Understanding Local Law 196: Who Is Affected And How?

Local Law 196 (LL 196) is a New York City law that requires construction workers to receive 40 hours of safety training and supervisors to receive 62 hours of safety training. The law was created in response to the increasing number of injuries and fatalities on construction sites in New York City. LL 196 applies to all jobsites with a Site Safety Plan and construction workers must carry an SST card to prove they are up to date with SST requirements.

Construction workers at specific sites

Local Law 196 of 2017 was passed in response to the rising number of construction-related injuries and fatalities in New York City. The law requires certain construction workers at specific sites to complete a certain number of hours of safety training, depending on their job and responsibilities.

Who does Local Law 196 apply to?

Local Law 196 applies to workers at sites that require a Construction Superintendent, Site Safety Coordinator, or Site Safety Manager. This includes new buildings and buildings under demolition nine stories and below. Site Safety Coordinators are required on new buildings 10-14 stories under construction or demolition, while Site Safety Managers are required on new construction or demolition sites 15 stories and above or 100,000 sq. ft. or greater.

All workers and supervisors at these sites must be trained, including the above roles and any other "competent persons". However, there are some exemptions. Delivery persons, flag persons, professional engineers, registered architects, department licensees, and department registrants (excluding safety professionals) are not required to have safety training.

Additionally, workers at sites that only involve minor alterations or the construction of a new 1-, 2-, or 3-family home are also exempt. Employees working under the direct supervision of a licensee are required to have training.

Training Requirements:

Under Local Law 196, workers at the specified construction sites are required to complete a minimum of 40 hours of safety training. Supervisors at these sites are required to complete 62 hours of safety training. The training must be provided by a New York City Department of Buildings (DOB) approved training provider and covers a range of safety topics, including general safety and health, hazard communication, and scaffolding or concrete safety (if applicable).

The law is implemented in three phases, with increasing training requirements:

• Phase 1 (March 1, 2018): All workers must have received a minimum of 10 hours of certified training.
• Phase 2 (December 1, 2019): Workers must have at least a Limited Site Safety Training (SST) Card, which includes 30 hours of training. Supervisors must have an SST Supervisor Card, which requires 62 hours of training.
• Phase 3 (September 1, 2020): Workers must complete their training, which includes OSHA 10, OSHA 30, and the DOB-approved 100-hour training.

Enforcement and Penalties:

The Construction Safety Enforcement Unit (CSE) and Construction Safety Compliance Unit (CSC) are responsible for enforcing Local Law 196's safety compliance requirements at construction sites throughout the city. They conduct inspections, respond to incidents and accidents, and issue violations for non-compliance.

Permit holders are required to ensure that workers are trained and maintain a daily log of trained workers. Failure to comply with these requirements can result in civil penalties of up to $5,000 per untrained worker and $2,500 for each violation of failing to maintain proper records.

Local Law 196 aims to enhance safety and reduce injuries and fatalities among construction workers in New York City. By mandating comprehensive safety training and enforcing compliance through inspections and penalties, the law strives to create a safer work environment in the construction industry.

Supervisors of certain job sites

Supervisors at construction sites must receive at least 62 hours of safety training. This includes supervisors such as concrete safety managers, construction superintendents, site safety managers, and site safety coordinators. The training covers a range of safety topics, including general safety and health, hazard communication, andsection on scaffolding or concrete safety if their work involves these tasks.

The New York City Department of Buildings (DOB) has set specific deadlines for supervisors to complete their training. By March 1, 2018, supervisors were required to have at least 10 hours of training. The second deadline, December 1, 2019, required supervisors to have 62 hours of training. The final deadline is yet to be announced.

It is important to note that permit holders are responsible for ensuring that the supervisors on their site have completed the required safety training. Failure to comply with Local Law 196 may result in fines and penalties for the permit holder and the employer of the untrained supervisor. These penalties can be significant, with a $5,000 fine for each untrained supervisor.

To ensure compliance, the DOB conducts random site inspections and issues violations if they find any issues related to scaffold safety, construction crane usage, fall protection systems, or existing construction safety regulations. Additionally, permit holders are required to maintain a daily log that lists all supervisors and proof of their completed safety training.

Construction and demolition workers

Local Law 196 (LL 196) of 2017 was passed in response to the rising number of construction-related injuries and fatalities in New York City. The law requires construction and demolition workers at most major worksites in the five boroughs to have 40 hours of Site Safety Training (SST) and an SST Worker card.

The New York City Department of Buildings (DOB) is responsible for enforcing LL 196, which aims to promote safer job sites and enhance safety training in the construction industry. The law applies to all jobsites with a Site Safety Plan, and most workers at these sites must carry an SST card to prove they are up to date with SST requirements.

There are some exemptions to the law. Workers at job sites that only involve minor alterations or workers involved in the construction of a new 1-, 2-, or 3-family home are not required to be trained. Additionally, professional engineers, registered architects, department licensees, and department registrants (excluding safety professionals) are also exempt.

However, if an exempt worker serves as a Safety Manager or competent person, they will need to undergo the training. Employees working under a licensee's direct supervision will also need to be trained.

The training must be provided by a DOB-approved training provider and covers a range of safety topics, including general safety and health, hazard communication, and specialised training for tasks such as scaffolding or concrete safety.

The rollout of LL 196 has been phased in gradually, with different deadlines for different types of workers. As of March 2023, all workers on construction sites in New York City must have completed the required safety training and hold a valid Training Connect SST card.

There are penalties for non-compliance. Employers who fail to comply may face fines ranging from $2,500 for failure to maintain a log demonstrating a properly trained workforce, to $5,000 per untrained worker for each of the site owner, the permit holder, and the employer of the untrained worker.

To ensure compliance, the DOB has been conducting random site inspections and issuing violations. They have also been working with the Construction Safety Enforcement Unit (CSE) and Construction Safety Compliance Unit (CSC) to enforce LL 196's safety compliance requirements at construction sites across the city.

Workers at jobsites with a Site Safety Plan

Local Law 196 (LL 196) applies to workers at jobsites with a Site Safety Plan. This includes jobsites with a designated Construction Superintendent, Site Safety Coordinator, or Site Safety Manager. If you work at a location with any of these safety measures in place, you will need to complete additional training and carry an SST card.

The amount of training you need will depend on your role and responsibilities at the job site. Workers are required to complete a minimum of 40 hours of safety training, while supervisors need a minimum of 62 hours. This training must be provided by a New York City Department of Buildings-approved training provider and should cover a range of safety topics, including general safety and health, hazard communication, and specialised training for tasks like scaffolding or concrete safety.

To obtain your SST card, you will need to complete the required number of training hours and then apply for the card. The courses you need to take will vary depending on your job title and past training experience. For example, current workers and new entrants may need to take different courses to meet the 40-hour training requirement for workers.

It's important to note that there are deadlines for completing the training and obtaining your SST card. These deadlines are enforced by the NYC Department of Buildings, and non-compliance can result in fines and penalties for employers and site owners.

To check if your job site requires an SST card, you can refer to the DOB's Site Safety Construction Map or contact them directly for clarification.

Workers at major worksites in the five boroughs

Local Law 196 (LL 196) applies to workers at major worksites in New York City's five boroughs. The law requires construction and demolition workers at these sites to undergo a minimum level of safety training and hold a Site Safety Training (SST) card. This training aims to reduce construction-related injuries and fatalities, which have been on the rise in the city.

The amount of training depends on the worker's job and responsibilities. Workers must complete at least 40 hours of safety training, while supervisors are required to undertake a minimum of 62 hours. The training covers various safety topics, including general safety and health, hazard communication, and scaffolding or concrete safety (if applicable to their work).

The law is implemented in phases, with different deadlines for workers and supervisors. The first phase, which began on March 1, 2018, required all construction workers and supervisors to have a minimum of 10 hours of training. The second phase, effective from December 1, 2019, mandated that workers possess an SST Card Limited Site Safety Training (SST) Card, with 30 hours of training for workers and 62 hours for supervisors. The final deadline of September 1, 2020, required workers to complete their training, including OSHA 10, OSHA 30, and the DOB-approved 100-hour training.

To obtain an SST card, workers must complete the required number of training hours from a New York City Department of Buildings-approved training provider. The training can be done through various paths, depending on the worker's job title and past training experience. For instance, current workers can opt for an OSHA 30 Card, while new entrants must finish an OSHA 10-Hour Course and 30 Hours of Additional Training.

Failure to comply with LL 196 can result in significant fines and penalties for employers. These range from $2,500 for not maintaining proper logs to $5,000 per untrained worker for the site owner, permit holder, and employer. The Department of Buildings (DOB) enforces these safety compliance requirements through random site inspections and issues violations for non-compliance.

Frequently asked questions