OSHA 10 and 30 NYC - Your Top Questions Answered

The New York City Department of Buildings (DOB) recently extended the final training deadline for Local Law 196.

Instead of falling on September 1, 2020, you now have until March 1, 2021, to earn your full SST card.

Between COVID-19 and the complicated transition that DOB has put in effect, you may have lost the plot on exactly what's required of you now. We've got you covered.

Below, you'll find answers to some of the most pressing questions about meeting the new safety training requirements in New York City.

How Do I Get OSHA Certified in NYC?

Just a refresher: OSHA does not recognize or require anything called "OSHA certification." However, getting "OSHA certified" is a common way to say you've completed OSHA 10-hour or 30-hour Outreach training.

In most jurisdictions, you can gain OSHA "certification" by finding a training provider that is "OSHA Authorized" and has a solid reputation. In New York City, there are additional proctoring requirements to consider. More on that, later.

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When is OSHA 30 Required in NYC?

For most of the country, OSHA 30 Construction is reserved for construction personnel with supervisory responsibilities, and OSHA 10 Construction is enough for everyone else.

That's not the case in New York City. In this (as in so many things), NYC DOB regulations complicate things. There's one set of rules for projects that require a Site Safety Plan (SSP) and another set for projects that don't.

OSHA 30 is technically never required for either category. However, certain employers may require OSHA 10 or 30 to ensure that you have safety training basics before non-SSP projects.

And OSHA 30 is a convenient way to meet the training requirements of Local Law 196.

What is Local Law 196 and When Do Its Training Requirements Apply?

Local Law 196 of 2017 changes the safety training requirements for any construction or demolition projects that require an SSP. The statute calls this curriculum Site Safety Training (SST).

SST requirements apply to any job sites that have a designated Construction Superintendent, Site Safety Coordinator, or Site Safety Manager.

Effectively, this means Local Law 196 applies to most construction and demolition sites in the five boroughs. Local Law 196 does NOT apply if you only work on jobs that involve the construction of (or minor alterations to) a 1-, 2-, or 3-family home.

How Many Hours of OSHA Training Do You Need?

If Local Law 196 applies to your job site, you probably need a 40-hour SST card by the deadline.

A few exceptions exist:

  • If you are serving as a Construction Superintendent, Site Safety Coordinator, Site Safety Manager, Concrete Safety Manager, or competent person on the site, you need a 62-hour SST Supervisor card instead. This requirement took effect on December 1, 2019.
  • If you sometimes work on an affected site but you're not a construction worker, you may be exempt. The list of exempt job titles includes site owners, project managers, flag persons, general contractors, and more.

Everyone else – including additional supervisory positions like forepersons – will need a regular SST card in order to work on March 1st of next year.

For now, a Limited SST card (or equivalent OSHA 30 card) is good enough.

How Do You Earn an SST Card if you already have OSHA 30 NYC?

If you have a valid and current OSHA 30 card, you need 10 additional hours of training by March 1st, in the form of 8 hours of Fall Prevention and 2 hours of Drug and Alcohol Awareness.

These courses must be completed with a DOB-approved training provider. Your training provider will issue your SST Card upon completion of all 40 hours.

Are There Other Ways to Earn an SST Card?

Yes – if you hold a valid and current OSHA 10 card, you can earn a total of 40 hours by taking the following with an approved provider:

  • 8-hour Fall Prevention
  • 8-hour Site Safety Manager Refresher/Chapter 33
  • 4-hour Supported Scaffold
  • 2-hour Drug and Alcohol Awareness
  • 4 hours of SST general electives
  • 4 hours of SST specialized electives

Moving forward, anyone new to the construction industry in New York City will need to complete OSHA 10 before starting the job. The additional 30 hours will be due within 6 months of your start date.

Does OSHA 10/30 expire in NYC?

Whether your training is required by law or not, all OSHA 10 or 30 cards in NYC expire 5 years after their issue date. For your OSHA 30 card to count towards your SST requirements, it must have been completed within the last 5 years.

SST cards will have the same renewal schedule. Before your card's 5th anniversary, workers will need to complete 8 hours of renewal training, while SST Supervisors will need 16 hours total.

Everyone will need 4-hour Supported Scaffold Training, as well as a Fall Prevention course that is 4 hours long for workers and 8 hours for supervisors. Supervisors will need additional courses: a 2-hour Toolbox Talks and a 2-hour Pre-Task Safety Meeting.

What Happens if You Violate NYC's Required OSHA Training?

Workers won't be faced with penalties.

Instead, employers are responsible for making sure everyone on their job site has the required amount of training. Site owners, permit holders, or employers can be fined up to $5,000 per untrained employee.

That means responsible employers will send you home if you don't have the right training.

Small business owners can apply for a grant to cover the cost of training.

Is Online OSHA Training Acceptable in NYC?

Yes, as long as the course is what DOB calls "actively proctored."

This can either mean:

  • You complete the online training in a classroom with a proctor present, OR
  • You complete it alone online but
    • You attest that you're the individual receiving the training, without assistance, AND
    • Your participation is monitored at random times to ensure you're present for the entire training

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