It's Time to Stop: This Practice Violates OSHA's Own Rules
OSHA explicitly states in the 2254 Outreach Training Program manual that completion cards are not intended to be used as proof of competency and should not be required for hiring or work authorization. Yet thousands of employers continue this illegal practice daily.
If you're an HR manager, safety director, or hiring manager who requires OSHA 10 or 30-hour training cards as a condition of employment, you're violating federal law. That's not an exaggeration. It's a fact supported by OSHA's own documentation, the Occupational Safety and Health Act, and the General Duty Clause.
This blog will break down exactly why this common practice is not only inappropriate but potentially exposes your company to serious legal and regulatory liability.
Every day, thousands of job postings across the United States list "OSHA 10" or "OSHA 30" as a requirement. Construction companies won't let workers on site without the card. HR departments reject qualified candidates who lack the certification. Insurance companies recommend requiring them. Everyone's doing it.
Here's the problem:
OSHA never authorized this use. In fact, they explicitly forbid it. Yet the practice has become so normalized that most people don't even question it. It's time to set the record straight.
The official OSHA Outreach Training Program manual (OSHA 2254) is unambiguous. Here's what it says:
"The OSHA Outreach Training Program is not intended to be a certification program. The completion cards are not to be used as proof of qualification or competency in the subject matter. Outreach training provides a basic awareness of common job site hazards."
— OSHA Publication 2254, Outreach Training Program
"It is important to note that this is a voluntary program and does NOT meet training requirements for any OSHA standards."
— OSHA Publication 2254, Training Requirements and OSHA Standards Manual
Let that sink in: OSHA explicitly states that the 10 and 30-hour training does NOT fulfill ANY OSHA training requirement. Yet employers treat it as if it does.
If OSHA says it doesn't meet their training requirements, how can you legally use it to prove someone meets OSHA training requirements?
When you require OSHA 10 or 30-hour training, you're requiring training that OSHA explicitly says does NOT meet any OSHA standard training requirement.
Think about the implications: Every OSHA standard that requires training—lockout/tagout, confined spaces, fall protection, hazard communication, respiratory protection—NONE of those requirements are satisfied by completing a 10 or 30-hour course.
Here are just a few OSHA standards with explicit training requirements that the 10/30-hour course does NOT fulfill:
Requires training on hazards, duties, and rescue procedures
Requires training on energy control procedures
Requires training on proper use, limitations, and maintenance
Requires training in fall hazards and protection systems
Requires training on specific chemicals and SDSs
Requires training on proper ladder selection and use
The 10 or 30-hour card does NOT satisfy the training requirements for ANY of these standards. Yet if you require the card, you're implying that it does.
When you put "OSHA 10 required" in a job posting or on your site access policy, what are you actually verifying? That someone sat through 10 hours of general awareness training that:
You're requiring something that OSHA says has no regulatory value—and then treating it as if it does.
The General Duty Clause requires employers to provide a workplace "free from recognized hazards that are causing or are likely to cause death or serious physical harm."
Here's the critical connection:
When you require an OSHA 10 or 30-hour card as proof of safety competency—which OSHA explicitly says it is not—you are creating a false sense of security. You're certifying workers as "qualified" based on awareness training, not actual competency verification.
By treating a 10-hour awareness course as a qualification, you're placing unqualified workers in positions where they may face hazards they don't actually know how to control. The card gives the appearance of competency without the substance.
The General Duty Clause requires employers to ensure workers are actually competent to perform their work safely. A 10-hour overview doesn't establish competency—it only provides awareness. If you're relying on that card as evidence of training, you're falling short of your legal duty.
When workers with only awareness-level training are put in situations requiring actual competency, that's a recognized hazard. You know (or should know) that the OSHA card doesn't equal qualification. Pretending otherwise puts workers at risk.
If an incident occurs and OSHA investigates, they will ask: "Was this worker competent to perform the task?"
If your defense is "They had an OSHA 30-hour card," OSHA will cite their own manual proving that card is not evidence of competency. You've just admitted you didn't verify actual qualification—a General Duty Clause violation.
The Occupational Safety and Health Act of 1970 was created to ensure safe and healthful working conditions. The intent was to establish real standards and actual competency, not symbolic gestures.
An OSHA 10 or 30-hour card meets none of these criteria. It's an awareness course—nothing more. When you require it as a condition of employment, you're substituting a checkbox for actual qualification. That undermines the entire purpose of the OSH Act.
Requiring OSHA cards gives the appearance of caring about safety without actually verifying competency. It's checking a box to satisfy HR, insurance, or industry norms—not ensuring workers are truly qualified.
Workers and employers alike believe the card means something it doesn't. This false confidence leads to inadequate training, unqualified workers in critical roles, and preventable incidents.
OSHA explicitly says these cards are not proof of competency and should not be used as hiring requirements (OSHA 2254 manual).
The General Duty Clause requires that workers be actually competent—not just aware. Relying on awareness training as proof of qualification violates this duty.
The OSH Act demands real competency, not symbolic gestures. Requiring a card that doesn't verify knowledge undermines the entire purpose of workplace safety regulation.
You're creating legal and regulatory risk by misrepresenting worker qualifications and failing to ensure actual competency.
You're operating in violation of OSHA's guidance, potentially violating the General Duty Clause, and exposing your company to liability. It's time to change.
Verify actual competency through knowledge assessments, task-specific training, and proper documentation. That's what the law requires—and what actually keeps workers safe.
EHSINDEX provides regulation-based knowledge assessments that actually measure competency—not just awareness. Our assessments benchmark candidates against the standards that matter.