Missouri's Construction Safety Training Act is the most forgiving of the public-works laws on timing. It still has real teeth.
The rule
RSMo 292.675 requires any contractor or subcontractor on a public body's construction project to provide a ten-hour OSHA construction safety program for on-site employees, or a similar program approved by the Division of Labor Standards that is at least as stringent, unless the employee has already completed it.
The 60-day and 20-day windows
- Employees who have not completed the program must do so within 60 days of beginning work on the project.
- An employee who has completed it but cannot produce documentation when asked has 20 days to produce it before being removed and before the employer faces penalties.
Penalties
Under RSMo 292.675, a contractor that misses the deadlines forfeits $2,500 to the public body, plus $100 for each employee for each calendar day of noncompliance after the deadline.
Does the card expire in Missouri?
No. The Department of Labor and Industrial Relations FAQ answers directly: "OSHA completion cards for 10-hour construction programs do not expire."
One nuance: a worker who completed a non-OSHA 10-hour program designed for a particular job function may need more training when moving to a different function.
Fraud warning from the state
DOLIR states that a program which does not actually provide ten hours of training is fraudulent, and that employees relying on it must be removed from the project. Our online course checker helps you vet providers before paying.
Accepted alternatives
The Division lists equivalents including the OSHA 30-hour construction program, MSHA Part 46 and Part 48 new-miner training, and PEC Core Compliance.
Who counts as a "public body" in Missouri
RSMo 292.675 applies to construction projects of a public body, which includes the state, counties, cities, school districts, special districts and other political subdivisions. A county road bridge, a school gym, a water treatment upgrade and a city fire station are all typical covered projects. Unlike several other states, the Missouri statute does not set a dollar threshold, so a small public job can be covered as easily as a large one. Check the contract: public bodies usually include a Construction Safety Training Act clause in their bid documents.
The duty falls on "any contractor or subcontractor" that has a contract with a public body or with a contractor of the public body. Every tier of subcontractor on the project is therefore covered.
Who must be trained
The requirement covers employees who are on site and directly engaged in construction work. The Department of Labor and Industrial Relations explains that this includes laborers, mechanics and other workers performing the construction itself. Office staff who never go to the site are not covered. Delivery drivers who drop off material and leave are generally not treated as on-site workers, but anyone who stays to perform construction work should be trained.
Timelines in practice
Missouri's two windows are generous compared with other states, but they are easy to lose track of on a busy job.
The 60-day training window
A worker who has never completed the program must do so within 60 days of beginning work on the project. The clock starts on the worker's first day on that public project, not their hire date with your company.
| First day on project | Training deadline |
|---|---|
| March 3 | May 2 |
| June 15 | August 14 |
| September 1 | October 31 |
| November 20 | January 19 (next year) |
Online OSHA 10 courses are capped at 7.5 hours a day, so a worker needs at least two days to finish. Most contractors schedule the course in the first two weeks so there is room for delays.
The 20-day documentation window
A worker who has completed the program but cannot produce documentation when asked has 20 days to produce it. This is where a photo of the card in your office file is valuable. If you have it, you can send it the same day. If you do not, the worker has to contact the original trainer or provider, and replacements can take weeks.
Penalties, worked out
A contractor that does not meet the deadlines forfeits $2,500 to the public body, plus $100 for each employee for each calendar day of noncompliance after the deadline. Some examples:
| Workers past deadline | Calendar days late | Forfeiture |
|---|---|---|
| 1 | 10 | $2,500 + $1,000 = $3,500 |
| 3 | 15 | $2,500 + $4,500 = $7,000 |
| 6 | 30 | $2,500 + $18,000 = $20,500 |
The forfeiture is paid to the public body, which usually withholds it from contract payments. On a small public contract, that can wipe out the margin.
Accepted programs, in more detail
The Division of Labor Standards accepts the OSHA 10-hour construction program and programs it has approved as at least as stringent. Its published list includes:
- OSHA 30-hour construction. Covers everything in the 10-hour course.
- MSHA Part 46 and Part 48 new-miner training, for workers whose jobs fall under federal mine safety rules.
- PEC Core Compliance, a program widely used in the energy and utility sector.
Check the Division's current list before relying on any other program. If a worker has a non-OSHA 10-hour program that was designed for a particular job function, DOLIR notes they may need additional training when they move to a different function.
Avoiding "fraudulent" training
DOLIR states plainly that a program that does not actually provide ten hours of training is fraudulent, and that workers who rely on it must be removed from the project. That is a real risk with cheap online courses that promise an "OSHA card" in a few hours. Before you pay for anyone's course:
- Confirm the provider is on OSHA's list of authorized online Outreach providers.
- Make sure the course takes at least two days to complete, because of the 7.5-hour daily cap.
- Confirm the card is the Department of Labor OSHA 10 Construction card, not a company certificate.
Our online OSHA course checker walks through these questions without naming any company as a fraud.
A Missouri compliance timeline
When you sign the contract
- Read the Construction Safety Training Act clause in the bid documents.
- Add the requirement to every subcontract and require subs to send card copies.
- List current workers and their card status.
First week on site
- Record each worker's first day on the project.
- Enroll anyone without a card in an authorized course.
- Collect photos of existing cards, front and back.
Weeks two to eight
- Check course progress weekly.
- Collect temporary certificates when workers finish, then card photos when the plastic cards arrive.
- Escalate anyone who is within 10 days of their 60-day deadline.
When a worker joins mid-project
- Start a new 60-day clock for that worker.
- Ask for their card on the first day.
Missouri compared with nearby states
| State | Timing | Penalty |
|---|---|---|
| Missouri | Within 60 days of starting; 20 days to document | $2,500 + $100 per employee per day |
| New Hampshire | Before beginning work; 15 days to document after a finding | Up to $2,500 + $100 per employee per day |
| West Virginia | Within 21 calendar days on public improvement contracts over $50,000 | See W. Va. Code §21-3-22 |
| Massachusetts | Before beginning work | Immediate removal |
Illinois, Kansas, Iowa, Arkansas and the other neighboring states do not have a general state OSHA 10 law that we track, but general contractors there commonly require it.
Keeping records the state will accept
For each worker record the name, card type, card number, completion date, trainer or provider, the first day on each public project, and a photo of both sides of the card. Do not put an expiry date on OSHA 10 cards: DOLIR says they do not expire. A crew card tracker can calculate each worker's 60-day deadline from their first day and remind you before it passes.
Questions public owners often ask Missouri contractors
Public bodies are responsible for collecting the forfeiture, so their project managers sometimes ask for proof directly. Be ready to answer:
- "Which of your workers on this project have completed the program?" A list with names, card types and completion dates answers this in one page.
- "When did each worker start on this project?" The 60-day deadline depends on it, so record first days per project, not just hire dates.
- "Can you send copies of the cards?" Keep photos of both sides on file so you can send them the same day.
- "Who trained them?" The trainer or authorized online provider is printed on the card. Record it anyway in case the card is lost.
Training a Spanish-speaking crew
The OSHA 10 Construction course is available in Spanish from several authorized online providers and from in-person trainers. OSHA requires training to be given in a language and vocabulary workers understand, so Spanish delivery is the better choice for crews that work mainly in Spanish. The card is the same Department of Labor card. Our Spanish guide, curso OSHA 10 en español, explains the course for workers and can be shared directly.