If you’ve read the Physical Agents Regulations, 2024 or the Noise Exposure Regulations, 2024 and gone looking for a licence to apply for, you won’t find one. There is no central register, no SANAS accreditation body, no single certificate that makes you a “Competent Person” under the new framework. That surprises a lot of employers — and it’s exactly where the compliance risk, and the commercial opportunity, both sit.
The old model is gone
Under the Environmental Regulations of 1987, physical hazard monitoring largely ran through Approved Inspection Authorities (AIAs) — SANAS-accredited bodies operating under a formal licensing regime. That model has been replaced. The Physical Agents Regulations, 2024 and Noise Exposure Regulations, 2024 (promulgated 6 March 2025, Government Gazette No. 52226) define “Competent Person” functionally instead: knowledge, training, experience, and — where the function calls for it — agent-specific qualifications, plus familiarity with the Act and its regulations.
No third party approves you. Your employer, or your client, does — and so, eventually, does an inspector or a court, if it comes to that.
Two different competence bars, not one
The regulations quietly split “competence” into two tiers, and conflating them is the single most common gap we see in employer systems:
Risk assessment competence — general knowledge, training, and experience relevant to the task, plus familiarity with the legislation. A seasoned SHE practitioner with a recognised qualification (NEBOSH, SAMTRAC, a relevant NQF-registered programme) and demonstrable workplace experience can usually meet this bar for identifying and assessing physical agent hazards.
Monitoring and measurement competence — the same, plus agent-specific technical qualifications. This is the tier that catches people out. Running a WBGT heat stress survey, a noise dosimetry programme, or a vibration assessment isn’t something a general safety qualification covers, and an inspector — or opposing counsel in a prosecution — will ask for the specific evidence behind the “competent person” who signed off the report.
Where the real qualification comes from
For the monitoring tier, South Africa’s recognised professional route runs through the Southern African Institute for Occupational Hygiene (SAIOH) — a SAQA-recognised body affiliated with the International Occupational Hygiene Association (IOHA). SAIOH operates a three-tier registration system:
| Registration | Entry point | Scope |
|---|---|---|
| Occupational Hygiene Assistant (ROHA) | Grade 12 / entry-level | Supervised, entry-level work |
| Occupational Hygiene Technologist (ROHT) | 3-year technical qualification or OHTA/BOHS module route + portfolio | Covers most commercial Physical Agents monitoring work — heat/cold stress, noise, vibration, illumination, indoor air quality |
| Occupational Hygienist (ROH) | 4-year degree + experience | Full scope, senior technical authority |
The practical route for an experienced H&S or engineering professional is usually the ROHT path: complete the relevant OHTA/BOHS modules for the stressors you want to cover, build a documented Professional Experience Portfolio from real site work, then apply to SAIOH for evaluation and sit the oral assessment.
Two functions sit outside this entirely, and no amount of SAIOH registration will cover them:
- Medical surveillance requires sign-off from a registered Occupational Medicine Practitioner (HPCSA)
- Audiometric testing requires a registered audiometrist operating under the Code of Practice for Audiometry
What this means for building a compliant service
For employers, the honest takeaway is that “competent person” is not a box you tick once. It’s a standing, documented position you need to be able to defend — qualifications, training records, calibrated instrumentation, and a clear line between who assesses risk and who is qualified to measure it.
For consultants and in-house H&S teams looking to build this capability, the sensible model isn’t to chase every qualification personally. It’s to structure a service around it: a lead practitioner who owns the risk assessment, the legal interpretation, and the management-system layer, supported by a panel of specialists — a registered occupational hygienist for monitoring, an OMP for medical surveillance, a registered audiometrist for noise testing. That’s a defensible, scalable structure, and it’s the one the regulations were arguably designed to enable.
Where AOAL comes in
AOAL Consulting Services helps organisations work through exactly this — building compliant, defensible Competent Person structures under the Physical Agents and Noise Exposure Regulations, and closing the gaps before an inspector or an incident finds them first.
The same pattern — regulations moving from prescriptive licensing toward documented, defensible competence and appointment structures — is playing out across South African HSE law. See our breakdown of the Draft Construction Regulations 2025 for how it’s reshaping construction H&S appointments specifically.
Not sure whether your current “competent person” appointments would hold up? Get in touch with AOAL to discuss a legal compliance review.
This article is for general information purposes and does not constitute legal advice. AOAL recommends confirming current SAIOH accreditation criteria directly with SAIOH, as professional body entry requirements are periodically updated.
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References
South Africa (2025) Occupational Health and Safety Act, 1993 (Act No. 85 of 1993): Physical Agents Regulations, 2024, Government Gazette No. 52226, Government Notice R.5952, 6 March. Pretoria: Department of Employment and Labour.
South Africa (2025) Occupational Health and Safety Act, 1993 (Act No. 85 of 1993): Noise Exposure Regulations, 2024, Government Gazette No. 52226, Government Notice R.5953, 6 March. Pretoria: Department of Employment and Labour.
Southern African Institute for Occupational Hygiene (SAIOH) (n.d.) Registration Criteria and Categories. Available at: saioh.co.za (Accessed: 12 August 2026).
Webinar courtesy of SAIOSH
