Safety on Staging for Live Events - Frequently Asked Questions

CA Labor Code sections 9250-9254  (2022)

In 2022, Governor Newsom signed AB 1775 into law. This bill added Part 14 (sections 9250 through 9254) to the portion of the California Labor Code that governs Safety in Employment. These sections became effective on January 1, 2023.

Entertainment events vendors contracted to set up, operate or tear down live events at public events venues must comply with the new requirements.

As part of the contract for producing a live event, these employers must certify in writing that they have verified the training and certification requirements for all employees and subcontractors’ employees who will work on the event.

This webpage explains the requirements and provides links to helpful resources.

  1. What businesses are considered "entertainment events vendors"?
    Entertainment events vendors are private employers that contract to set up, operate or tear down a live event at a public events venue. This includes any subcontracted employer involved in setting up, operating or tearing down a live event. Direct employees of the public events venues are not required to fulfill the training and certification requirements of Labor Code section 9251.
  2. What is a public events venue?
    For the purposes of this standard, a public events venue is any of the following:
    • a state-operated fairground
    • a county fairground
    • a state park
    • a California State University facility that hosts live events
    • a University of California facility that hosts live events
    • an auxiliary organization-run facility that hosts live events
  3. What is an "auxiliary organization"?
    An auxiliary organization is an entity associated with the California State University system or the University of California system. Auxiliary organizations are defined in CA Education Code section 89901.
  4. What activities are included in "operating" a live event?
    Operating a live event includes activities such as operating lighting, sound, pyrotechnics, machinery, electrical apparatus, scenery, audiovisual equipment, or rigging.
  5. What are the training requirements under Labor Code section 9251?
    Labor Code section 9251 requires entertainment events vendors to certify for their employees and any subcontractors' employees both of the following:
    • (1) An employee involved in setting up, operating, or tearing down a live event at the venue has completed the Cal/OSHA-10, the OSHA-10/General Entertainment Safety training, or the OSHA-10 as applicable to their occupation.
      AND
    • (2) One of the following is true:
      • (A) Heads of departments and leads have completed the Cal/OSHA-30, the OSHA-30/General Entertainment safety training, or the OSHA-30, and are certified through the Entertainment Technician Certification Program relevant to the tasks they are supervising or performing, or another certification program, as specified by the division.
        OR
      • (B) The entertainment events vendor certifies that its employees and any subcontractors' employees meet the conditions for a skilled and trained workforce.
  6. What is the Cal/OSHA 10?
    "Cal/OSHA-10" means a 10-hour course offered by a training provider that is authorized by an OSHA Training Institute Education Center to provide the course.

    Cal/OSHA does not directly provide the 10-hour course. To find authorized OTI educational centers, please visit federal OSHA's Current List of Authorized OTI Education Centers webpage.

    Note: Many training providers listed on these webpages offer both Cal/OSHA general industry and federal OSHA general industry courses, which are different. Be sure to attend the Cal/OSHA course if required by regulations that apply to your workplace.

  7. What is the OSHA-10 and OSHA-10/General Entertainment Safety?
    "OSHA-10" means the United States Department of Labor's Occupational Safety and Health Administration's 10-hour course on workplace health and safety.

    "OSHA-10/General Entertainment Safety" means the United States Department of Labor's Occupational Safety and Health Administration's 10-hour course on workplace health and safety specific to the entertainment and exhibition industries.

    OSHA-authorized trainers issue course completion cards to students that successfully complete an OSHA Outreach Training Program class. The Outreach Training Program offers 10-hour or 30-hour classes for Construction and General industry, among others. To obtain an OSHA card, one must attend and successfully complete the entire class, including all required topics and the minimum number of hours. Please note that an OSHA card is not considered a certification or license.

    Cal/OSHA does not directly provide the 10-hour course. The International Alliance of Theatrical Stage Employees (IATSE) developed a 10-hour training program that focuses on the Entertainment Industry. To find authorized OTI educational centers, please visit federal OSHA's Current List of Authorized OTI Education Centers webpage. 

  8. Who is considered the head of a department or a lead?
    "Heads of departments" and "leads" mean any worker that leads, supervises, or directs one or more workers in that same occupation and is employed in an occupation that may be certified by the Entertainment Services and Technology Association (ESTA) Entertainment Technician Certification Program.
  9. What is the Entertainment Services and Technology Association (ESTA)?
    ESTA is the non-profit trade association for the entertainment technology industry. ESTA develops standards for entertainment crafts through a technical standards program accredited by the American National Standards Institute (ANSI).

    To learn more about ESTA, please visit https://www.esta.org/.

    To learn more about the technical standards program, please visit https://tsp.esta.org/tsp/about/about.html.

  10. What is the Cal/OSHA-30?
    "Cal/OSHA-30" means a 30-hour course offered by a training provider that is authorized by an OSHA Training Institute Education Center to provide the course.

    Cal/OSHA does not directly provide the 30-hour course. To find authorized OTI educational centers, please visit federal OSHA's Current List of Authorized OTI Education Centers webpage.

  11. What is the OSHA-30 and OSHA-30/General Entertainment Safety?
    "OSHA-30" means the United States Department of Labor's Occupational Safety and Health Administration's (OSHA) 30-hour course on workplace health and safety.

    "OSHA-30/General Entertainment Safety" means the United States Department of Labor's Occupational Safety and Health Administration's (OSHA) 30-hour course on workplace health and safety specific to the entertainment and exhibition industries.

    OSHA-authorized trainers issue course completion cards to students that successfully complete an OSHA Outreach Training Program class. The Outreach Training Program offers 10-hour or 30-hour classes for Construction and General industry, among others. To obtain an OSHA card, one must attend and successfully complete the entire class, including all required topics and the minimum number of hours. Please note that an OSHA card is not considered a certification or license.

  12. What is a "skilled and trained workforce"?
    "Skilled and Trained Workforce" is defined by CA Public Contract Code Section 2601(d), which states:

    "Skilled and trained workforce" means a workforce that meets all of the following conditions:

    • (1) All the workers performing work in an apprenticeable occupation in the building and construction trades are either skilled journeypersons or apprentices registered in an apprenticeship program approved by the chief.
    • (2)(A) For work performed on or after January 1, 2017, at least 30 percent of the skilled journeypersons employed to perform work on the contract or project by every contractor and each of its subcontractors at every tier are graduates of an apprenticeship program for the applicable occupation. This requirement shall not apply to work performed in the occupation of teamster.
      • (B) For work performed on or after January 1, 2018, at least 40 percent of the skilled journeypersons employed to perform work on the contract or project by every contractor and each of its subcontractors at every tier are graduates of an apprenticeship program for the applicable occupation, except that the requirements of subparagraph (A) shall continue to apply to work performed in the following occupations: acoustical installer, bricklayer, carpenter, cement mason, drywall installer or lather, marble mason, finisher, or setter, modular furniture or systems installer, operating engineer, pile driver, plasterer, roofer or waterproofer, stone mason, surveyor, teamster, terrazzo worker or finisher, and tile layer, setter, or finisher.
      • (C) For work performed on or after January 1, 2019, at least 50 percent of the skilled journeypersons employed to perform work on the contract or project by every contractor and each of its subcontractors at every tier are graduates of an apprenticeship program for the applicable occupation, except that the requirements of subparagraph (A) shall continue to apply to work performed in the following occupations: acoustical installer, bricklayer, carpenter, cement mason, drywall installer or lather, marble mason, finisher, or setter, modular furniture or systems installer, operating engineer, pile driver, plasterer, roofer or waterproofer, stone mason, surveyor, teamster, terrazzo worker or finisher, and tile layer, setter, or finisher.
      • (D) For work performed on or after January 1, 2020, at least 60 percent of the skilled journeypersons employed to perform work on the contract or project by every contractor and each of its subcontractors at every tier are graduates of an apprenticeship program for the applicable occupation, except that the requirements of subparagraph (A) shall continue to apply to work performed in the following occupations: acoustical installer, bricklayer, carpenter, cement mason, drywall installer or lather, marble mason, finisher, or setter, modular furniture or systems installer, operating engineer, pile driver, plasterer, roofer or waterproofer, stone mason, surveyor, teamster, terrazzo worker or finisher, and tile layer, setter, or finisher.
  13. Is there a document that officially certifies an employer as having a skilled and trained workforce?
    No. There is no formal document that officially certifies an employer as having a skilled and trained workforce. The employer is responsible for determining whether its employees meet the criteria stated in Public Contracts Code section 2601(d).
  14. What is the certification requirement under Labor Code 9251?
    An entertainment events vendor is required to certify in writing, as part of its contract with the contracting entity, that they have verified that their employees and subcontractors' employees have completed the applicable training and/or meet the criteria for a skilled and trained workforce.

    Contracting entities and their entertainment events vendors should address these issues in their contracts for events that will take place at "a state-operated fairground, county fairground, state park, California State University, University of California, or auxiliary organization-run facility that hosts live events."

  15. How will the requirements be enforced?
    Cal/OSHA will enforce the certification requirement of Labor Code section 9251. When investigating an entertainment events vendor or contracting entity, Cal/OSHA will determine whether the written certification was included in the contract between the parties and may investigate how the entertainment events vendor verified that its employees met the requirements of Labor Code section 9251. At entertainment events, vendors who are unable to provide certification that their workforce has completed the required training could be cited by Cal/OSHA directly under Labor Code section 9252. 

November 2023