In the previous issue of SKYlines, we provided an in-depth overview on Local Law 196, formerly known as Introduction 1447-C, which made amends to the Administrative Code of the City of New York and the New York City Building Code, in relation to construction Site Safety Training (SST). The new mandates require New York City construction workers to complete 40-55 hours of safety training in three phases beginning on March 1, 2018 and ending in 2019.
Phase 1: By March 1, 2018, Local Law 196 requires workers to complete OSHA-10; or OSHA-30; or a DOB-approved 100-hour training program.
Phase 2: By December 1, 2018, Local Law 196 requires workers to complete OSHA-10 and 20 additional DOB-approved training hours; or OSHA-30; or a DOB-approved 100-hour training program.
Phase 3: By May 1, 2019, Local Law 196 requires workers to complete OSHA-10 and 30-45 additional DOB-approved training hours; or OSHA-30 and 10-25 additional DOB-approved training hours; or a DOB-approved 100-hour training program.
As Phase 1 approaches, it is critical to understand additional information pertaining to Local Law 196, such as which additional individuals need training; what constitutes acceptable training; and the violations that follow the failure to comply.
This information is broken down below.
Additional SST Trainees:
New Entrants to Construction: Individuals new to construction must complete an OSHA 10 training course before working, followed by the completion of 40 hours within six months to continue working.
Supervisors: Competent Persons, Construction Superintendents, Concrete Safety Managers, Site Safety Coordinators, and Site Safety Manager must complete a minimum of 60 hours of training.
Site Safety Jobsites: Workers at job sites with a Site Safety Plan (and jobsites with Superintendent, Site Safety Coordinator or Site Safety Manager) must complete a minimum of 40 hours of training by the final phase ending in 2019.
After October 16, 2017, all Site Safety Training must be in-person or actively proctored online. Any online training received before October 16, 2017 will be accepted.
Proper online training is defined as: training taken in a classroom with a proctor; online training where the individual is able to prove that they received the training with no assistance; and training that is randomly monitored to ensure that the trainee is present through the entirety of the online course.
Failure to show the DOB that workers are properly trained will result in a violation and civil penalty - incurred by the site owner, permit holder and the employer of the worker - of up to $5,000 per untrained worker.
An additional violation and civil penalty of $2,500 will also be issued if the permit holder regrets to upkeep the required workers’ log proving completion of training.
For complete information regarding Local Law 196, please visit the following link