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You finished your OSHA 10, got your DOL card in the mail, and figured you were set. Then a foreman on a NYC job site tells you your card is “expired” — even though there’s no expiration date printed on it.
What’s going on?
The short answer: your federal OSHA 10 card does not expire. But that doesn’t mean every job site will accept it. New York City, New York State, and your employer each have their own rules — and confusing them can cost you a day of work or your employer thousands in fines.
After 34 years of training construction professionals across New York, this is one of the most common questions our instructors hear. Here’s how the system actually works — and what it means for your card.
Does Your OSHA 10 Card Expire?
No. Your OSHA 10 card does not expire at the federal level. The Occupational Safety and Health Administration’s Outreach Training Program has no renewal requirement, and the DOL card you received after completing your 10-hour course has no expiration date printed on it. Once you earn it, OSHA considers it valid indefinitely.
That’s the official answer from OSHA.gov, and it applies to both the 10-hour and 30-hour outreach courses for construction and general industry.
But here’s where workers get tripped up — and where the real confusion starts. Federal OSHA sets the floor, not the ceiling. States, cities, and individual employers can (and do) set their own requirements on top of that. A card that’s valid in the eyes of OSHA may not be accepted on a specific job site, depending on where you work and who you work for.
For workers in New York, this distinction matters more than almost anywhere else in the country.
Why NYC Job Sites Reject “Valid” OSHA Cards
If you work construction in New York City, your federally valid OSHA card may not get you on-site. The reason is Local Law 196.
Passed in 2017, Local Law 196 created the Site Safety Training (SST) card system administered by the NYC Department of Buildings. Any construction or demolition project that requires a Site Safety Manager, Site Safety Coordinator, or Construction Superintendent must have SST-carded workers on-site. That covers most major projects in the five boroughs.
Here’s the key: to obtain or renew an SST card, your OSHA 10 or OSHA 30 training must have been completed within the last 5 years. If your OSHA training is older than that, the NYC DOB considers it “stale” — and you’ll need to either retake it or complete an approved OSHA refresher course before your SST card can be issued or renewed.
The SST requirements break down like this:
In our experience training tens of thousands of workers across New York, this is the single biggest source of OSHA 10 “expiration” confusion. Workers hear “5 years” and assume their OSHA card expired. It didn’t. What expired (or became insufficient) is their eligibility for an SST card — which is what the job site actually requires.
The distinction matters, but the practical outcome is the same: if your OSHA 10 is more than 5 years old and you need to work on a Local Law 196 job site in NYC, you need to retake the training.
NY State vs. NYC: Two Different OSHA 10 Rules
This is where New York workers get caught off guard. The state and the city have separate rules, and they don’t match.
| Factor | Federal OSHA | New York State | New York City |
| Does OSHA 10 expire? | No | No | Effectively yes (5-year recency required for SST) |
| Renewal required? | No | No | Yes — every 5 years for SST card |
| When is OSHA 10 required? | Never (voluntary program) | Public works contracts over $250,000 (Article 8 §220-h) | Most construction/demolition sites via Local Law 196 SST |
| Governing authority | U.S. Dept. of Labor / OSHA | NY Dept. of Labor | NYC Dept. of Buildings |
| Proof required? | DOL card | DOL card or certificate of completion on first payroll | SST card (DOL card alone is not sufficient) |
| Penalty for non-compliance | None (voluntary) | Contractor may be disqualified from project | Up to $5,000 per untrained worker per responsible party |
| One-time or recurring? | One-time | One-time | Recurring (5-year cycle) |
The bottom line: If you work on state-funded public works projects upstate or in the Hudson Valley, your OSHA 10 card is good for life — the NY Department of Labor has confirmed this directly. If you work on covered construction or demolition sites within the five boroughs, you’re operating under a completely different system that effectively treats your OSHA 10 as valid for 5 years.
Our instructors walk through this distinction in every OSHA 10 class we teach, because getting it wrong can mean showing up to a job site and being turned away.
When Can Your Employer Require You to Retake It?
Even outside of NYC, your employer can require you to retake OSHA 10 training at any time. This isn’t an OSHA rule — it’s a company policy decision. And it’s increasingly common.
Many general contractors and construction firms now require OSHA 10 training completed within the last 3 to 5 years as a condition of employment or site access. They do this for insurance reasons, safety liability, or simply because they want workers trained on current regulations.
If a job posting says “Must have current OSHA 10” or “OSHA 10 within last 5 years,” that’s the employer talking — not OSHA. Your card is still federally valid. But if you want the job, you need to meet their standard.
Beyond employer policies, several other jurisdictions have formal OSHA 10 renewal requirements:
| Jurisdiction | Requirement | Renewal Cycle |
| Nevada | All construction workers must hold OSHA 10 | Every 5 years (state law) |
| Connecticut | Workers on state-funded public works projects | Every 5 years |
| Philadelphia | Licensed contractors must have supervisor with OSHA 30 | Within last 5 years |
| Miami-Dade County | Workers on public and private contracts over $1M | OSHA 10 required; check local recency rules |
| New York City | All workers on Local Law 196 covered sites | Every 5 years (via SST card system) |
The trend is moving toward recency requirements, not away from them. Workplace safety regulations have changed significantly since OSHA updated its Outreach Training Program requirements (most recently effective October 1, 2024, which eliminated the 90-day grace period for expired trainer authorizations). Workers trained in 2018 missed seven years of regulatory updates, new hazard communication standards, and revised fall protection guidance. That’s the practical argument for refresher training even when it’s not legally required.
The 5-Year Replacement Card Rule Everyone Confuses
Here’s the other reason “5 years” and “OSHA 10” are linked in people’s minds — and it has nothing to do with expiration.
If you lose or damage your DOL card, you can request a replacement from your original training provider. But only if your training was completed within the last 5 years. After that window closes, no replacement can be issued. Your only option is to retake the full OSHA 10 course to get a new card.
This is a replacement policy, not an expiration date. Your original training is still valid. You just can’t get a new copy of the card proving it.
The practical problem is obvious. If you can’t produce proof of your training on a job site because your card is lost and you’re past the 5-year replacement window, you’re effectively in the same position as someone who never took the course. You’ll need to retake the training — not because your certification expired, but because you can’t prove you completed it.
That’s why our instructors recommend: keep a photo of your DOL card on your phone, and save your certificate of completion email or PDF somewhere you won’t lose it.
How to Decide If You Need to Retake OSHA 10
Not sure where you stand? Here’s how to think through it:
Retake your OSHA 10 if any of these apply:
You do NOT need to retake if:
When it is time to retake, the course is 10 hours — our OSHA 10 for Construction course covers the same curriculum with updated 2026 regulatory content and can be completed in a hybrid format: online coursework plus hands-on components at one of our New York locations in Buffalo, Manhattan, Rochester, or Syracuse.
EEA has been an OSHA-authorized training provider since 1992, and our instructors bring 10 to 40+ years of field experience to every course. We don’t just teach you what the regulations say — we teach you how they apply on an actual job site.
Frequently Asked Questions
No. The DOL card issued after completing OSHA 10-hour outreach training does not include an expiration date. It is considered valid indefinitely at the federal level. However, NYC’s Department of Buildings requires OSHA training to be within 5 years for SST card eligibility, which creates an effective expiration for workers on covered NYC job sites.
Yes, and this is where most confusion happens. Your OSHA 10 DOL card never expires federally. Your NYC SST card expires after 5 years and requires refresher training to renew. To renew your SST card, your underlying OSHA training must be within 5 years — otherwise you’ll need to retake the OSHA 10 or 30 course first.
Yes, as long as the online course is provided by an OSHA-authorized training provider and is actively proctored. NYC DOB requires active proctoring for online OSHA training to count toward SST card eligibility. You will receive the same official DOL card regardless of whether you train online or in-person.
Costs vary by provider. OSHA 10-hour construction training through an authorized provider typically ranges from $75 to $300 depending on format and location. EEA offers OSHA 10 for Construction with flexible scheduling across multiple New York locations — contact us for current pricing and upcoming course dates.
The same rules apply. Federal OSHA 30-hour outreach cards do not expire. However, NYC Local Law 196 and various employer policies may require OSHA 30 training to be within 5 years. Maritime outreach cards previously had a 5-year expiration, but OSHA removed that requirement effective April 1, 2019.
The question isn’t really whether your OSHA 10 card expires — federally, it doesn’t. The real question is whether the job site you’re walking onto will accept it. In New York, that depends on whether you’re working under federal rules, state rules, or city rules — and they’re all different.
If you’re due for a retake or need your OSHA 10 for the first time, EEA’s OSHA 10 for Construction course gets you trained and carded with instructors who’ve spent decades on real job sites. View our upcoming OSHA 10 course schedule or call us to find the next available session at a location near you.
About the Author
Andrew J. McLellan, President & Founder — Environmental Education Associates
Andrew McLellan founded EEA in 1992 and has served as training director for all accredited programs for over three decades. With roots in SUNY Buffalo’s Toxicology Research Center and direct relationships with EPA, NYSDOH, and OSHA accreditation programs, Andrew has overseen the training of tens of thousands of environmental and safety professionals across New York State and nationally.
May 12, 2026
May 12, 2026
May 12, 2026