Why day one
Travelers' 2025 Injury Impact Report, built from five years of its own claims, found employees in their first year on the job accounted for about 36% of injuries and 34% of claim costs. OSHA's heat data says nearly three out of four heat deaths happen in the first week. The pattern is the same for falls, struck-by and machine injuries: the new person doesn't know where the hazard is, doesn't know who to ask, and doesn't want to be the one who slows the crew down. Orientation is the hour where you fix all three, and it is the training inspectors ask for first when a new worker gets hurt.
What the rules require before work starts
There is no standard titled "orientation." There are a dozen standards that say training happens before the worker is exposed, at the time of initial assignment, or before first use. Put together, they are the orientation:
| Training | When | Rule |
|---|---|---|
| Recognizing and avoiding unsafe conditions and the rules that apply to the work | Every construction worker, before they are exposed. This is the general one. | 1926.21(b)(2) |
| Hazard communication: the chemicals, the labels, the safety data sheets, where the written program is | At the time of initial assignment, and whenever a new chemical hazard is introduced | 1910.1200(h)(1) |
| PPE: what, when, how to wear, adjust and care for it, and its limits | Before the worker uses it, with a demonstration that they understood | 1910.132(f) |
| Fall protection: the hazards, the systems, and how to use them | Before exposure to a fall hazard, with a written certification | 1926.503 |
| Forklifts and telehandlers: training and a hands-on evaluation | Before operating without supervision; evaluated again at least every 3 years | 1910.178(l), 1926.602(d) |
| Lockout/tagout: authorized, affected and other employees | Before the worker services equipment, or works around locked equipment | 1910.147(c)(7) |
| Respirators: fit test, seal check, limitations, maintenance | Before first use and annually; medical evaluation before the fit test | 1910.134(k), (e), (f) |
| Confined spaces: the hazards, the permit, the attendant's and entrant's duties | Before first assignment to permit space duties | 1910.146(g), 1926.1207 |
| Emergency action plan: exits, alarms, assembly, who to call | When the worker is initially assigned, and when the plan or their duties change | 1910.38(f), 1926.35(e) |
| Fire extinguishers: hazards of fighting fires and how to use them | Upon initial employment and annually, if the worker is expected to use one | 1910.157(g) |
| Bloodborne pathogens | At the time of initial assignment to tasks with exposure, including designated first aiders, and annually | 1910.1030(g)(2) |
| Noise: effects, protection, audiograms | Before exposure at or above 85 dBA and annually | 1910.95(k) |
| Silica: the tasks, the controls, the plan, the competent person | Before exposure | 1926.1153(i), 1910.1053(j) |
| Scaffolds, ladders and stairways, aerial lifts, powder-actuated tools, flagging | Before the worker uses or works on each, by a qualified or competent person as each rule specifies | 1926.454, 1926.1060, 1926.453, 1926.302(e), 1926.201 |
| Heat illness | Before the first day working in heat, under the state rules and the proposed federal rule | 8 CCR §3395(h), OAR 437-002-0156, others |
Two more things that aren't training but belong on day one. The OSHA poster (OSHA 3165, or the state's version) has to be posted where workers see it. And every worker has to be told how to report an injury, and that they can report without being punished for it (29 CFR 1904.35(b)(1)); a reporting procedure the new hire has never heard of is the one OSHA calls unreasonable.
Several states and cities require training cards on top of this: Nevada's OSHA 10 for construction workers and OSHA 30 for supervisors within 15 days of hire, New York's OSHA 10 on public works over $250,000, New York City's Site Safety Training card, and OSHA 10 requirements on public works in Connecticut, Massachusetts, Missouri, New Hampshire, Rhode Island and West Virginia, plus local ordinances such as Philadelphia's and Miami-Dade County's. No federal rule requires an OSHA 10 card; most general contractors do.
The day-one checklist
This is the one we use for a contractor or shop with no safety department. Ninety minutes, led by the supervisor the person will work for, with a walk, not a video. Check each item, both sign at the bottom.
Before the walk
- Emergency contact, and who the worker's supervisor and competent person are, by name.
- How to report an injury, a near miss or a hazard, to whom, and that nobody gets in trouble for reporting. Where the OSHA poster is.
- Stop-work authority: anyone can stop the job, and here is what happens when they do.
- The three rules that get you sent home today: for most crews, no fall protection at height, inside an unprotected trench, operating equipment you're not signed off on.
- Drug and alcohol policy, phone policy, driving policy if they drive for you.
The walk
- Exits, the assembly point, the first aid kit, the AED, the eyewash, the fire extinguishers, the SDS binder or the screen it's on, the restrooms and water.
- The address to give 911 from this site, and where the ambulance comes in.
- Where the hazards are on this job: the edge, the trench, the traffic, the live panel, the press. Point at them.
- Where things are stored, where equipment moves, where not to stand.
Equipment and PPE
- PPE issued and fitted: hard hat, eye protection, boots checked, high-visibility, gloves for the task, hearing protection if needed. How to inspect it, how to get it replaced.
- What they may not operate or do until trained and signed off: forklift, lift, saw, powder-actuated tool, crane signaling, anything with a lockout procedure. Write the list on the sheet.
- Respirator: medical evaluation and fit test scheduled before any task that needs one.
The hazards of this job
- Read the JHA or the pre-task plan for the first week's work with them, in their language.
- Hazard communication: the chemicals they'll touch, the labels, where the SDS is.
- Fall protection, trenching, lockout, confined spaces, silica, heat: whichever apply, the training and its record, before they're exposed.
- Housekeeping, lifting, hand and power tool basics.
Close
- Ask them to show you: put on the harness, find the SDS, point to the assembly point, name the competent person. Demonstration is how you verify understanding, and it is what 1910.132(f) asks for.
- Assign a buddy for the first week.
- Both sign and date, with the language the orientation was given in.
The first week and the 30-day check
Orientation is the start. The first week, the new worker shadows an experienced one, is not left alone on anything that can hurt them, and is watched for heat if it is hot. The supervisor checks in each day with one question: what did you see today that you weren't sure about? At 30 days, a second sit-down: what training is still missing, which equipment are they ready to be evaluated on, what have they noticed that the rest of the crew stopped seeing. Write both down on the same sheet as the orientation. A GC's prequal will ask whether you have a new-hire program; this is the evidence.
Temps, subs and transfers
- Temporary workers get the same orientation as your own hires. OSHA holds the host employer and the staffing agency jointly responsible; the agency covers general safety training and the host covers the site-specific hazards, equipment and emergency procedures, because the agency has never seen your site. Injuries to temps you supervise day to day go on your OSHA 300 log (1904.31).
- Subcontractors' workers are trained by their employer, but on a multi-employer site the controlling contractor is expected to orient them to the site's hazards, rules and emergency plan. Keep a sign-in.
- Transfers from the office, another division or the night shift are new to this job's hazards, whatever their seniority. So is the ten-year hand who comes back from six months on light duty. Orient them.
Workers who don't work in English
OSHA's position since 2010 is that training has to be in a language and vocabulary the worker understands. A bilingual coworker summarizing the orientation in the parking lot is not that. The orientation is given in Spanish by someone who speaks it, with the forms, the JHA and the signs in Spanish, and the record says which language was used. Where you can't do that in-house, a trainer who can, or a bilingual recorded module followed by a live walk with someone who can answer questions in Spanish. Then the demonstration test, which works in any language: show me.
What the record has to contain
Several standards specify the training record. Build one form that covers all of them: the worker's name, the date, the topics covered, the trainer's name and signature, how understanding was verified, and the language used. The specific requirements it has to satisfy:
- Fall protection certification: name, dates of training, signature of the trainer or employer (1926.503(b)).
- Forklift certification: operator's name, date of training, date of evaluation, identity of the trainer and evaluator (1910.178(l)(6)).
- Lockout training certification: employee name and dates (1910.147(c)(7)(iv)).
- Confined space training: employee name, trainer signatures or initials, dates (1910.146(g)(4), 1926.1207(d)).
- Respirator fit test record: name, type of test, respirator make, model and size, date, result (1910.134(m)(2)).
- Bloodborne pathogens: dates, contents, trainer's name and qualifications, attendees' names and job titles, kept 3 years (1910.1030(h)(2)).
- Hazard communication: no certification form is required, but the written program has to describe how training is done, and a signed record is how you prove it.
Keep orientation and training records for the length of employment plus three years at least, and longer where a standard says so. Keep them where you can find them by the worker's name in an hour, because that is how long you'll have when an inspector asks.
Mistakes that make orientation a formality
- A 20-minute video and a signature page, done by the office, with no walk.
- "He's experienced, he doesn't need it." He has never seen your site, your equipment or your emergency plan.
- The new hire put on the forklift to move one pallet before the evaluation.
- Orientation in English, signature in English, worker in Spanish.
- No buddy and no check-in. Day two, alone on the saw.
- Temps skipped because "the agency trains them."
- Records in a drawer in the trailer that went to the next job.
- The orientation never mentions how to report an injury, so the first one is reported to the workers' comp carrier three weeks late.
Orientation on the phone, in both languages, with the card that proves it
29Safety walks the supervisor and the new hire through the orientation on a phone, in English or Spanish, with your site's hazards, your emergency plan and your equipment list pulled in. Both sign, the record files under the worker's name with the language noted, and the forklift, fall protection and other training cards show what is still missing and when each one expires.
See exactly what you'd get
The JHA plus a toolbox talk record, an inspection and more, in one PDF: five documents for a jobsite crew, or three for a plant. No watermark.
Plans from $199 a month. No per-person fees. 14 days free.
Rather have us write it? Two written programs ($295)
Questions we get
Is new-hire safety orientation required by OSHA?
Not under that name. What is required is training before exposure under a long list of standards: instruction in the hazards of the work (29 CFR 1926.21(b)(2)), hazard communication at initial assignment (1910.1200(h)), PPE before use (1910.132(f)), fall protection before exposure (1926.503), forklift evaluation before operating (1910.178(l)), lockout, respirators, confined spaces and the rest. Orientation is the practical way to do them all on day one and prove it.
How long should orientation take?
Sixty to ninety minutes for a contractor or shop, longer where the job has permit spaces, respirators or specialized equipment. It includes a walk of the site or shop and a demonstration by the worker. Equipment-specific training like forklift operation is scheduled separately and takes as long as it takes.
Does an experienced worker need orientation?
Yes. Experience with the trade is not knowledge of your site, your equipment, your emergency plan, your chemicals or your reporting procedure. Experienced hires skip orientation most often and get hurt in the first month at a rate that shows it.
Do my new hires need an OSHA 10 card?
No federal rule requires one. Nevada requires OSHA 10 for construction workers and OSHA 30 for supervisors within 15 days of hire, New York requires OSHA 10 on public works over $250,000, and several other states require it on public or all construction. Most general contractors require it in their contracts. An OSHA 10 card is general awareness training; it does not replace the site-specific orientation or the equipment-specific training in this guide.
What records do I have to keep?
A record with the worker's name, the date, the topics, the trainer, how you verified understanding and the language used covers almost everything. Specific standards add fields: fall protection (name, dates, trainer signature), forklift (training date, evaluation date, trainer and evaluator), lockout (name and dates), PPE (name, dates, subject), respirator fit tests, and bloodborne pathogens (kept 3 years with the trainer's qualifications).
Can orientation be done by video or in Spanish?
A video can carry part of it, but the rule for PPE and the practical reality for everything else is that the worker has to demonstrate understanding, which means a live person, a walk of the site, and questions answered. It should be given in Spanish for a worker who works in Spanish; OSHA's position since 2010 is that training must be in a language and vocabulary the worker understands, and the record should say which language was used.
Not sure how this applies to your work? in the chat, or email safetyteam@29safety.com.