Upcoming OSHA Training Compliance Deadlines for NYC Local Law 196 of 2017

Signed into law in October 2017, Local Law 196 enacts new OSHA training requirements for New York City construction workers and supervisors at certain job sites. The first implementation deadline is March 1, 2018.

Local Law 196 applies to*:

Workers at job sites that require a Site Safety Plan must be trained. This includes sites that are required to designate a Construction Superintendent, Site Safety Coordinator or Site Safety Manager. Supervisors at these job sites must also be trained. This includes Site Safety Managers, Site Safety Coordinators, Concrete Safety Managers, Construction Superintendents and competent persons.

Workers will be required to receive between 40 and 55 hours of training.

Supervisors will be required to receive between 60 and 75 hours of training.

Training will be phased-in over three deadlines beginning on March 1, 2018, with full training being required by as late as September 1, 2020*:

• March 1, 2018 – All workers must have received a minimum 10 hours of training
• December 1, 2018 – The earliest date by which workers must have at least a Limited Site Safety Training Card, which includes a minimum 30 hours of training.
• May 1, 2019 – The earliest date by which workers must have a Site Safety Training Card, which means that they have been fully trained

Final deadlines will be announced by the NYC Department of Building once they have determined whether there is sufficient capacity to provide training.

For the March 1 deadline, at a minimum, the following training will be required:

• An OSHA 10-hour class; or
• An OSHA 30-hour class; or
• A 100-hour training program approved by the Department (such as training received through an apprenticeship program).

Online training is acceptable for meeting these requirements as follows:

• Online training in any format received before October 16, 2017 will be accepted.
• After October 16, 2017, only in-person training and actively proctored online training will be accepted. Actively proctored online training is:

− online training that is taken in a classroom with a proctor; or

− online training that at a minimum requires the individual receiving the training to attest that they are the individual that received the training and that the training was received without assistance; and to have their participation monitored at random times to ensure that the individual receiving the training is present for the entirety of the training.

For complete details on the regulation, see the presentation at NYC.gov.