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Full Compliance SST Cards Now Required at Qualifying Job Sites

Permit holders liable for all workers who did not complete 40-hour training as of March 1, 2021.

As of March 1, 2021, construction and demolition workers at certain job sites must carry their Site Safety Training (SST) cards issued by a DOB-approved course to be able to work, to certify they have completed 40 hours of site safety training.

Under Local Law 196 of 2017, building permit holders must ensure that workers and supervisors at job sites requiring a Construction Superintendent, Site Safety Coordinator or Site Safety Manager have received approved training in subjects such as electrocution and fall prevention.

Background

Construction work is one of the deadliest professions in the city, regularly racking up the highest number of work-related deaths. Unfortunately, there is often a correlation between increased construction work and increased construction injuries – according to Crain’s New York Business, deadly construction accidents increased each year from 2014 to 2018, in correlation with a citywide construction boom, with 2018 having the highest number of construction-related injuries since 2008.

While the number of job injuries went down 34% in 2020 according to a January 2021 DOB press release, possibly in relation to the required training, a construction worker died from a fall in Midtown as recently as February 26, 2021. The work toward better site safety is far from over, but mandated training provides a helpful first step.

Workers should have already completed 30 hours of training as of December 1, 2019, at which point they would have received their OSHA 30 card to qualify to work onsite. With the disruptions of the past year, the original full compliance deadline of September 1, 2020 was pushed back 6 months to accommodate those who still needed to get their final 10 hours of training.

Requirements & Penalties

For permit holders, the responsibility falls on you to make sure your workforce is trained, including keeping daily logs of each worker and their SST card.

Incomplete training not only makes it illegal for the worker to do their job, but can include a fine of up to $5,000 per untrained worker and unannounced inspections from the DOB at any sites where an untrained worker has previously been discovered. In addition, if you failed to maintain a log that demonstrated that all of the workers at a site are trained, the DOB can issue a fine of $2,500.

As of October 2020, the Construction Safety Compliance (CSC) unit have identified 900 construction sites where approximately 1,500 workers did not have their required training, resulting in over $2 million in penalties.

For qualifying job sites, the following workers require safety training:

Construction Workers
Demolition Workers
Construction Superintendents (CS)
Site Safety Coordinators (SSC)
Site Safety Managers (SSM)
Concrete Safety Managers (CSM)
Competent Persons
Journeypersons
Forepersons
Employees of DOB Licensees or Registrants

You will also have to make sure workers take a refresher course to get their card renewed every 5 years, when the initial training expires.

For workers who are new to the field, a Temporary SST card will be required, which can be obtained by completion of an OSHA 10-Hour course. This will be valid for 6 months (non-renewable), to give time for the worker to catch up on the other 30 hours of training.

A Digital SST card, connected to an interactive and secure application, or a printout of the front of the SST card, issued by an approved course provider, can also count as acceptable proof. (Note: Printout is only good for 60 days from date of issuance, to allow time for physical card to be sent.)

The pandemic has shown that the safety of construction workers matters. From better job site cleaning and sanitation protocols to increased training, it’s important to keep workers protected and informed on the job.

For more on training, for assistance in clearing violations, or any other filing issues, feel free to reach out to us at Outsource Consultants.

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