EHAP explained: what the card proves, and what the employer still owes

EHAP is the Tree Care Industry Association's Electrical Hazards Awareness Program: an online course requiring 84 percent on every chapter test, proof of a practice aerial rescue from at least 35 feet, and an in-person first aid and CPR card. The certificate runs one year. TCIA states it must be combined with documented on-the-job training to meet 1910.269.

A crew file holds one page about electricity: an EHAP certificate of completion dated March 14, 2026, with a wallet card behind it reading March 14, 2027. The climber scored above 84 percent on every chapter test. He sent in proof of a practice aerial rescue from 38 feet. His employer paid $126.50 for it, because the company is a TCIA member and members save 35 percent.

Every line of that is real, and none of it is the record 29 CFR 1910.269 asks the employer to produce. The publisher of the course says so in one sentence, on the page that sells it.

What EHAP is, and who issues it

The Electrical Hazards Awareness Program is a course. The Tree Care Industry Association publishes it from Manchester, New Hampshire, delivers it online through the Brightspace learning platform, and sells it in English and Spanish. TCIA prints its reason for the course at the top of the page:

Electricity is a serious and widespread hazard to arborists. Electricity causes about 15 percent of all fatalities in the tree care industry, making it the leading cause of worker fatalities.

That figure is TCIA's own, published on the page without a source behind it. What the program asks of a candidate is easier to hold to:

What TCIA requires	The condition
Chapter tests	A grade of 84 percent or better on each one, retaken as often as needed
Aerial rescue	Proof of a practice rescue from a height of at least 35 feet
First aid and CPR	A valid card, earned in person at an accredited facility
Certificate	Awarded through Brightspace, valid one year from date of completion
Wallet card	Carries the renewal date
Renewal	Annual
Price	$126.50 member, $206.99 non-member
Credit	7.5 ISA and 7.5 CTSP continuing education units

TCIA aims the course upward on the same page. It quotes ANSI Z133 sections 4.4.2 and 4.5.2 in full, and says the Electrical Level 3 and Level 4 Arborist "must know more about electrical hazards and the special techniques used to safely work near electrical conductors." Those are the 2026 edition's section numbers, which is current. Two paragraphs lower, the same page calls the standard ANSI Z133.1, a designation it stopped carrying in 2012. Which level reads which approach distance table is the page that sorts that out.

The sentence on TCIA's own page that decides what the card is worth

Under the heading "OSHA Safety Requirements," below two bullets describing what the federal standard asks of an employer, TCIA prints this:

EHAP must be used in combination with documented on-the-job skills training and verification to meet OSHA 1910.269 requirements.

The vendor is telling a buyer the certificate is an input to a compliance record rather than the record. Read the rest of the page against that sentence and the product sits where it belongs. It is classroom content, tested by chapter, with two physical demonstrations bolted on, sold annually.

Everything the standard wants beyond that happens on a job site, under the employer's supervision, and is written down by the employer. How the training paragraphs fit together and what closes them is the page that walks 1910.269(a)(2) from end to end.

The word "certify" came out of the rule on July 10, 2014

TCIA describes the first of the two OSHA duties this way:

Employers must certify that employees who work 10 feet or closer to energized conductors are trained in the special hazards involved in such work.

That obligation was real until 2014. It sat at 1910.269(a)(2)(vii), and OSHA removed it. The final rule at 79 FR 20316, published April 11, 2014 and effective July 10, 2014, set out what it was replacing:

Existing § 1910.269(a)(2)(vii) requires employers to certify that each employee has received required training. The certification has to be made when the employee demonstrates proficiency in the relevant work practices and maintained for the duration of the employee's employment.

TCIA fought the change on the record and lost. Scott Packard of Wright Tree Service testified on the association's behalf that the certification requirement "has clearly raised the level of safety in the line clearance tree trimming industry overall," at transcript page 751.

TCIA's written comment argued that the requirement "has imposed internally within line clearance contractors' and others' training procedures creation of failsafe mechanisms to unambiguously assure the employee has received the required safety training." The Utility Line Clearance Coalition asked for the same outcome. Peter Gerstenberger, also for TCIA, told the hearing that "it's the connotation of the word 'certify' that just accords the whole process more importance." OSHA went the other way:

OSHA has carefully considered the feedback it received on this issue and has decided to adopt the requirement as proposed, without a certification requirement.

Then it said where the duty landed:

OSHA stresses that it is the employer's, not the employee's, obligation to determine that the employee demonstrates proficiency before he or she is deemed to have completed the required training.

The reasoning OSHA gave was enforcement practice: the agency said it can establish compliance with the training requirements through interviews with management and workers, so it has no need of the paperwork. Twelve years on, the current text of 1910.269 carries one certification requirement, in paragraph (d)(2), and that one is about lockout and tagging. An EHAP certificate in a file today answers a question a compliance officer stopped being obliged to ask in 2014. The question they ask instead is who watched this climber work, and when.

Two annual dates on one worker

The wallet card says March 14, 2027, and that date belongs to TCIA. It is discharged by paying and retesting. The standard runs its own yearly clock at 1910.269(a)(2)(iv), owned by the employer and discharged by a supervisor standing in a yard, watching somebody set a rope under a 12 kV primary, and writing down what they saw and when.

A file holding a current EHAP card and eighteen months of silence in the field has answered one of the two. Which one an inspector opens first depends on what brought them out. The continuing obligations under (a)(2)(iv) and (a)(2)(v), including the retraining the once-a-year note forces are read in full on the tiers page, and none of them move when a renewal is paid.

The rescue at 35 feet, and the card that cannot be earned online

The two parts of EHAP that happen off the screen are the two a screen cannot carry. A candidate submits proof of a practice aerial rescue from a height of at least 35 feet, and a valid first aid and CPR card. TCIA sets a condition on the second:

To meet OSHA safety standards and ensure hands-on skill development, all CPR and First Aid (CPR/FA) training must be completed in person at an accredited facility. Online-only courses do not meet OSHA requirements, which mandate physical practice of life-saving techniques like CPR and bandaging.

The approved sources are the American Heart Association, the American Red Cross, and the Health and Safety Institute. TCIA cites OSHA's letter of interpretation dated August 2, 2012, and the letter supports the policy squarely. Thomas Galassi signed it as Director of the Directorate of Enforcement Programs, answering a question from the Health and Safety Institute that named 1910.269 among six standards:

Online training alone would not meet the requirements of these training standards. The word "train" is defined as "[t]o make proficient with special instruction and practice," Webster's II New Collegiate Dictionary, 1995, p. 1,169. These standards require training in physical skills, such as bandaging and CPR. The only way these physical skills can be learned is by actually practicing them.

That is the whole argument for why an online course ends with a video of somebody lowering a dummy. It also sets the shape of the two records that come out of it. What an aerial rescue drill has to demonstrate and who on a crew has to hold a current first aid card are separate requirements, each with its own date, and each stands on its own paperwork.

Six chapters, or seven

TCIA runs two live pages about EHAP, and they print different chapter counts. The program page, carrying the later date stamp of June 15, 2026, says "Pass a test for each of the seven chapters with a grade of 84% or better." The revised-program announcement, stamped April 24, 2025, says "Pass a 25-question test for each of the six chapters with a grade of 84% or better," and repeats the six in its own FAQ.

Both pages agree on everything a file cares about: 84 percent, the 35-foot rescue, the in-person first aid card, a certificate good for one year, annual renewal. The chapter count is TCIA's to settle, and the address it publishes for that is education@tcia.org. A crew record that names the certificate, the completion date and the renewal date stands either way.

Where somebody else makes EHAP a condition

The program's regulatory footing is soft, and its contractual footing can be hard. TCIA states on its EHAP page that the course "is often required by the US Army Corps of Engineers in order to qualify for storm-related clean-ups," and that the Corps has recognized it "dating back to Hurricane Katrina."

That is TCIA's account of the Corps' practice rather than a published Corps rule. It points at something California contractors met in 2025, when Los Angeles County put Phase 2 fire debris removal for the Eaton and Palisades fires under the Corps to coordinate and manage. Missions like that run on federal contracts, and the contract sets the crew qualifications.

So the question to ask before buying seats is which document is driving. A utility's line clearance specification, a prime contractor's subcontract, or a Corps mission scope can each name EHAP and make it a condition of working at all. Title 8 and 1910.269 do something different, covered below.

Where the card stops

An EHAP certificate is a training record, and four separate questions turn on something else.

• The California credential turns on training plus documented on-the-job experience, which 8 CCR 2951(b) then makes a staffing condition for the operation. A certificate is evidence toward the training half. What separates a qualified line clearance tree trimmer from a qualified tree worker reads both definitions.

• The federal tier turns on the competency lists at 1910.269(a)(2)(ii) and (a)(2)(iii), and on the employer's determination that closes them.

• The approach distance tracks the credential rather than the course. A holder lacking the Title 8 line clearance credential, and lacking trainee status under it, owes the Table 1 of 8 CCR 2950 distance on a 12 kV span, which is 10 feet, subject to the three exceptions printed under that section.

• The standard EHAP is sold against may sit outside the job entirely. 1910.269 reaches line-clearance tree trimming when the work is done to clear space around the lines and on behalf of the organization operating them. Work that fails either condition falls under 29 CFR 1910.331 through 1910.335, where 1910.332 is the training rule and reads differently.

California names the qualification and never names the course

Cal/OSHA publishes a 24-page Tree Work Safety Guide covering chain saws, chippers, aerial lifts, heat, approach distances and training. Search it and the count for EHAP is zero. So is the count for ANSI, for certificate, for certification and for credential. TCIA appears once, in the resource list at the back, alongside the ISA and the Contractors State License Board. What the guide asks of training it states directly:

Provide employees with safety training that addresses the hazards associated with the tree work they perform. Safety training must be: Completed prior to a job assignment. Provided in the language(s) workers understand. Documented.

One bullet further down: "Require employees to demonstrate safe work practices as part of the training."

Three conditions and a demonstration. EHAP can carry all three conditions for the electrical portion of a crew's training, with the Spanish edition available for the second. The demonstration belongs to the employer here exactly as it does federally, and Cal/OSHA offers no certificate that substitutes for it.

What the file holds

For one worker with a current EHAP card, a crew record that survives an audit carries six things.

Document	What it names
EHAP certificate of completion	The worker, the completion date, the issuing platform
Wallet card or its copy	The renewal date, one year out
Aerial rescue proof	The date, the height, who witnessed it
First aid and CPR card	The issuer, the issue date, the expiration
Employer's proficiency determination	Who observed which work practices, on what date, and the conclusion
Annual field inspection record	The supervisor, the date, what was observed under a conductor

The last two are the ones that answer 1910.269, and both are generated in-house. How that file gets built and what each entry has to name is the practice behind them.

One practical note on the first row. TCIA's current EHAP pages publish no roster and no certificate lookup, and the EHAP roster URL the association's older site offered for verifying certificates returned a 404 when checked on September 20, 2026. A hiring manager holding a card from an applicant has one route to confirm it, which is email to TCIA. The copy that goes in the file is the record, and that is a reason to take it at hire rather than at the first inspection.

Further reading

• 29 CFR 1910.269(r): the three tiers, and what each one may approach: The training paragraphs a certificate feeds, and the employer determination that closes them.

• Qualified line clearance tree trimmer versus qualified tree worker: The two California credentials, neither of which is a course anybody can buy.

• ANSI Z133-2026: the four electrical levels and the tables they read: The consensus standard TCIA's EHAP page quotes at sections 4.4.2 and 4.5.2.

Frequently asked questions

What does EHAP stand for?

Electrical Hazards Awareness Program. It is a training course published by the Tree Care Industry Association of Manchester, New Hampshire, delivered online through the Brightspace learning platform in English and Spanish. TCIA sells it at $126.50 to members and $206.99 to non-members, and awards 7.5 ISA and 7.5 CTSP continuing education units for completion.

How long is an EHAP certificate valid?

One year. TCIA states that the certificate is valid for one year from date of completion, that the candidate also receives a wallet card carrying the renewal date, and that annual renewal of EHAP is required following initial program completion. That clock belongs to TCIA and is satisfied by retesting. The annual field obligation in 29 CFR 1910.269(a)(2)(iv) belongs to the employer and is satisfied by watching somebody work.

Does EHAP satisfy OSHA 1910.269?

TCIA says it satisfies part of it. The association's own EHAP page states that EHAP must be used in combination with documented on-the-job skills training and verification to meet OSHA 1910.269 requirements. The standard puts the closing step on the employer at 1910.269(a)(2)(viii), which treats training as complete only once the employee has demonstrated proficiency in the work practices involved.

What are the requirements to finish EHAP?

TCIA lists three. Pass a test for each chapter with a grade of 84 percent or better, retaking any test as often as needed. Submit proof of performing a practice aerial rescue from a height of at least 35 feet. Submit a valid first aid and CPR card, which under TCIA's policy must be earned in person at an accredited facility, from the American Heart Association, the American Red Cross, or the Health and Safety Institute.

Does an EHAP card make somebody a qualified line clearance tree trimmer?

No. In California that status is set in Title 8 and turns on training plus documented on-the-job experience, which 8 CCR 2951(b) then makes a staffing condition for line clearance tree trimming operations. Federally, the tiers are built from the competency lists in 1910.269(a)(2)(ii) and (a)(2)(iii) plus the employer's own determination. A vendor certificate appears nowhere in either scheme.