Connecticut OSHA 10 requirement (C.G.S. §31-53b)

Connecticut ties its OSHA 10 rule to public works projects and to certified payroll. If you bid state or municipal work, the training paperwork travels with your payroll.

What the law says

Section 31-53b of the Connecticut General Statutes requires every contract for a covered public works project entered into on or after July 1, 2009 to include a provision that each contractor furnish proof with the weekly certified payroll for the first week each employee begins work that the person has completed at least ten hours of OSHA-approved construction safety and health training.

The statute also accepts a new-miner program approved by MSHA under 30 CFR 46, and for telecommunications employees, ten hours of training under 29 CFR 1910.268.

The plumber and electrician refresher

Since July 1, 2012, a licensed plumber or electrician subject to Connecticut's continuing-education rules whose OSHA 10 was completed five or more years before starting work on the project must also complete a supplemental refresher of at least four hours, taught by an OSHA-authorized trainer. The Department of Labor's regulations (§31-53b-2) repeat this rule.

History: the $100,000 threshold

The original 2006 act (Public Act 06-175) applied to public building projects of at least $100,000 and accepted cards dated within five years of the project start. The current statute instead uses the public works definitions in §31-53, so check whether your contract is covered rather than relying on the old dollar figure.

Paperwork tips

• The Connecticut DOL payroll certification form tells contractors to attach the OSHA 10 card to the first certified payroll on which the employee appears.
• Keep a clear scan of both sides of every card. The tracker's card photo upload produces exactly what you need to attach.
• Flag licensed plumbers and electricians whose card is approaching five years, so the 4-hour refresher is done before they start on the next public job.

Who is covered by §31-53b

Section 31-53b applies to contracts for public works projects covered by Connecticut's prevailing wage statute, §31-53. That means construction, remodeling, refinishing, refurbishing, rehabilitation, alteration or repair of public works by the state or its agents, or by a political subdivision. Whether your job is covered depends on the prevailing wage thresholds in §31-53, which have changed over the years. The quickest check: if the contract requires Connecticut prevailing wage and certified payroll, assume §31-53b applies too.

The requirement attaches to "each employee" of the contractor who performs work on the project, and the provision must be in every contract and subcontract on the job. That includes small specialty subs who are only on site for a day or two.

Accepted training

The statute names three paths:

1. Ten hours of OSHA-approved construction safety and health training. In practice this is the OSHA 10-hour Construction Outreach card, or an OSHA 30 Construction card, which covers the same topics and more.
2. An MSHA new-miner training program approved under 30 CFR 46, for employees working under federal mine safety rules, such as some quarry and aggregate operations.
3. For telecommunications workers, ten hours of training under 29 CFR 1910.268, the OSHA telecommunications standard.

A General Industry OSHA 10 card is not one of the listed paths for construction work. If a worker shows up with one, plan to put them through the construction course before they start on the project.

How the certified payroll step works

Connecticut contractors on prevailing wage jobs submit weekly certified payroll. Under §31-53b, the proof of training goes with the payroll for the first week each employee begins work on the project. The Department of Labor's payroll certification instructions tell contractors to attach a copy of the OSHA card to the first certified payroll on which the employee appears.

A simple office routine keeps this clean:

• When a new name is added to the project payroll, the payroll clerk checks the card file.
• If there is a card copy, it is attached to that week's payroll.
• If there is no copy, the clerk flags the foreman before the worker's next shift.
• Once attached, the clerk notes the date so it is not sent again every week.

Because the card copy travels with payroll, a clear photo of both sides matters. A blurry photo may be rejected by the awarding authority, and the worker may be asked to stop work until it is replaced.

The four-hour refresher in detail

The refresher rule is the part of Connecticut's law that most often catches contractors out. It applies when three conditions are all true:

• The employee is a licensed plumber or electrician subject to Connecticut's continuing professional education requirements.
• Their OSHA 10 was completed five or more years before they begin work on the project.
• The project is covered by §31-53b.

When all three apply, the worker needs a supplemental refresher of at least four hours, delivered by an OSHA-authorized trainer, before starting on the project. The regulation, §31-53b-2 of the Regulations of Connecticut State Agencies, repeats the requirement and sets out how the refresher is delivered.

Worked examples

The refresher does not replace the OSHA 10 card and does not reset any expiry, because federal OSHA 10 cards do not expire. It is a separate credential you need to record and attach when required.

How to plan for it

• Record the license type and number for every plumber and electrician alongside their OSHA card.
• Calculate the five-year date from the OSHA 10 completion date, not the date the plastic card arrived.
• Ninety days before a licensed worker's card turns five, schedule a refresher if any public works job is on the horizon.
• Keep the refresher certificate with the OSHA card copy so both go to payroll together.

History and why old advice is confusing

When Connecticut first adopted an OSHA 10 rule in 2006, Public Act 06-175 tied it to public building projects of at least $100,000 and accepted cards dated within the five years before the project began. Many websites still repeat that version. The law was later rewritten. The current §31-53b uses the public works definitions in §31-53 and does not have a general five-year limit on cards. The five-year rule survives only in the plumber and electrician refresher. If you see older guidance that says every Connecticut card must be under five years old, it is out of date.

Common Connecticut mistakes

• Waiting for the plastic card. A worker who finished an authorized course can use the trainer's temporary certificate while the card is in the mail.
• Missing the refresher for a licensed electrician. The refresher depends on the license, not the job title on payroll.
• Not attaching proof for short-term subs. A sub on site for one week still files certified payroll for that week, and the card copy goes with it.
• Assuming the old $100,000 rule. Check coverage under the current statute.
• Using a General Industry card. Put the worker through the construction course.

Connecticut and New York jobs in the same year

Many Fairfield County contractors also work in Westchester or New York City. The rules stack, they do not replace each other:

• On a New York State public work contract of $250,000 or more, workers need OSHA 10 before any work under Labor Law §220-h. See the New York OSHA 10 guide.
• On many New York City sites, workers need a Site Safety Training card. See the NYC SST card guide.
• In Connecticut, the card copy goes with the first certified payroll, and licensed plumbers and electricians may need the refresher.

Compare all of these in the state requirements checker.

A Connecticut checklist

• Is the job a public works project under §31-53? If you are filing certified payroll, assume yes.
• Put the §31-53b provision in every subcontract.
• Collect OSHA 10 or 30 Construction card copies before mobilization.
• For licensed plumbers and electricians, check the five-year date and schedule refreshers.
• Attach each employee's proof to the first certified payroll on which they appear.
• Keep license numbers, card numbers, issue dates, trainers and refresher certificates together in your crew card tracker.

What to record for each Connecticut worker

A good card file for Connecticut public works has these fields for every employee:

• Full name as it appears on certified payroll.
• Card type (OSHA 10 or 30 Construction, MSHA Part 46, or 1910.268 telecom training).
• Card number and completion date.
• Trainer or authorized online provider.
• Photo of the front and back of the card.
• For plumbers and electricians: license type, license number, and the date the four-hour refresher was completed, if any.
• The first payroll week the proof was attached, per project.

With these fields in one place, the payroll clerk, the foreman and the project manager are working from the same list, and a request from the awarding authority can be answered the same day.