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February 22, 2021

FROM: Steven Davi

Steven N. Davi

Executive Director and General Counsel

Reminder- Final SST Compliance Deadline Under NYC Local Law No. 196

This is a reminder regarding the remaining site safety training (“SST”) requirements under New York City Local Law No. 196 (“LL196”).  

As you know, LL196 mandates that construction and demolition workers at covered job sites must receive a total of forty (40) hours of designated site safety training. LL196 established a series of incremental milestones in this regard. 

As of December 1, 2019, covered construction and demolition workers at covered building sites across the city were required to have successfully completed at least thirty (30) hours of approved site safety training. Accordingly, permit holders and entities tasked with compliance under LL196 were advised to ensure their covered workers obtain a thirty-hour OSHA card, or were otherwise compliant, by the December 1, 2019, interim compliance date. 

In August, 2020, in consideration of the industry disruptions caused by Covid-19, the NYC Council passed a bill to extend from September 1, 2020, to March 1, 2021, the final compliance milestone under LL196, providing covered construction and demolition workers additional time to March 1, 2021 to successfully complete the last 10 hours of safety training necessary to reach the final 40-hour SST compliance mandate. 

As previously advised, Local 580 and Locals 40/361 are DOB-approved course providers offering site safety training on an as-needed basis in-person or by Zoom through their respective apprentice and journeyman training centers and are authorized to issue Site Safety Training Cards upon the completion of such training. The best option to reach the 40-hour milestone is to ensure that covered workers, in addition to their 30-hour OSHA card, receive 8 hours of fall prevention training and 2 hours of drug and alcohol awareness training. The Locals have gotten the word out among their members regarding these course offerings; members have been instructed to sign up for classes either online via the training centers’ respective websites or by calling the training centers directly, and to arrive for training—whether by Zoom or in-person—with their certifications in-hand from prior trainings they have taken. 

If you have particular workers on payroll that you believe have not completed their forty hours of site safety training under LL 196, please let me know and I can coordinate their training through the unions’ training directors Rich Falasca (Local 580) and Bryan Brady (Locals 40/361); you should also feel free to reach out to Rich (212-736-1244) or Bryan (718-433-2790) directly. Otherwise, safety training is also available from any of the more than one-hundred DOB-approved course providers in and around the NYC metro area. You can search and sort course providers by location using the Department’s interactive course provider map. 

Additional information regarding the SST requirements under LL196 can be found by visiting the Department’s website, which, among its several features, includes an interactive SST work site map showing the exact locations of all of the permitted construction sites in New York City where SST is required, as well as an extensive set of LL196 FAQs.

 Please feel free to contact the Allied office directly if you have any questions regarding any of the above.

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