The New York City building code is an ever-changing panoply of rules and regulations, with new local laws and regulations coming out every day. Miss a new regulation and your project could be faced with thousands of dollars in fines for each occurrence.
It is extremely important to stay up to date and educated on national OSHA regulations but if you are working in New York City you must take it a step further and make sure you know all the Local Laws that DOB enforces as well. I have worked on different construction sites in different states and every state and even city has their own rules. New York City is complex because you have OSHA, Department of Buildings (Building Codes), Chapter 33 (with different revisions), FDNY, Department of Transportation, and more. There are many entities in New York City that are involved in starting a construction project here. You have to continually coordinate and check on your paperwork and filings. Permits also pay a huge factor. Learning the ropes comes with years of experience and mentoring from trusted expeditors and safety professionals.
The biggest concern in the industry right now is Local Law 196. Local Law 196 of 2017 requires workers at job sites that must designate a construction superintendent, site safety coordinator or site safety manager to receive 30 hours of site safety training by December 1, 2019, and an additional 10 hours of training by September 1, 2020.
All construction professionals are trying to understand exactly what the difference is between the different trainings are, when the deadlines will be enforced and how it is going to directly affect their company and their staff. For us we need to know how it will affect our staff and our projects. We tackled the task of getting our staff trained with at least 30 hours of OSHA “NYC DOB Local Law Approved Training” first. There are so many schools, courses, online and in-person training for OSHA 30 but not all of them will be accepted. We have a lot of subcontractors that found out the hard way by spending money and time online for training only to find out it isn’t accepted by NYC DOB. Once we had our staff LL196 compliant we pushed it even further and started the SST training (62 hours) which could be applied towards becoming eligible to become a competent person. KBE-NY project manager Michael Kolakowski Jr. and I worked together to strategize how we could ensure our company and projects would not suffer from LL196 being enforced. We knew if the contractors were not able to finish their training in time we would suffer from a lack of manpower on our projects. We continued to stay on top of all DOB updates online, attend meetings at the DOB, events, consult our safety trainers and research as much as we could. We coordinated with our contractors and workers to make sure we kept everyone informed and on track for completing their training so we would be prepared for the deadline coming up in December. Local Law 196 was postposed last year but we feel this year it will be enforced and we are ready. This law goes for all construction workers performing work on job sites in New York City. Project manager and consultants are exempt right now but we have taken precautions and finished the training just in case. There are a series of additional hours that will be due in 2020. We advise if you are in the industry even as a consultant, designer, owner, architect, or vendor, check out your options for OSHA training and DOB approved courses. It is a great way to stay informed and get ahead start incase New York City DOB does implement a new law that may affect you.
For more information on Local Law 196 check out the link to the NYC DOB website and updates.
https://www1.nyc.gov/assets/buildings/local_laws/ll196of2017.pdf
https://www1.nyc.gov/assets/buildings/pdf/ll196_updates_sn.pdf
Leslie Cook is a senior project engineer with KBE-NY, LLC, New York, N.Y.
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