Background: Co-curricular activities are engaging out-of-classroom learning activities that attract student’s participation. However, the risk and safety of the students become a concern since it is one of the activities that often cause injuries during the activities. Such activities require a needs analysis study to be conducted to ensure that the modules produced can meet the needs and specifications of co-curricular activities in schools. Objective: This study was conducted to identify the need for module content and module specifications based on the safety of students in school during co-curricular activities. Methodology: To construct a module that can meet the needs of students and teachers, a needs analysis was conducted on 40 teachers who specialized in uniformed units, sports and games and associations in the district of Kudat. Data collection was done through constructed questionnaires and simple and purposive random sampling techniques. Results: The needs analysis shows that the student safety management modules in out-of-classroom learning have significant needs to be developed. Conclusion: The needs analysis of the study found that it is important to construct safety management modules in out-of-classroom learning to overcome the problems faced by the co-curricular advisory teachers in schools. These findings will be used to design and develop the module in the next phase. These findings are expected to help produce teaching modules that can solve the problems of co-curricular advisors during co- curricular activities.