US States, Counties and municipalities sometimes require OSHA 10 and 30 training for construction, entertainment, and cannabis work, creating overlooked compliance risks.
Not addressing the mandatory requirement for OSHA 10- and 30-hour training can result in workers being blocked from job sites and can potentially create serious legal and safety risks for employers.
Is OSHA Training optional?
Often US employers assume OSHA 10 hour and 30-hour training is optional, but in numerous states and counties, completion of these courses is either a legal requirement or mandated specifically via contract provisions.
This misunderstanding can expose employers to compliance violations, project delays, and preventable liability.
Whilst the federal OSHA does NOT mandate OSHA Outreach Training, the agency does acknowledge that some states, counties and municipalities do in fact require it as a non-negotiable condition of employment.
These requirements are established through state statutes, local ordinances, and public contracting rules rather than federal OSHA standards. This being the case, employers who rely solely on federal OSHA guidance may miss enforceable obligations at the state or local level.
States that Mandate Outreach Training
Several states currently mandate OSHA 10 and 30-hour training for workers on applicable projects.
Currently these states:
- Connecticut,
- Massachusetts,
- Missouri,
- New Hampshire,
- New York,
- Rhode Island,
- West Virginia,
- and Nevada
require OSHA 10 Outreach training for employees on specified public works or construction projects. Workers in supervisory roles are often expected or required to complete OSHA 30 training.
Failure to comply can result in workers being denied access to job sites, removal from projects, or penalties against contractors.
Local Jurisdictions can Mandate OSHA Training
Many local jurisdictions have enabled their own training mandates.
- Miami-Dade County, Florida, requires OSHA 10 training for workers on specific large construction projects.
- Philadelphia mandates OSHA 10 training for construction and demolition workers and OSHA 30 training for supervisory personnel.
- New York City enforces OSHA 10 and 30 training as part of its Site Safety Training program, with additional local training hours required in addition to OSHA outreach courses.
Mandatory OSHA outreach training is not limited just to the construction industry.
OSHA Training is not just for Construction Workers
Nevada for example, extends OSHA 10- and 30-hour training requirements beyond construction. The state requires OSHA outreach training for workers and supervisors in the entertainment industry, including stagehands, rigging crews, lighting, audio, and production personnel.
Nevada also mandates OSHA training for employees working in licensed cannabis cultivation and processing facilities.
California is often seen as a state without mandatory OSHA outreach training requirements, but that presumption is false, as Cal/OSHA enforce their own requirements. Under California Assembly Bill 1775, contractors and subcontractors employing workers who set up, tear down, operate, or maintain live events at public entertainment venues owned by the state or any county must ensure those workers complete OSHA outreach training.
Standard workers must complete OSHA 10-hour general industry training, while supervisors and workers with safety responsibilities must complete OSHA 30-hour general industry training before performing covered work.
OSHA Training can be required by Contract Provisions
Even in states without statutory mandates, OSHA training is frequently required by contract provisions.
Owners, developers, general contractors, public agencies, and insurers often specify OSHA training as a prerequisite for site access. These contractual requirements carry the same practical effect as a legal mandate: workers without proof of training may be barred from entering a site.
Beyond Compliance: Benefits of OSHA Training
In addition to compliance, OSHA outreach training provides employers with a standardized baseline for safety awareness. While OSHA 10 and 30 training does not replace job-specific instruction required by the various OSHA standards, it does help workers to recognize common hazards, understand employer and employee responsibilities, and identify when additional controls or training are required.
While employers can hire an OSHA-authorized trainer to conduct a class at their site, many employers operating across multiple jurisdictions now use online OSHA 10 and 30 training courses to comply with both mandatory requirements and contractual obligations.
Online training allows workers to complete their obligations before reporting to a job site, which can reduce administrative burdens and minimize delays caused by compliance issues.
Summary
As states and municipalities continue to adopt their own safety and training requirements, employers are encouraged to review all applicable laws, ordinances, and contract documents carefully rather than solely relying on federal OSHA standards.
Understanding state and local OSHA training requirements, as well as common contractual expectations, is essential for avoiding compliance gaps and maintaining uninterrupted operations.
