New submission rules, construction superintendent limits, revoked training, and their potential impacts on your next project.

Site safety has become a major focal point for the DOB in recent years, with increases in training and requirements correlating with fewer incidents for construction workers across NYC.

As such, the DOB has recently released a slew of updates on the site safety front, some relating to filing in DOB Now, that contractors need to understand.

Here are the latest updates:

Site Safety Plan Submission in DOB Now

Beginning July 15, 2022, site safety plans can be submitted before job approval in DOB Now for projects requiring one.

This is how it works: Once a job is submitted, the plan examiner will review the site safety criteria. This will include the building height, stories, footprint, and additional considerations for alteration and/or demolition.

Once this criteria, separate from the job itself, has been approved, a banner will appear on the filing and an email will be sent to the stakeholders that the site safety plans can be submitted.

In addition, you will no longer need to submit site safety plans for subsequent filings under the same Job Filing number – only once for the whole job.

This change should help ease filing concerns, since buildings between 7-9 stories now require site safety plans.

Construction Superintendent Job Limitations

On the flip side, the DOB has also increased requirements for construction superintendents that could cause roadblocks.

Under Local Law 149 of 2021, which went into effect on June 1, 2022, an individual may not be designated as the primary construction superintendent (CS) for more than five active jobs at a time, a major decrease from the previous limit of ten. The DOB will not issue permits for active projects who have listed a CS with more than five jobs.

For projects in this position, options are as follows:

• The offending CS may request to be withdrawn from the job permit by sending a signed letter,
• The permit can be renewed with under different CS through a PW2 or DOB Now, or,
• A request can be submitted to release the site safety requirements from the job in DOB NOW: Build, in which case the CS would need to be released through a signed letter.

Revoked Certificates and SST Cards

Finally, construction professionals should be advised that anyone who completed a course through EHS Academy LLC for certificates of completion or Site Safety Training Cards, said certifications have been revoked.

Because EHS Academy has failed to comply with regulations and is no longer authorized to conduct DOB-approved courses, all training received through them is no longer seen as valid, as of June 23, 2022.

If you have been impacted, you will need to re-take impacted training with a DOB-approved provider.

Those with an OSHA-10 or OSHA-30 Construction Industry card NOT issued by EHS may apply for a Temporary Site Safety Training Card, which will cover you for six months while you retake training. But those with SST cards issued directly by EHS will not be eligible for any type of replacement card until after training has been redone.

For assistance on filing site safety plans or any other necessary documents, please reach out to the team at Outsource Consultants

Resources

• Site Safety Service Update
• EHS Service Update
• Decoder – “Redefining Moment: Proposed Local Laws Expand “Major Building” Status and Safety Requirements”