1.6 Trainer Roles, Training Language, Geographic Jurisdiction & Alternative Delivery

1.6 Trainer Roles, Training Language, Geographic Jurisdiction & Alternative Delivery

Core Principle: The Outreach Training Program Requirements regulate the container around a class as carefully as its contents. Four constraints decide whether a class you are planning can be delivered at all: which ATO you report through, where the class is physically held, what language it is delivered in, and whether it is in person, by video conference, or asynchronous. Get any of these wrong and the hours are valid instruction but invalid outreach, and the ATO will not issue cards.

---

1. One ATO Per Industry (Requirements, Section IV.A)

Your Authorizing Training Organization (ATO) is the organization that provided your most recent trainer course or trainer update course. It is your primary point of contact, it processes your OTPRs, and it issues your student cards. Its name and contact information appear on the upper back portion of your Outreach trainer card.

Three rules follow:

1. One ATO per industry. A trainer may be authorized through only one ATO per industry. Being authorized for construction through one Education Center and for general industry through another is fine; being authorized for construction through two Centers is not.
2. Report to the matching ATO. Construction OTPRs go to the ATO that issued your construction trainer card. You may not request construction student cards through the ATO that issued your general industry card.
3. Notify on change. When you change ATOs while your authorization is still current, you must notify the original ATO that you are now authorized through another organization, so that the one-ATO-per-industry rule holds.

After taking an update course, card requests go to the ATO that provided your most recent authorization for that industry.

---

2. Geographic Jurisdiction (Requirements, Section V.K)

Outreach classes may be conducted only in training locations within the geographic jurisdiction of the OSH Act, which is:

The 50 U.S. States, the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, American Samoa, Guam, the Commonwealth of the Northern Mariana Islands, Wake Island, Outer Continental Shelf Lands as defined in the Outer Continental Shelf Lands Act, and Johnston Island.

The Military and Civil Service Exception

Classes delivered outside that jurisdiction are permissible, and the students are eligible for course completion cards, if the students are members of the U.S. military or civil service employees of the U.S. government. In that case:

• No exception request is required; but
• The trainer must ensure the ATO is aware that the persons trained are military members or civil service employees.

A civil service employee is defined narrowly as a federal employee who is Competitive Service, Excepted Service, or Senior Executive Service. Non-civil-service employees, contractors for the U.S. government, and anyone else not subject to the OSH Act cannot be trained outside the jurisdiction.

The Advertising Corollary (V.Q.3)

Trainers may not disseminate or post promotional materials, advertising, or information of any kind — including email, print media, and websites — for outreach training conducted outside the geographic jurisdiction of the OSH Act, and may not post information about such training on any website. Even where the military exception makes the class legal, advertising it is not.

---

3. Training Language and Interpreters (Requirements, Section V.L)

Outreach trainers must teach in a language that students understand. If a student's vocabulary is limited, the training must accommodate that limitation. The primary trainer must be fluent in the training language, or an interpreter may be used — and if an interpreter is used, three rules apply:

That last row is the one candidates miss. A 10-hour class delivered consecutively in English and then in Spanish is a 20-contact-hour class. Combined with the 7.5-hour daily cap, it needs at least three calendar days, not two.

Trainers who conduct outreach in a language other than English may also ask their ATO to add them to OSHA's list of trainers delivering in other languages by submitting their name, industry, organization, city and state, phone, email, website, and language.

---

4. Alternative Training Methods (Requirements, Section V.R)

OSHA's preferred delivery method is standard in-person classroom instruction. Two alternatives exist, and they are treated very differently.

Asynchronous Remote Training — Prohibited for Individual Trainers

Outreach trainers may not conduct asynchronous (not live instructor-led) remote classes. Only OSHA-authorized online Outreach training providers may conduct asynchronous remote outreach classes. An authorized trainer cannot record a 30-hour course, post it to a learning management system, and request cards for the people who clicked through it. OSHA maintains the list of accepted online providers separately at osha.gov/training/outreach/training-providers.

Video Conferencing — Permitted with Conditions

Live, instructor-led training through a remote video conferencing platform is permitted. Five conditions attach.

Advance notification. The primary trainer's ATO must receive advance notification no later than seven calendar days before the scheduled class start date, containing:

• Names of primary and assistant Outreach trainers;
• Names of any guest trainers;
• A copy of the relevant Outreach trainer card(s);
• Guest trainer qualifications;
• The type of hardware, software, or system used to deliver the training — cellular devices are not permitted to deliver or receive training; and
• A list of the materials each student will receive, including when and how they will receive them; and
• A detailed course outline showing each topic and the length of time it will be taught.

Class size. The maximum class size must not exceed 20 students unless a proctor is present for the entire class duration. This is a tighter cap than the 40-student in-person maximum, and it exists so that the trainer can genuinely observe students.

Accessibility. All training must be accessible to OSHA and the respective ATO by submitting a valid class website address link for observation purposes.

Hardware. Trainers and students must use camera and audio hardware for the duration of the entire class. A student dialling in with the camera off has not attended.

Reporting. Classes delivered by an alternative training method must be reported on the OTPR and recorded under the "Other" type of training in block 11 as "remote."

---

5. Stand-Alone Courses and the 10-to-30 Upgrade

Stand-Alone Rule (V.F.10)

Outreach courses are stand-alone courses and must not be conducted as part of, or in conjunction with, other Outreach Training Program training. A trainer may not combine like portions of a General Industry 10-hour and a Construction 10-hour class, teach the remaining portions of each, and claim cards for both. In that situation OSHA issues course completion cards for one 10-hour class in one industry only. Organizations remain free to build wrap-around coursework that is not part of the Program.

The One Permitted Overlap (V.F.9)

The stand-alone restriction does not apply to using portions of a 10-hour class toward a 30-hour class in the same industry. A trainer may provide 20 additional hours to 10-hour students and have them receive 30-hour cards if:

1. The same Outreach trainer conducts both the initial 10 hours and the additional 20;
2. All training from the start of the 10-hour class to the end of the 30-hour class is completed within 180 calendar days;
3. The original 10-hour card is returned to the ATO — if it is not available or not returned, a 30-hour card will not be issued; and
4. The primary trainer completes the reporting requirements in Section VII.

The card surrender exists so the student's documentation reflects 30 hours of training, not an apparent 40.