Rhode Island is the one state that says workers must keep the physical card on their person.
The rule
R.I. Gen. Laws §37-23-1 requires all contractors on municipal and state construction projects with a total cost of $100,000 or more to have an OSHA ten-hour construction safety program for their on-site employees, taught by OSHA-trained instructors using an OSHA-approved curriculum. Graduates receive the OSHA card.
Carry it, don't lend it
Subsection (b) requires every person to have the card on their person at all times while work is actually being performed on a covered project. It also bans transferring a card to another person. Lending a card to a coworker is a violation in itself.
Penalties
Under §37-23-8, the Department of Labor and Training may issue cease-and-desist orders and administrative penalties of $250 to $950 per offense, per day.
What this means for your crew
- A photo on the office's file is not enough on a Rhode Island public job. The worker needs the card in their wallet.
- Lost cards are a real risk. Replacements come only through the original trainer, only within five years of the class, and only once. See lost OSHA card replacement.
- Keep a photo anyway, so you know who issued it if a replacement is needed.
Who the Rhode Island law covers
Chapter 37-23 of the Rhode Island General Laws covers construction projects owned by the state or a municipality with a total cost of $100,000 or more. In practice that includes schools, town halls, public safety buildings, state facilities and many road and utility projects. The requirement attaches to the contractor's on-site employees, which means every tier of subcontractor is covered on a qualifying job.
The training must be an OSHA ten-hour construction safety program taught by OSHA-trained instructors using an approved curriculum. Section 37-23-5 says the state's Board of Safety Awareness has endorsed OSHA's Outreach Training Program as the way to deliver and document the 10-hour and 30-hour construction courses. So the card you need is the standard Department of Labor OSHA 10 Construction card, or an OSHA 30 Construction card, which covers the same topics and more.
Why the carry rule changes how you manage cards
Most states let a contractor prove compliance with paperwork in the office. Rhode Island adds a personal requirement: the worker must have the card on their person at all times while work is being performed on a covered project. Three practical effects follow.
- Lost cards become a site problem. A worker who leaves their wallet at home is out of compliance that day, even if they have taken the course.
- Photos are a backup, not the answer. Keep photos so you can prove the course was taken and request a replacement, but the worker still needs the physical card.
- Card lending is easy to spot and serious. The statute bans transferring a card. If an inspector compares names and ID, a borrowed card will show.
A morning check that takes two minutes
On covered projects, many foremen add a card check to the morning huddle once a week. Workers hold up their card, the foreman ticks the list, and anyone without a card is flagged before work starts. It also catches cards that are worn out or cracked, which may need replacing before they become unreadable.
Replacing a lost card in time
Replacement cards come only from the trainer or online provider who issued the original. OSHA's outreach rules allow one replacement, and only within five years of the original class. After that the worker must retake the course. For Rhode Island jobs:
- Note each worker's trainer or provider when you first record the card.
- If a card is lost, contact the trainer the same day. Replacement can take weeks.
- If the card is older than five years, enroll the worker in a new OSHA 10 course right away. An online course takes at least two days because of the 7.5-hour daily cap.
Our guide to lost OSHA card replacement walks through the process.
Penalties in practice
Section 37-23-8 lets the Department of Labor and Training issue cease-and-desist orders and administrative penalties from $250 to $950 per offense, and each day can be a separate offense. A cease-and-desist order on a public job can stop work, which usually costs more than the fine. Treat a card gap as a same-day fix.
Working in Rhode Island and Massachusetts in the same season
Many Rhode Island contractors also work in southeastern Massachusetts. The rules differ in a few ways.
| Compared | Rhode Island | Massachusetts |
|---|---|---|
| Threshold | $100,000 total project cost | Over $10,000 |
| Owner | State and municipal | Public works and buildings |
| Card on person | Required | Not stated in the statute |
| Course | OSHA 10 Construction | OSHA 10 Construction |
A crew that meets the Rhode Island rule, cards in wallets, will normally meet the Massachusetts rule too. See the Massachusetts OSHA 10 guide and the New Hampshire OSHA 10 guide for the other New England rules, or compare all of them in the state requirements checker.
A checklist for Rhode Island public jobs
- Confirm the owner is the state or a municipality and the total cost is $100,000 or more.
- Require OSHA 10 Construction from every sub in the subcontract, with copies sent to you before mobilization.
- Record each worker's card number, issue date, trainer and a photo of both sides.
- Tell every worker, in a language they understand, that the card must be in their wallet on this job.
- Do a weekly card check at the morning huddle.
- Keep a spare-day plan: if someone loses a card, have them contact the trainer and keep the photo ready.
- Do not let anyone lend or borrow a card, and explain why on day one.
Spanish-speaking crews
The same rules apply, and the OSHA 10 course is available in Spanish from several authorized online providers and from in-person trainers. Explain the carry rule clearly. A simple line works: "En esta obra, la tarjeta OSHA tiene que estar en su cartera todo el día. No se presta." Our Spanish guide, OSHA 10 en español, explains the course for workers.
Record-keeping that helps later
The statute does not set a renewal period, and federal OSHA 10 cards do not expire. Do not put an expiry date in your records. Do record the issue date, because it tells you whether a replacement is still possible and whether a general contractor's "card from the last five years" rule is met. A crew card tracker or a simple training matrix keeps the dates in one place.
Sample subcontract language for Rhode Island
Adapt this with your attorney before using it:
Subcontractor shall ensure that each employee assigned to the project has completed an OSHA 10-hour or 30-hour Construction Outreach course and carries the course completion card on their person at all times while performing work on the project, as required by R.I. Gen. Laws chapter 37-23. Subcontractor shall provide copies of all cards before mobilization and shall immediately notify Contractor of any lost card.
Asking for copies before mobilization gives you two things: a record of who trained where, and an early warning when a sub has untrained workers.
What an inspector usually checks
Rhode Island inspections on public jobs tend to be quick and practical. Expect questions like these:
- "Show me your OSHA card." The inspector asks the worker, not the office.
- "Is this your card?" The name on the card should match the worker's ID.
- "Who is your employer?" This links the worker to a contractor so penalties can be assessed against the right company.
- "Do you have a list of your crew?" A foreman with a current roster and card details makes the visit shorter.
Workers who understand why the card must be with them answer these questions without stress. Spend five minutes on day one explaining the rule.
OSHA 30 for supervisors
The statute's core requirement is the 10-hour program, but section 37-23-5 references both the 10-hour and 30-hour construction courses. Many Rhode Island general contractors and public owners also require OSHA 30 for foremen and superintendents in their contract documents. If you are bidding public work regularly, train at least one supervisor per crew to the 30-hour level. It covers supervisor duties such as hazard assessment and incident investigation in more depth. Our OSHA 10 vs OSHA 30 comparison explains the difference.
Questions workers often ask
"My card is from 2012. Is it still good?" Yes. Federal OSHA 10 cards do not expire, and the Rhode Island statute does not set a renewal period. A general contractor may still ask for newer training under its own policy.
"Can I keep a photo on my phone instead?" The law says the card must be on your person. Carry the card. A photo is useful as a backup for a replacement request.
"I took the course online. Is that OK?" Yes, if the provider is on OSHA's list of authorized online providers and you received the DOL card.