The OSHA 10-Hour class in construction safety is a flexible, well-designed product that has served the industry for more than 20 years. It is the foundation of OSHA’s safety training courses. The 10-Hour course is taught at Laborers’ training centers all across the country.

In October, for reasons that remain unexplained, OSHA announced plans to change the qualifications for 10-Hour instruction. Currently, instructors must pass the OSHA 500 and have at least five years of experience in the industry. The change would require passage of the OSHA 510 or the equivalent certified industrial hygienist (CIH) or certified safety professional (CSP) exams. For a variety of reasons (see below), most union-associated training center instructors have never had reason to acquire CIH or CSP credentials or take the OSHA 510.

“Why would OSHA make such a change?” asks LIUNA General President Terence M. O’Sullivan. “The construction industry needs this training. Restricting the availability and increasing the cost makes absolutely no sense.”

The announcement provoked a backlash from the union sector of the industry, and OSHA has back-peddled, indicating that it will re-consider the requirement. Other proposed changes – modifying the required modules and adding an expiration date on the 10-Hour card that would require periodic refresher training, perhaps every three to five years – also drew criticism in some quarters. The dust has not settled on this controversy, and the LHSFNA and the Laborers-AGC Education and Training Fund are actively engaged in shaping any changes that may finally be adopted.

“The most important change that is needed,” says O’Sullivan, “would be for OSHA to require the 10-Hour for ALL construction workers. Currently, OSHA standards merely require workers to be trained on all the hazards they will face, but do not specify how much training is required, by whom or on what. The non-union sector is notorious for cutting corners on this. A mandatory OSHA 10-Hour requirement would level the playing field and, for the first time, clarify the minimum training requirement and thereby make the industry safer for all.”

Recently, the OSHA 10-Hour has been the focus of LIUNA’s efforts in several states to upgrade safety on projects that involve state funding. Over the last couple years, LIUNA successfully lobbied legislatures in Rhode Island, Massachusetts, Connecticut, New Hampshire and New York to require the training for all workers on state projects. Other states are considering similar legislation. For LIUNA signatory employers, the training is available at no cost at Laborers training centers (which are supported through negotiated contract contributions), but non-union employers may have to pay for outside instruction.

Despite the cost of training, says O’Sullivan, “The OSHA 10-Hour is the most basic safety course in our industry. No construction worker should go to work anywhere without the benefit and protection of this instruction.”

As to the proposed, added certification requirement for 10-Hour instructors, LHSFNA Senior Safety and Health Specialist Travis Parsons concedes that OSHA needs to find a way to monitor the quality of instruction that is offered by the mushrooming array of private training vendors. “But requiring this level of certification is not the answer. Intended or not, the fallout would be disproportionately serious for union employers and workers. At the Laborers, our joint labor-management training program has been in place for almost 40 years. Most of our instructors come up from the ranks. They start out as construction Laborers and, later in their careers, based on outstanding work habits, are recruited to become instructors at our training centers. Then, they are well-schooled in both the technical and instructional sides of Laborers’ training. Most have been teaching for many years.”

To pass the OSHA 510 exam, Laborers training instructors would have to pay registration fees for 30 hours of college training, complete the course work and, then, pay for and pass the exam. This would roughly double the costs now associated with acquiring OSHA 500 certification.

“Though few Laborers’ training instructors are CIHs or CSPs, their hands-on experience is invaluable, and they’ve passed the OSHA 500 exam,” says Parsons, who has a master’s degree in industrial hygiene and is OSHA 500-certified. “They are at least as qualified to teach the OSHA 10-Hour as those with more academic orientations and far less field experience.”

[Steve Clark]