Raising the Bar of Safety Training: NYC’s Local Law 196

As a follow up to Safety Week, the importance of safety and training is at the top of the list for most safety-oriented people.  With an increased commitment to safety training, New York City’s Department of Buildings will begin to enforce Local Law 196 of 2017 starting in December of this year.  As part of a response from an increase in construction related fatalities a few years ago, the New York City council passed LL 196 to require contractors to have a much higher commitment to safety training to work inside the city. 

​As the law will continue to be phased in over the next year, all workers at commercial construction jobsites will be required to have 40 hours of safety training and all supervisors will require 62 hours of safety training.  In addition, all workers will be required to have a Site Safety Training (SST) Card.  This card is to provide access to an online verification system, dates of course completion and expiration, a unique identification card number, photographs of the person to whom it was issued, and the printed name of the signature of the card holder.  So what training is needed?

Worker Required Training:

OSHA 10 Version	OSHA 30 Version	100 Hour Training Program Version
OSHA 10-Hour 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​ ​	OSHA 30-Hour 8-Hour Fall Prevention 2-Hour Drug and Alcohol Awareness​	100-Hour training program that at a minimum meets the coursework identified in the curriculum for the SST Card (OSHA 10 Version)​

Supervisor Required Training:

OSHA 30-Hour 8-Hour Fall Prevention 8-Hour Chapter 33 (Site Safety Manager Refresher) 4-Hour Supported Scaffold User 2-Hour Site Safety Plan 2-Hour Toolbox Talks 2-Hour Pre-Task Safety Meetings 2-Hour Drug and Alcohol Awareness 2-Hour General Electives 2-Hour Specialized Electives

Renewal Training:
How long does this training last? The SST card is valid for 5 years before a renewal is required. Within the one-year period prior to renewal application, each worker is to take a 4-Hour Fall Protection and 4-Hour Supported Scaffold User training class. All supervisors are required to take 8-Hour Fall Prevention, 4-Hour Supported Scaffold, 2-Hour Toolbox Talks and 2-Hour Pre-Task Safety Meetings training courses.  All training must be done in person or an actively proctored online training.

Enforcement:
What happens if you don’t live up to the new standard? Well the worker, employer and owner of the project can all be fined up to $5,000 per untrained worker.  In addition, each permit holder is required to maintain the BC3321.2 Log which maintains the information of all trained workers and their SST Cards or be fined $2,500 per occurrence. 

​Safety and safety training should be an integral part of every company culture, especially in construction.  Tracking and documenting that training is an important component in addition to providing the training because if there is no proof, it did not happen in most people’s eyes.  Since we are all forgetful and busy people, refreshing training should be a routine part of your company’s culture as well.  Although, not every city or state will go as far as NYC, it is important to reinforce the need and commitment to safety within a company and community.  As a commitment to this ideology STAC will also be introducing the new STAC Safe Badge to companies that show an increased commitment to safety training. More to come, stay tuned.