appendix A).
• Inspect excavations, adjacent areas and protective systems daily and as conditions change (1926.651(k)).
• Remove workers from hazardous areas until precautions are taken (1926.651(k)(2)).
• Check shallow excavations: decide whether a trench under 5 feet shows any indication of a potential cave-in (1926.652(a)(1)(ii)).
• Design structural ramps used only by employees (1926.651(c)(1)(i)).
• Monitor water removal equipment and operations (1926.651(h)(2)), and inspect after heavy rain runoff.
• Examine damaged protective system materials and equipment, and take them out of service if needed (1926.652(d)(3)).
• Decide on slope reductions when surcharge loads are present (Appendix B).

When daily inspections happen

Under 1926.651(k)(1), the competent person inspects:

• Before the start of work each day,
• As needed throughout the shift,
• After every rainstorm or other hazard-increasing occurrence (such as a freeze-thaw cycle, nearby blasting or a utility leak).

These inspections are required only when employee exposure can be reasonably anticipated, but that covers almost every day someone works in or near the excavation.

What to inspect

A thorough inspection covers the excavation, the area around it and the protective system. Use our daily trench inspection checklist as a guide:

• Soil: classification still correct, changes in moisture, new fissures, layers or seepage.
• Walls and edges: tension cracks, bulging, sloughing, spalling, undercutting.
• Protective system: shores tight and spaced per tabulated data, no bent or damaged components, shield in contact with the walls with small gaps, shield depth correct, 18-inch rule met where sloped above.
• Water: accumulation, seepage, pump operation, surface water diverted.
• Atmosphere: testing done where required, ventilation running, gas-powered equipment placed properly.
• Surroundings: spoil 2 feet or more back, surcharge loads, equipment and traffic, adjacent structures, utility marks and exposed lines supported.
• Access: ladders within 25 feet of lateral travel, in the protected area and extending 3 feet above the top; walkways and barricades.

Warning signs that mean "everybody out"

1926.651(k)(2) requires the competent person to remove exposed employees from the hazardous area when there is evidence of a situation that could cause a cave-in, failure of a protective system, a hazardous atmosphere or other hazardous condition, until the necessary precautions are taken. Common triggers:

Documenting inspections

Subpart P doesn't prescribe an inspection form, but writing it down is the best way to prove the inspection happened and to hand off conditions between shifts. A useful record includes the date and time, the trench location and depth, soil classification and the tests used, the protective system, weather, findings and corrective actions, and the competent person's name.

Key takeaways

• A competent person can identify hazards and has the authority to fix them, and is designated by the employer.
• Subpart P gives the competent person soil classification, inspections, water monitoring, ramp design and equipment checks.
• Inspect before work, as needed during the shift, and after every rainstorm or hazard-increasing event.
• When there are signs of a cave-in, protective system failure or bad air, remove workers until it's fixed.

Last reviewed: October 25, 2026 · Free general education based on OSHA 29 CFR 1926 Subpart P. It does not replace the site-specific training and competent person your employer must provide, and it does not issue a certificate. Nothing you enter on this page is saved or sent.