Credential Checks That Prevent Day-One Site Access Delays

A card that scans as active can still be wrong

On September 8, 2026, the Brooklyn District Attorney's office announced that two men and a training company, Redcode Inc., had been arraigned. The indictment charges them with making and selling New York City Site Safety Training (SST) cards and OSHA cards to workers who never took the training. Between April 22 and July 16, 2025, undercover investigators from the city's Department of Investigation posed as construction workers at Redcode's Brooklyn and Queens locations. The owner and an associate allegedly agreed to provide both cards for $500 each. According to the DA, Redcode then told the Department of Buildings and an OSHA training intermediary that the "students" had finished the course. The intermediary issued OSHA cards. DOB issued SST cards.

Both issuers were real.

Most day-one delays at a site entrance have nothing to do with fraud (a misspelled name, a pending portal status, a missing ID), but the Redcode case shows what a lookup cannot catch. A lookup result tells a reviewer that an issuer produced the credential. It does not say whether the class happened, whether the card covers the task, or whether its status on the start date will match its status today.

Status can change after the reviewer checks it

Redcode had been an approved DOB provider since April 2021 and had issued about 2,000 SST cards tied to more than 7,000 certificates, Bryan Gottlieb reported in ENR. DOB auditors had found a similar problem on their own. On July 26, 2025, they showed up at Redcode's 146-04 Hillside Avenue location in Queens for a scheduled two-hour Drug and Alcohol Awareness class, and the class did not take place. The next month DOB confirmed that Redcode had issued a completion certificate for it anyway. DOB denied the company's renewal as a provider in November 2025. "Additional investigation was needed before the Department could determine this was a [recurring] issue," says Andrew Rudansky, DOB's press secretary.

The DOB Redcode FAQ sets a 90-day grace period that runs through December 7, 2026, and until then the affected SST cards remain active (ENR reports they still scan as active at jobsites). On December 8 they are revoked, and OSHA cards that list Redcode's owner as instructor no longer count toward SST. "You must retake OSHA training through a current OSHA Training Provider," the FAQ says.

"Allowing untrained workers onto a job site puts them at risk and can put their coworkers in danger as well," says Ahmed Tigani, New York City's Buildings Commissioner, in the DA's announcement.

The 2024 Valor case went differently. In its April 2, 2024 notice, DOB disabled every Valor SST card in circulation, roughly 17,000 of them still active, effective immediately, and said workers who try to enter a site that requires the training with an invalidated card "must be turned away from the site." Same city. Both providers were accused of selling training that never happened, and nothing printed on either card told a foreman which rule applied. DOB's notice about each provider did.

OSHA does not verify its own Outreach cards

The OSHA Outreach FAQ says, "For privacy reasons, OSHA does not provide individual verification of student course completion cards or authorized trainer cards." On its card verification page, OSHA says it does not run any national database for checking cards. A plastic card has a QR code on the back with contact information for the OTI Education Center that processed it, and that center (or the trainer, who has to keep class records for five years) is where a real verification goes.

Construction Outreach cards have no expiration date, so any refresher rule comes from a state, a city, an owner, a union or the employer. More than 6.51 million workers went through the Outreach program between FY 2021 and FY 2025, and OSHA's program overview still says the voluntary training "does not fulfill the training requirements found in OSHA standards." The duty to train belongs to the employer under 29 CFR 1926.21(b)(2), whatever card the worker carries.

Local rules add deadlines. Under NRS 618.987, a Nevada construction worker other than a supervisor has 15 days after hire to present a current and valid OSHA-10 completion card. A supervisor needs an OSHA-30 card. Otherwise the employer "shall suspend or terminate" that person. New York City checks at the site entrance. On sites that require SST, DOB's SST FAQ says each card has to be validated in the Training Connect app before the worker is allowed in, and untrained workers draw civil penalties as high as $5,000 per worker, issued to the site owner, the permit holder and the employer.

Qualification is decided task by task

A trade license and a safety card are separate records, and neither one says whether a worker is qualified for the task on the first shift. Under 29 CFR 1910.399, a qualified person has received training in and "demonstrated skills and knowledge in the construction and operation of electric equipment and installations and the hazards involved." OSHA's note to that definition says a worker is likely to be qualified on some equipment and unqualified on other equipment at the same workplace.

Jim Dollard is a retired safety coordinator for IBEW Local 98 in Philadelphia and still serves on NFPA 70E. "The employer decides, and OSHA says the foreman is the employer on each job site," says Dollard, writing in Electrical Contractor. When inside electrical workers in 70E training are asked whether they are qualified, he says, "they almost always nod their head without knowing what task they will be performing." On training records, he says, "If it is not documented, it did not happen."

State licensing rules differ again. California's Electrician Certification Unit says out-of-state electricians have to be certified before they start working in the state and "there is no grace period," and a certification expires three years from its effective date; our post on licenses and reciprocity for traveling electricians covers the state-by-state checks.

Owners and regulators publish what delays a badge

The Bonneville Power Administration's contractor guide to access and permitting, revised February 13, 2026, lists what holds up onboarding. Workers bring two current forms of ID, and a state driver's license used as the primary ID has to be REAL ID compliant. Temporary paper IDs are refused. Names on the IDs must match each other and the onboarding paperwork, or the worker brings linking documents that explain the change. No hats in the badge photo, because a retake at a later date means, in BPA's words, "onboarding delays." A worker with no PIV enrollment center inside 100 miles has to email BPA's personnel security registrar to make other arrangements.

A BPA badge by itself does not grant unescorted energized access.

"Energized Access will not be granted until the badging process and background check have been completed," the guide says, and contract workers need an active badge and NERC CIP training before anyone can request a permit. Other owners and regulators publish their own deadlines.

Build the check around the start date

Start with the work package, meaning the jurisdiction, the owner's access rules and the task on the first shift, because those decide which credential controls. OSHA's TWI Bulletin No. 15 says the host employer "may specify the qualifications required for temporary workers in its contract with the staffing agency," and that the host should give the agency all task assignments, written job descriptions, the job hazard analysis and a list of equipment on the worksite. OSHA's Protecting Temporary Workers page says the agency and the host "share control over the worker." It treats training as a shared responsibility of both.

For each credential, record the issuer, the number, whether the legal name matches the ID the site requires, the status, any expiration, the lookup date and the reviewer. Redcode adds a field for the date to check again, since a Redcode SST card that is active in September will be revoked on December 8.

One Texas safety consultancy, in a September 2026 post, suggests comparing training rosters against payroll or timesheets for the same date and auditing about five records out of every hundred submitted.

Keep ID copies and background results out of the field roster.

An expired card, a name mismatch or a pending portal result is a decision to make before travel is booked. It ends in one of four outcomes (fixed, approved in writing by someone with authority, reassigned to work that does not need the credential, or held). Set the cutoff by the longest lead time on the job, which is roughly two months on a port job that needs TWIC and 48 hours for the forms at BASF Beaumont once the ISTC badge and background check are done. Give the receiving supervisor the same roster version the badging office has, and plan the first-day orientation around it.

Routine checks do find bad cards. In the 2023 New York case against sellers of fake OSHA and SST cards, one defendant's counterfeits allegedly sold for between $200 and $650 per card, and the investigation began in November 2021, according to the April 17, 2023 release, "after NYCHA reported to DOI that it had identified construction safety cards with discrepancies as part of a routine check."

Sources

1. Two Individuals and Company Indicted for Making and Selling Fake OSHA and Buildings Department Site Safety Cards, Kings County District Attorney's Office, September 8, 2026.
2. NYC Invalidates 2,000 Construction Safety Cards Tied to Alleged Training Fraud, Bryan Gottlieb, ENR, September 9, 2026.
3. Frequently Asked Questions (FAQs) regarding the Redcode Inc. indictment, NYC Department of Buildings, September 11, 2026.
4. DOB Issues Notice of Intent to Revoke Approved Course Provider Status of Valor Consulting, NYC Department of Buildings, April 2, 2024.
5. OSHA Outreach Training Program FAQs, Occupational Safety and Health Administration, accessed September 29, 2026.
6. How do I verify a student course completion card?, Occupational Safety and Health Administration, accessed September 29, 2026.
7. Outreach Training Program overview, Occupational Safety and Health Administration, accessed September 29, 2026.
8. 29 CFR 1926.21, Safety training and education, Occupational Safety and Health Administration, accessed September 29, 2026.
9. NRS Chapter 618, Occupational Safety and Health, Nevada Legislature, accessed September 29, 2026.
10. SST Frequently Asked Questions, NYC Department of Buildings, accessed September 29, 2026.
11. 29 CFR 1910.399, Definitions applicable to this subpart, Occupational Safety and Health Administration, accessed September 29, 2026.
12. Qualified? For What? Do you have the demonstrated skills and knowledge for the task?, Jim Dollard, Electrical Contractor, February 15, 2023.
13. Electrician Certification FAQs, California Department of Industrial Relations, Division of Labor Standards Enforcement, accessed September 29, 2026.
14. Contractor's Guide to Access and Permitting, Bonneville Power Administration, revised February 13, 2026.
15. TWIC, Transportation Security Administration, accessed September 29, 2026.
16. TWIC Frequently Asked Questions, Transportation Security Administration, accessed September 29, 2026.
17. Contractor Background Investigations Standard Operating Procedures, Western Area Power Administration, Attachment 1 revised August 1, 2019.
18. Site Entry Requirements, BASF Beaumont, BASF, accessed September 29, 2026.
19. TWI Bulletin No. 15, Construction Industry Employment (OSHA 4482), Occupational Safety and Health Administration, 2025.
20. Protecting Temporary Workers, Occupational Safety and Health Administration, accessed September 29, 2026.
21. When the Safety Card Is Real and the Training Never Happened, Chris Fredette, TriCore Safety, September 22, 2026.
22. Brooklyn Residents Indicted for Making and Selling Fake OSHA and Buildings Department Safety Cards, Kings County District Attorney's Office and NYC Department of Investigation, April 17, 2023.