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Local Law 196 has passed

What is Local Law 196?

Effective March 1, 2018, Local Law 196 (LL196) mandates safety training for all demolition and construction workers employed within the Five Boroughs on projects requiring a Construction Super, Site Safety Manager, Site Safety Coordinator, Concrete Safety Manager, or Competent Person. Ultimately, all workers will be required to complete a minimum of 40-hours of safety-related training and obtain a Site Safety Training (SST) Card to be eligible to work on construction sites in NYC.

Supervisors will be required to complete 62 hours of safety-related training to obtain a Supervisor SST Card.

Who Does LL196 Apply To?

Construction or demolition workers and supervisors (Site Safety Managers, Site Safety Coordinators, Concrete Safety Managers, Construction Superintendents and competent persons) at job sites that are required to designate a Construction Superintendent, Site Safety Coordinator or Site Safety Manager must be trained.

For a list of examples of workers who do and do not require training from the DOB here.

LL196 Dates to Remember

March 1, 2018, was the first compliance milestone date; all demolition and construction workers must complete one of the following courses:

On or by December 1, 2018, all workers must have either a Temporary SST Card, a Limited SST Card, or an SST Card.

On or by December 1, 2018, every Construction Superintendent, Site Safety Manager, Site Safety Coordinator, Concrete Safety Manager, Competent Person must have a Supervisor SST Card.

On or before May 1, 2019, all workers must have an SST Card.

Click here to read the full law.

Worker Requirements for Obtaining an SST Card

 

Temporary SST Card

 – For new demolition or construction workers who have completed the 10-Hour OSHA. Card expires after 6 months during which time training must be completed to receive a Limited SST Card or SST Card.

 

Limited SST Card

 – Required by 12/1/2018, Workers who are not yet able to meet the full LL196 requirements but have completed:

  • 10-Hour OSHA, plus 20 additional SST credits including:
    • 8-Hour Fall Prevention
    • 8-Hour Chapter 33 (Site Safety Manager Refresher)
    • 4-Hour Supported Scaffold User
  • 30-Hour OSHA Course,
  • 100-Hour training program (such as approved apprenticeship), or
  • Prior Experience *
    • 4-Hour Fall Prevention
    • 4-Hour Supported Scaffold User

The limited card expires and is not renewable.

*Please see note from DOB on Prior Experience.

What is required to obtain a SST Card?

 

SST Card

– Required by 5/1/2019*, Workers who have fully satisfied one of the following:

  • 10-Hour OSHA, plus 30 additional SST credits including:
    • 8-Hour Fall Prevention
    • 8-Hour Chapter 33 (Site Safety Manager Refresher)
    • 4-Hour Supported Scaffold User
    • 4-Hour General Electives
    • 4-Hour Specialized Electives
    • 2-Hour Drug and Alcohol Awareness, or
  • 30-Hour OSHA, plus 10 additional SST hours consisting of:
    • 8-Hour Fall Protection Course and
    • 2-Hour Drug & Alcohol Awareness Seminar, or
  • 100-Hour Training Program

*Workers who have the required 40 Hours of SST training prior to 12/1/18 can obtain an SST Card in lieu of a Limited SST Card.

This card will be valid for a 5-year period and will require 8-hours of SST training to renew.

Supervisor Requirements for Supervisor SST Card

Supervisor SST Card

– Required by 12/1/2018 for Construction Superintendents, Site Safety Manager, Site Safety Coordinators, Concrete Safety Managers, or Competent Person who have completed 62 SST credits including:

  • 30-Hour OSHA,
  • 8-Hour Fall Protection Course,
  • 8-Hour Site Safety Manager Refresher Training,
  • 4-Hour Supported Scaffold User Training, and
  • 2 hours of each of the following topics:
    • Site safety plans
    • Toolbox talks
    • Pre-task meetings
    • General electives,
    • Specialized electives,
    • Drug & Alcohol Awareness

This card will be valid for a 5-year period and will require 16-hours of SST training to renew.

What Are The Risks of Not Completing The SST Training?

Permit holders must certify workers have the required training. A DOB inspector may levy fines up to $15,000 per untrained worker:

  • $5,000 for the owner
  • $5,000 for the permit holder
  • $5,000 for the employer

The Law also requires permit holders maintain a log of trained workers or face fines up to $2,500.

The DOB is planning unannounced site checks where untrained workers have been found and will target other jobs of permit holders with past violations!

We’re Here to Help

TSCTA is regularly communicating with the regulatory agencies responsible for the implementation of the new requirements. We know you have questions and we’re actively working to deliver the answers you need to comply and continue to work.

Have specific questions about Local Law 196 that we can answer? Email us your inquiries here.