A distinctive feature of contemporary professional, vocational and continuing education is the prevalence of the 'competency' approach. So-called competency-based education or training (CBE/T) can be adopted as a basis for programs of learning, frameworks for development within occupations, or for national systems of vocational education. Its application is observed across a wide range of occupations -- from gardening to teaching to piloting aircraft -- and to diverse levels of expertise, from entry-level to continuing professional development. Although acceptance of the competency-based approach is widespread, there is still debate about its meaning and merits. Just as diverse applications can be cited, there are varying definitions and rationales for the approach. And while CBE/T appeals to common sense, there have been and continue to be challenges and criticisms from different disciplinary perspectives and with respect to its features and impacts. In this paper a special set of problems with CBE/T is examined. A model is presented which differentiates three interrelated components: competence, "competency texts" and "CBE/T." By separating the definition into three components, a little-understood characteristic of the approach is foregrounded -- processes of interpretation that translate between these components. The model thus exposes 'hermeneutic' dimensions of the competency approach which are argued to be key to understanding a number of problems associated with CBE/T. The paper concludes that the hermeneutic features of the competency approach represent challenges for basic assumptions of the model.