NYC Enacts New Construction Safety Training Requirements

The New York City Council, on Sept. 27, adopted a new municipal construction safety law – requiring all construction workers on building projects of five stories or higher – to receive receive 40 to 55 hours of construction safety training with periodic refresher courses. The Bill’s (Int. No. 1447-C) passage was a response to several work site deaths involving union and non-union workers.

The bill revises Section 3321 of the NYC building code to add the new training requirements and details about the new Site Safety Training Card (SST Card) program. The new training requirements will be phased in over time with a final deadline of September 2020. The law applies to workers on building projects of five stories or higher.

Classroom or online safety training can be used to fulfill the requirements of the new legislation. For online training, the bill lays out specific requirements that training providers must meet.

  • March 1, 2018 – Every worker on a site requiring a Construction Superintendent, Site Safety Coordinator, or Site Safety Manager must have at least a 10-Hour OSHA Card.
  • December 1, 2018 – Every worker must have either a *”Site Safety Training” (SST) card, a limited SST card, or a temporary SST card.
  • Every Construction Superintendent, Site Safety Coordinator, Site Safety Manager, Concrete Safety Manager or competent person must have a “Site Safety Training” Supervisor card (see complete law below).
  • May 1, 2019 – Every worker must have a SST card or temporary SST card.
OSHA TrainingNYC OSHA Training 10hr/30hr
  • NYC requires all construction workers on building projects of five stories or higher - to have mandated construction safety training.
  • NYC SST cards will be issued to workers who complete OSHA 10-hour, 30-hour, or 100-hour programs. For 10-hour and 30-hour training, workers will be required to complete additional “SST credits” to earn the card.
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Site Safety Training (SST) Cards

NYC OSHA Construction Training will be verified using a “card” system similar to OSHA’s “10-Hour Card” system. SST cards will be issued to workers who complete OSHA 10-hour, 30-hour, or 100-hour programs. For 10-hour and 30-hour training, workers will be required to complete additional “SST credits” to earn the card.

The legislation creates some variants of the SST card:

  • A Temporary SST card can be issued to a new entrant to the construction or demolition workforce who completes an OSHA 10-hour training course, and expires after 6 months.
  • An SST Supervisor Card can be issued to SST card holders who complete an OSHA 30-hour training course.
  • In addition, a Limited SST Card may be issued before the final compliance date in the legislation.

More details about the various types of SST cards can be found in the Bill (Int. No. 1447-C).

Employers: Duties of NYC Construction Safety Permit Holders

The Bill (Int. No. 1447-C) requires permit holders at construction and demolition sites in NYC are responsible for ensuring that each construction or demolition worker they employ—or who otherwise works at the site—meets the new safety training requirements.

3321.2 Duties of permit holder. On and after March 1, 2018, each permit holder at a building site shall be responsible for the following:

  1. Ensuring that each construction or demolition worker employed or otherwise engaged at such site by or on behalf of such permit holder complies with the requirements of Section 3321.1.
  2. Certifying to the department, in a form and manner established by the department, that the requirements of Section 3321 have been met.
  3. Maintaining at such site a daily log, in a form and manner established by the department, that identifies each such worker and that includes, for each such worker, a copy of the SST card, SST supervisor card, limited SST card, temporary SST card or proof of compliance with Item 1 of Section 3321.1, as applicable.
  4. Providing such log to the department upon request by the department.

Employers: Civil Penalties for NYC Construction Safety Training Violations

The Bill (Int. No. 1447-C) lays out civil penalties for violations of the new safety training requirements, as follows (with some exceptions – refer to bill):

§ 28-202.1 Civil penalties. Except as otherwise specified in this code or other law, violations of this code, the 1968 building code, the zoning resolution or other laws or rules enforced by the department shall be punishable by civil penalties within the ranges set forth below:

  1. For immediately hazardous violations, a civil penalty of not less than one thousand dollars nor more than $25,000 may be imposed for each violation. In addition to such civil penalty, a separate additional penalty may be imposed of not more than $1,000 for each day that the violation is not corrected. The commissioner may by rule establish such specified daily penalties.
  2.  For major violations, a civil penalty of not more than $10,000 may be imposed for each violation. In addition to such civil penalty, a separate additional penalty may be imposed of not more than $250 for each month that the violation is not corrected. The commissioner may by rule establish such specified monthly penalties.
  3. For lesser violations, a civil penalty of not more than $500 may be imposed for each violation.

Get NYC OSHA Construction Safety Trained Before the Deadline

The Bill (Int. No. 1447-C) added definitions to the The New York city building code for:

  • 100-hour Training Program, actively Proctored Online Training, limited Site Safety Training (Sst) Card, osha 10-hour Class, osha 30-hour Class, site Safety Training (Sst) Card, site Safety Training (Sst) Credit, site Safety Training (Sst) Full Compliance Date, site Safety Training (Sst) Provider, site Safety Training (Sst) Second Compliance Date, site Safety Training (Sst) Supervisor Card, site Safety Training (Sst) Task Force” And “temporary Site Safety Training (Sst) Card.

Avoid the rush, crowds, and penalties – sign up for NYC OSHA online construction safety training today!