1.2 Class Administration, Attendance & Delivery Limits

Class Administration, Attendance & Delivery Limits

Core Principle: To preserve instructional quality, ensure adult learner engagement, and prevent fraudulent 'card milling,' OSHA enforces strict parameters governing class sizes, daily contact hours, course duration, student attendance, makeup instruction, guest presenters, and multimedia usage. Violating any of these administrative delivery standards places the course in non-compliance and risks card revocation.

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1. Class Size Restrictions and ATO Approvals

The OSHA Outreach Training Program Requirements establish clear upper and lower limits on the number of students permitted in a single Outreach class:

The Minimum Class Size Rule: 3 Students

• An authorized trainer must train a minimum of three (3) students per class.
• Pedagogical Rationale: Outreach training relies heavily on peer interaction, small-group hazard identification exercises, adult discussion, and collective problem-solving. A one-on-one or two-student session does not provide the dynamic group interaction intended by the program.
• Advance ATO Waiver: A trainer may not conduct a class for one or two students without obtaining prior written approval from their Authorizing Training Organization (ATO). The trainer must submit an exception request explaining the extenuating circumstances before the class begins.

The Maximum Class Size Rule: 40 Students

• A single Outreach class cannot exceed forty (40) students.
• Instructor Span of Control: Classes exceeding 40 participants compromise the instructor's ability to monitor engagement, facilitate participatory workshops, assess learning outcomes, and maintain classroom discipline.
• Advance ATO Approval: Training more than 40 students requires prior written authorization from the ATO. The ATO may require an additional co-authorized trainer to be present and co-teach the course.

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2. Daily Student Contact Hour Limits and Class Spacing

OSHA mandates strict limits on how many instructional hours may be delivered in a single 24-hour calendar day.

The 7.5-Hour Daily Maximum

• Maximum Contact Hours: Training is strictly limited to a maximum of 7.5 student contact hours per calendar day.
• Definition (Requirements V.F.3): Student contact hours are the time spent covering course content. They exclude:
  • Meal breaks and all other breaks
  • Administrative matters such as taking attendance
  • Administering optional tests — testing is never instructional time and never counts toward the 10 or 30 hours
  • Registration, course evaluations, and card distribution
• The 10-Hour Session Envelope: An individual training session may run no more than 10 consecutive hours in total (7.5 contact hours plus breaks, meals, attendance, and testing). No more than 10 hours of training may be conducted in any 16-hour period, and an 8-hour minimum break is required if 7.5 or more hours of training occur within a 16-hour period.

Mandatory Minimum Calendar Days

Because of the 7.5-hour daily cap, Outreach courses cannot be compressed into single-day marathons:

• 10-Hour Construction Course: Must be delivered across at least two (2) calendar days. A trainer can never deliver a 10-Hour course in one calendar day (e.g., 7.5 hours on Day 1 and 2.5 hours on Day 2, or two 5-hour days).
• 30-Hour Construction Course: Must be delivered across at least four (4) calendar days (e.g., four days of 7.5 contact hours, or five days of 6 contact hours).

Mandatory Break and Meal Schedules

• Meal Breaks: Any training session lasting six (6) hours or longer in a single day must include a dedicated meal break of at least thirty (30) minutes.
• Rest Breaks: Instructors must provide at least one 10-minute rest break for every two (2) hours of continuous instruction.
• Breaks cannot be accumulated or skipped to dismiss students early, and break minutes cannot be counted toward instructional contact hours.

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3. The 180-Day Completion Window

• Duration Rule: An Outreach training course—from the first instructional minute of Day 1 to the final minute of the last session—must be completed within 180 calendar days.
• Flexible Delivery Formats: Instructors have the flexibility to schedule classes over consecutive days, spread them across consecutive weekends, or deliver two hours per evening once a week, provided the entire course finishes within the 180-day window.
• Consequences of Exceeding 180 Days: If a class exceeds 180 calendar days from start to finish, the course is invalid. Students cannot receive completion cards for that training.

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4. Student Attendance Mandate and Makeup Training Policies

OSHA Outreach training requires verified, comprehensive student participation.

100% Attendance Requirement

• Every student must attend 100% of all scheduled contact hours to receive an official Department of Labor student course completion card.
• No Partial Cards: There is no such thing as a partial card, fractional credit, or an excused absence from mandatory topics. If a student misses a single 30-minute module, they cannot receive a card until that specific topic is completed.

The 50% Rule for Makeup Training

When a student misses instructional time due to an unavoidable illness, family emergency, or operational conflict, makeup training is permissible under strict regulatory conditions:

1. The 50% Threshold: To be eligible for makeup training, the student must have completed at least 50% of the instructional contact hours during the original class offering (at least 5.0 contact hours in a 10-Hour class; at least 15.0 contact hours in a 30-Hour class).
2. Ineligibility: If the student completed less than 50% of the course, they are ineligible for makeup training and must retake the entire course from the beginning.
3. 180-Day Limit: All makeup training must be completed within the original 180-calendar-day window from the initial course start date.
4. Who May Deliver It: Makeup training may be performed by the primary Outreach trainer or by an assistant Outreach trainer. A student may also make up a portion with the guest trainer who originally taught that portion, provided the primary trainer coordinates it and the student has access to the primary trainer for follow-up questions. The primary trainer remains responsible for all reporting.
5. Small Classes Permitted: Makeup training classes consisting of fewer than three students are expressly permitted — the three-student minimum does not apply to makeup sessions.
6. Documentation: Makeup documentation must be submitted separately from the original OTPR and must include the student's contact information, completed topics and contact hours, missed topics and contact hours, and the reason the student could not complete the original class. A new OTPR carrying the makeup class end date is then submitted.

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5. Primary, Assistant and Guest Trainers (The 50% and 20% Rules)

Requirements Section V.M defines three distinct trainer roles. This is one of the most frequently mis-taught areas in the whole program, so learn the two percentages and which role each one attaches to.

The Primary Outreach Trainer (V.M.1)

The primary trainer owns the class. This individual must:

• Design and coordinate the class;
• Teach a minimum of 50% of the class (except as modified by the assistant-trainer rule below);
• Be in attendance at all times to answer questions (again, except under the assistant-trainer rule);
• Document the class and retain class documentation, including student attendance; and
• Maintain a list of assistant and guest trainers used for each class, their qualifications, and the topics each one delivered.

Assistant Outreach Trainers (V.M.2)

• An assistant Outreach trainer must be OSHA-authorized in the specific industry being delivered (construction, here).
• Using assistant trainers relieves the primary trainer of the duty to attend every session — but when assistants are used, the primary trainer must still be in attendance for at least 20% of the class.
• The primary trainer still documents, coordinates, and retains records for all sessions.

Guest Trainers (V.M.3)

• A guest trainer is a subject matter expert who is not an OSHA-authorized Outreach trainer — a master rigger, a certified industrial hygienist, a utility locator, a crane inspector.
• At least one OSHA-authorized Outreach trainer must be in attendance at all times while a guest trainer is presenting.
• OSHA publishes no percentage cap on guest-trainer time. The limit is indirect: because the primary trainer must personally teach at least 50% of the class, guest and assistant delivery together cannot displace more than half of it.
• Records: The primary trainer must retain a list of each guest trainer's name, the specific topics taught, the cumulative class time spent on each topic, and the guest trainer's qualifications (Requirements V.P).

[!WARNING] Exam Trap: There is no "80/20 guest trainer rule" in the Outreach Training Program Requirements. The two numbers that matter are 50% (minimum the primary trainer personally teaches) and 20% (minimum attendance by the primary trainer when authorized assistant trainers are used). Anyone on the Outreach Trainer Watch List may not be used as an assistant or guest trainer at all.

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6. Video and Multimedia Delivery Limits (The 25% Rule)

Passive video watching is contrary to adult learning principles and violates Outreach training standards.

The 25% Multimedia Cap

• Videos, pre-recorded films, and multimedia presentations cannot account for more than 25% of total course contact time:
  • In a 10-Hour course: Video/multimedia is capped at a maximum of 2.5 hours (150 minutes).
  • In a 30-Hour course: Video/multimedia is capped at a maximum of 7.5 hours (450 minutes).
• Active Facilitation: The remaining 75%+ of instructional time must consist of direct, interactive adult learning methods (instructor-led discussions, case study analyses, small-group hazard hunts, mock inspection walkthroughs, and hands-on demonstrations).
• Prohibition on Unattended Video: A trainer may never turn on a video and leave the classroom. All videos must be directly introduced, actively monitored, and followed by structured discussion or comprehension checks.