Local Law 196 requirements primarily include that workers at job sites must designate a Construction Superintendent, Site Safety Coordinator, or Site Safety Manager. This manager must undergo safety training. Some deadlines have already passed, but additional training is required by Sept. 1, 2020.
Local Law 196 Reminder
NYC Local Law 196 was signed in 2017 to improve the safety of construction and demolition sites around the city. Local Law 196, OSHA, and other safety regulations were put in place to minimize injury. The law works through what are essentially layers of required training. Coming up in 2020, the final deadline will hit.
As a quick reminder, I’ll go through some of the major milestones of the legislation. At its base level, LL 196 went into effect in early 2018 and mandated that all construction and demolition workers, as well as their site supervisors, received 10 hours of safety training.
The next deadline just passed on Dec. 1, 2019, mandated that workers and site supervisors earn and carry a Site Safety Training (SST) card. To earn this card, workers were required to attend 30 hours of training while site supervisors were required to hit 62 hours.
The final deadline will arrive on Sept. 1, 2020, and mandates that workers acquire much more training.
Hitting the Sept. 1, 2020, Deadline
Local Law 196 requires that, by Sept. 1, 2020, all workers meet three training requirements.
OSHA 10 – This 10-hour training course is available online and covers topics including fall protection, protective equipment, electrocution risks, and more. It is likely that, by this point, workers in New York City have already completed this course due to compliance requirements with earlier deadlines.
OSHA 30 – This 30-hour course is also available online and covers more extensively the topics included in the OSHA 10 training. Topics include the OSHA Construction Focus Four (major fall, caught-in/-between, struck-by, and electrocution), crane hazards, steel structure hazards, fire hazards, and more. This training may also have already been completed as a part of previous requirements under NYC Local Law 196 and other city or state requirements.
Department of Buildings-Approved Training – Other than the OSHA-approved training classes, Local Law 196 also requires that 100 hours of additional training approved by the NYC Department of Buildings be completed.
Inspectors with the City of New York, discussed specifically later, will be visiting registered construction and demolition sites to verify that proper safety procedures are being followed. Potential violations include incorrect scaffolding safety measures, failure to install and use cranes in accordance with required training, inadequate fall protection, and other safety issues.
Construction permit holders are required to maintain a log and attest that all workers on the site have undergone proper safety training. If that log is not maintained, the permit holder can be fined $2,500 per untrained worker on the site. The site holder, the permit holder, and the employer of the untrained worker can also be fined $5,000 per untrained worker. These violations all constitute civil penalties.
Local Law 196 mandates that workers undergo extensive OSHA and DOB-approved training if construction permit holders, site owners, and employers are to avoid extensive fines.
Enforcing Local Law 196 in New York City
Local Law 196 mandates that the Construction Safety Enforcement Unit (CSE) and the Construction Safety Compliance Unit (CSC) conduct inspections and enforce safety compliance at construction and demolition sites throughout the city.
The CSC is tasked with proactive measures including inspections of active sites and construction plans. This unit will ensure that sites are meeting compliance requirements, waivers are granted, and all related compliance needs are met.
The CSE, on the other hand, is designed as an emergency response unit. The CSE will conduct emergency inspections and respond to incidents and accidents on a reactive basis. Together, these two units constitute a comprehensive enforcement structure.
Where React Industries Comes In
In our recent blogs on the topics of important local laws in New York City, React has set out to help building owners and property managers in NYC meet changing environmental and safety compliance requirements. If you’re interested in learning more about Local Law 196 updates or any of the other new regulations in the city, we are happy to help. Contact us today.