Signed into law by Mayor De Blasio in October 2017, Local Law 196 commands that construction workers at specific sites receive 40 hours of safety training, while the supervisors of certain job sites receive 62 hours of safety training. While some of Local Law 196's previous deadlines were delayed, the most recent deadline for Phase 2 went into full effect on December. 1, 2019.
Prior to the deadline, DOB inspectors began sweeps of over 6,000 construction sites to educate workers about the city's safety training deadline. Additionally, inspectors will be examining work sites and issuing violations of up to $25,000 if they find the following conditions:
- Incorrect scaffold safety measures
- Failure to install/use construction cranes in accordance to approved plans
- Non-adequate fall protection systems being utilized
- Failure to meet existing construction safety regulations
Read on to avoid violations and ensure you and your company's personnel are in full compliance with Local Law 196.
Who needs to be trained?
Construction or demolition workers and supervisors (Site Safety Managers, Site Safety Coordinators, Concrete Safety Managers, Construction Superintendents and competent persons) at job sites that require a Site Safety Plan (sites that must designate a Construction Superintendent, Site Safety Coordinator or Site Safety Manager) must receive training.
Pictured on the left: The DOB's active map of the city's constructions sites that must meet Local Law 196 safety training requirements.
Phases of Local Law 196
The NYC Local Law 196 consists of three phases:
Phase 1: This phase was initiated on March 1, 2018. It required that all construction workers and supervisors have at least 10 hours of training.
Phase 2: The second phase of the deadline went into effect on December 1, 2019. It requires construction workers carry at least an SST Card Limited Site Safety Training (SST) Card (30 hours for workers and 62 hours for supervisors).
Phase 3: The law’s final deadline is September 1, 2020 and it requires workers to have completed their training, which includes OSHA 10, OSHA 30, and the DOB-approved 100-hour training.
How do I get trained?
The answer to this question can be found in this DOB bulletin which contains copious information on the types of training required for each phase depending on job role.
What happens if the training isn’t completed?
Permit holders are required to attest that workers are trained. A violation with a civil penalty of up to $5,000 per untrained worker will be issued to the site owner. the permit holder, and the employer of the untrained worker. A violation with a civil penalty of $2,500 will also be issued if a permit holder fails to maintain a log that proves all the workers on a site are trained.
Who enforces Local Law 196?
The newly formed Construction Safety Enforcement Unit (CSE) and Construction Safety Compliance Unit (CSC) will work in tandem to enforce Local Law 196’s safety compliance requirements at construction sites throughout the city. The B.E.S.T. Squad, Excavation/Interior Demolition and Scaffold Safety Units previously held this responsibility until the DOB retired and reorganized them into CSE and CSC.
Construction Safety Compliance Unit
The Construction Safety Compliance (CSC) Unit performs proactive periodic inspections on all active sites, performing plan examination of site safety plans and full demolition plans, processing site safety-related waiver requests, scaffold safety inspections and interior/full demolition inspections.
- - Demolition Sign-off
- - Pre-Demolition Inspection
- - Sidewalk Shed Removal
- - Site Safety Manager/Coordinator Program Removal
- - Suspended Scaffold Pre-Use Inspection
Construction Safety Enforcement Unit
The Construction Safety Enforcement (CSE) Unit conducts emergency inspections and responds to construction incidents and accidents as well as responding to construction complaints and inspections for violations or SWOs issued by the CSC Unit. The unit also performs technical reviews/audits of construction documents to verify code compliance.
If you have any questions on how to comply with the Local Law 196 requirements, please reach out to Milrose and we will be happy to assist you.