1.5 Required Outreach Curriculum, Focus Four Objectives & Student Materials

1.5 Required Outreach Curriculum, Focus Four Objectives & Student Materials

Core Principle: An OSHA-authorized Outreach trainer has wide latitude over how to teach, but far less over what to teach. Two pieces of curriculum are fixed by OSHA and published on osha.gov: the Introduction to OSHA module required in every class, and the Focus Four Hazards terminal and enabling objectives in Appendix C to the Construction Industry Procedures. Trainers must use the required curriculum, must furnish students with reference materials, and must hand over specific contact information before the class ends.

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1. Required Curriculum (Requirements, Section V.I.1)

Requirements Section V.I.1 states that Outreach trainers must use required curriculum as noted on OSHA's Outreach Training Program webpage, and that trainers must maintain awareness of current Program requirements. Two items presently carry that status.

Introduction to OSHA — 1 Hour, Every Class, Every Industry

The Introduction to OSHA module is the single piece of curriculum that appears in every Outreach class — construction, general industry, maritime, and disaster site worker alike. For construction it is a required topic of one hour in both the 10-hour and the 30-hour class (Construction Industry Procedures IV.A.1.a and IV.B.1.a).

OSHA publishes the required content, and the Construction Industry Procedures describe what it must cover:

• Workers' rights under the OSH Act;
• Employer responsibilities;
• How to file a complaint with OSHA;
• Helpful worker safety and health resources; and
• Sample documents, specifically a weekly fatality and catastrophe report, safety data sheets, and the OSHA Log of Work-Related Injuries and Illnesses (OSHA Form 300).

The published package includes an instructor guide, student handouts, and participatory activities, available from the teaching-aids page at www.osha.gov/training/outreach/teaching-aids. A trainer who substitutes a home-made "What is OSHA?" slide deck for the published module has not met the requirement.

Focus Four Hazards Lesson Plans

OSHA publishes lesson plans for each of the Focus Four hazards at www.osha.gov/training/outreach/construction/focus-four. They pair with the mandatory objectives described below.

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2. Appendix C — The Focus Four Terminal and Enabling Objectives

This is a genuinely unusual piece of OSHA policy, and it is easy exam material because it is short and absolute. Appendix C to the Construction Industry Procedures fixes the learning objectives for all four Focus Four lessons. Trainers do not get to rewrite them.

The Terminal Objective (TO)

One terminal objective, with the hazard name swapped in:

Given current OSHA and industry information regarding construction worksite illnesses, injuries, and/or fatalities, the student will be able to recognize [falls, electrocution, struck-by, caught-in or between] hazards in construction.

The Four Enabling Objectives (EO)

For each of the Focus Four hazards, the student will be able to:

The Two Binding Instructions

Because these objectives are the expected student outcomes, Appendix C directs that trainers:

1. Must not vary from these objectives when planning the training session; and
2. Must follow the participatory training model by applying effective training techniques.

Exam Trap: A candidate who writes a beautifully constructed ABCD objective of their own invention for the falls lesson — "Given a jobsite photograph, the student will identify three fall hazards with 100% accuracy" — has done a fine job of instructional design and has still violated Appendix C. Write your own objectives for elective and optional topics; use OSHA's for the Focus Four.

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3. Student Materials and Trainer Contact Information (V.I.3 and V.I.4)

Student Reference Materials Are Mandatory

Requirements Section V.I.3: Outreach trainers must provide students with reference materials that highlight the key training points for each topic covered. A student who leaves a 30-hour class with nothing but a memory of the slides has not been given what the Program requires. Acceptable materials include OSHA QuickCards, fact sheets, pocket guides, topic handouts, and the Introduction to OSHA student handouts.

Trainer Resources Are Not Student Materials

Section V.I.2 contains a warning worth repeating in class: the materials a trainer receives from their ATO during the trainer course are intended for use by Outreach trainers and are not designed for students. Photocopying the #500 participant manual and calling it a student handout misses the point — students need hazard-recognition material, not standards-interpretation material.

The Four Things Every Student Must Receive

Section V.I.4 requires the trainer to provide all students with:

1. The trainer's name (and any assistant trainers' names);
2. The trainer's contact information;
3. The name of the Authorizing Training Organization; and
4. Instructions on how to request a replacement student course completion card.

Trainers must also present their original trainer card — not a copy — at the beginning of each Outreach class, and on student request. Section V.A.6 adds that the trainer must maintain physical possession of that card at all times, and must promptly contact the ATO for a replacement if it is lost, damaged, stolen, misprinted, or rendered obsolete by a name change.

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4. Ineligible Training and Topics

Three categories of instruction can never be counted toward outreach hours, regardless of how safety-relevant they feel (Requirements V.H.3; Construction Industry Procedures IV.C):

That third row is the one that catches experienced safety managers, because it feels backwards. Remember the Program's own framing: outreach training does not meet the training requirements contained in any OSHA standard, and by the same logic, training conducted to satisfy a standard cannot be reported as outreach.

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5. Sector-Specific Emphasis Training

If an organization wants an outreach course tailored to a specific industry sector, Requirements Section VI provides a formal route rather than improvisation. The organization submits a written request to the OSHA Office of Training and Education containing:

• A justification naming the sector, why the training is needed, why the Program's inherent flexibility is insufficient, and the training goals and objectives;
• A topics listing with minimum instructional times that aligns with the applicable industry procedures; and
• Training materials — a copy of everything developed, the delivery methods, Section 508 accessibility compliance, and an annual review with updated materials provided to OSHA for posting.

An individual trainer cannot create sector emphasis training unilaterally and report it as outreach.