NYC has enhanced and expanded the site safety program application to buildings between 10-14 stories and not only are requiring a site safety program prior to permitting but there is a new requirement for the identification and designation of a site safety coordinator. The coordinator must obtain his/her certification from the DOB and while the site safety coordinator position does not require a test, it requires a combination of training and experience. The DOB has also initiated a low-rise safety program thus expanding safety inspections to the entire NYC construction universe.
In addition, the NYC DOB has registered superintendents also on the basis of training and experience and require that either a site safety manager or registered super "sign on" to any permit.
Also, the NYCFD has also required the designation of a fire safety manager on job sites under rule FC1408 and inspection guide 7 and the development of a pre-fire plan for job sites. This is being overseen and enforced by the newly created construction, demolition, abatement unit of the Bureau of Fire Prevention that will inspect sites on a regular basis.
The site safety manager or site safety coordinator must also ensure that the newly required 10 hour OSHA training and job site orientation requirement are being adhered to on the site and also identified in the site safety plan and program. He must also see the appropriate training is in place for the workers as required by suspended and platform scaffold requirement. Also the new crane requirements for pre jump meetings, inspections and record keeping are in vogue.
Also, the requirement for concrete safety manager (who must go through a training course and obtain certification) must be adhered to for the 2,500 cubic foot concrete thresholds that will affect not only superstructure concrete contractors, but many foundation contractors.
In addition, certain parameters have been adapted by rule or legislation for specific standpipe inspection which will probably require some pro-active testing, inspection, and pressurization monitoring. New requirements are also being enforced for site safety plan enhancement as well as noise mitigation plans, no smoking policies and housekeeping parameters.
Be aware all hoist plates must be secured to the machine and must be shown on hoist plan approvals.
There must be an inspection program for safety straps and some installation may in some cases require testing. In addition, concrete operations have experienced some focused inspection activity by DOB and in some cases resulted in contractors filing and permitting their shop drawings (such as rebar, shoring, formwork) just as excavation contractors have done for underpinning and the filing has resulted or required the development of a "controlled inspections" program. Pre construction surveys and vibration monitoring requirements (in conjunction with NYCTA required monitoring if applicable) create a substantial adjacent property monitoring program.
In addition, certain scaffolds that were always considered "moveable" (Baker Scaffold) as well as structural outrigger systems and platforms have been required to be filed, permitted and subject to controlled inspections.
DOB's enforcement efforts have been enhanced through the development of "focused" enforcement units, like the B.E.S.T. Squad for safety, for excavation/foundation, scaffold and concrete. Combine this with the recent policy of personally issuing violations to Site Safety Managers and the development of contractor safety registration numbers and the recent legislation for allowing DOB to put their own Safety Compliance officer on "bad" projects, you have the makings of a tough enforcement program with teeth that will reward good guys and substantially penalize the bad. This is not even to mention the "criminal" side or exposure of these requirements.
We should all realize in our industry now it's safety with a capital "S" and today it's more efficient to invest in doing the right thing up front than experiencing the cost of not complying at the end.
Matt Caruso is the executive vice president of operations for Construction & Realty Safety Group, Valley Stream, N.Y.
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