Instructor 90 Day Grace Period & Student Completion Card Requests

Dec 12, 2018

The Occupational Safety and Health Administration’s (OSHA) Directorate of Training and Education (DTE) has asked the ET&D Partnership to communicate with all partnership companies and their trainers to ensure they are aware of recent changes regarding instructor reauthorization and issues arising from late submissions of requests for course completion cards for students completing the Supervisory Leadership Skills Outreach Training course (20‐Hour).

Important Change in Instructor 90 Day Grace Period

As part of its continuing effort to improve the Outreach Training Program, OSHA will be eliminating the authorized trainer “90‐day grace period” described in Section III.B.1.,2, and 4 of the OSHA Outreach Training Program Requirements. This change will be included in the next published revisions of the OSHA Outreach Training Program Requirements and applicable sections of each Industry Procedures document, and will become effective January 1, 2019. However, Section III.C. of the OSHA Outreach Training Program Requirements (Trainer Update Exemption for Overseas Military Service) remains in effect while the Agency evaluates the impact of this change.

The intent of the elimination of the grace period is to reduce confusion regarding trainer authorization status, and to encourage trainers to maintain their trainer authorization(s). OSHA urges authorized trainers to schedule registration, attendance, and completion of the relevant Trainer Update course well in advance of their trainer authorization expiration date.

Authorized trainers that let their authorization lapse will be ineligible to attend a Trainer Update course, and will be required to meet all prerequisite requirements to attend the relevant Trainer course, to include having successfully completed the applicable OSHA Standards course(s) within seven calendar years of attendance at the Trainer course. Extensions of trainer authorizations that expire on or after January 1, 2019, will not be granted.

Receipt of Student Completion Card

As stated in Section VIII. A & B of the OSHA Outreach Training Program Requirements, authorized trainers are to ensure student course completion cards are received by all students within 90 calendar days of the course completion date.

  • Authorized trainers are required to submit the course completion records to their authorizing Training Organization (ATO) within 30 calendar days of course completion.
  • The ATO will then have 30 calendar days to process the cards and return them to the Authorized Trainer.
  • Once the authorized trainer has received the course completion cards from the ATO, they must provide the completion cards to the students within 30 calendar days, but no later than 90 calendar days after class completion.

The above applies to instructors requesting either the OSHA 10‐hour and/or 30‐hour cards.

For those instructors applying for Supervisory Leadership Skills Outreach Training cards (aka OSHA 20‐ Hour and/or the SLSOT course), the exact same periods stated above and in the OSHA Outreach Training Program Requirements apply.

  • Once started, the trainer has 6‐months to complete the Outreach training courses.
  • Upon completion, the trainer must apply for the cards within 30‐days of completing the training.
  • DTE has 30‐days to send the cards to the trainer
  • The trainer has 30‐days to get the cards to the student.

The primary difference is the ET&D trainer currently requests 20‐Hour cards from DTE in Arlington Heights, IL and not their Authorizing Training Organization (ATO). 

A current copy of the Outreach Training Program Requirements is available for free download at the following site: