On May 9th, NYC Department of Buildings (DOB) Commissioner Rick Chandler released the full safety-training requirements for Local Law 196 of 2017 (LL196). The announcement established that workers at certain job sites will need 40 hours of safety training and that supervisors will need at least 62 hours of training. Details about the number of hours and the makeup of the course curriculum had been eagerly anticipated by the construction industry, which must comply by next spring and applies to workers and supervisors for which DOB requires construction superintendents, site-safety coordinators, or site-safety managers. The initial compliance date under the law took effect March 1, 2018, with the remaining requirements to take effect in stages over the next 12 to 28 months.
Quick LL196 History
Ongoing instances of preventable accidents, injuries, and fatalities on job sites in NYC contributed to the passage of LL196 by the New York City Council, which Mayor de Blasio signed into law last October. LL196 requires all construction workers, demolition workers, and supervisors on jobs that require a site safety plan to complete this mandated training. As of March 1, 2018, workers were required to have at least a 10- or 30-Hour OSHA Training program; failure to comply means stiff penalties of up to $5,000 for permit holders, owners, and employers (if different from permit holder). With the recent announcement of the full Site Safety Training (SST) Curriculum last week, the DOB moves towards the next compliance milestone, 12/1/18 or 6/1/19.
Full SST Curriculum
A link to the full SST Curriculum for Workers and Supervisors as published by the DOB can be found here (PDF).
Some points of clarification:
What’s the easiest way for workers to meet the training requirements for the next compliance deadline, 12/1/18?
What’s the easiest way for Supervisors to meet the training requirements for the next compliance deadline?
Unfortunately, we’re going to have to wait and see what is announced by DOB at the end of this month when additional details about which training courses can be used to meet the 62-hour requirement for Supervisors is published.
In the meantime, keep in mind that LL196 does contain the provision for training that was completed beyond the 5-year lookback in the law. This option may afford you the opportunity to qualify for the Supervisor SST Card by completing only the training outlined under the Prior Experience Note on the DOB’s recent Service Notice.
Prior Experience Note: If one or more of the required training under LL 196 was taken in excess of 5-years prior to applying for an SST card of any kind. The applicant – Worker or Supervisor – may complete the 4-Hour Fall Prevention and 4-Hour Supported Scaffold User courses in the one-year preceding submittal of an application for an SST card.
Why are two deadlines listed in the DOB memo?
The reason for two deadlines is that the effective dates may be extended to the later date if the DOB determines insufficient capacity to provide the training which is not presently expected.
What is the final deadline for Supervisors?
Supervisors must have met all course requirements and have their Supervisor SST card by 12/1/18.
How To Get Ahead and Stay In Compliance
We understand that the DOB’s requirements are a lot to take in and we’re always here to help. While we now know the exact number of hours and subject matter required, there are still some additional points to be clarified by the DOB. It’s widely expected that the DOB will be releasing those details by months end so stay tuned to Gallagher Bassett as we’ll continue to share this critical information on our site, social media channels, and newsletter. If you’re looking for a quick list of LL196 Required Training, you can bookmark this page.