City Council passed its construction safety bill on September 27th, 2017. The bill makes additions to the Administrative and Building Codes to mandate worker safety training, creates a task force and imposes penalties for failure to comply.
Newly created Building Code Section 3321 presents requirements for Site Safety Training (SST). The rollout for worker Site Safety Training comes in three phases, referred to as “compliance dates.”
First Compliance Date: March 1, 2018
Second Compliance Date: December 1, 2018 or, if determined by the DOB, a later date, but no later than June 1, 2019.
Full Compliance Date: Five months after the second compliance date, or, if determined by the DOB, a later date, but no later than September 1, 2020.
Building Code Section 3321
Wherever a job requires a construction superintendent, site safety manager or site safety coordinator, the permit holder of the job is required by BC Section 3321 to provide the following:
Between the 1st and 2nd Compliance Dates, permit holders must ensure that all workers (construction, demolition, subcontractors, etc) have completed an OSHA 10-hour and 30-hour course or a 100-hour training program.
Between the 2nd and Full Compliance Dates, permit holders must ensure that each worker has an SST card—full, limited or temporary. Site safety managers, site safety coordinators, construction superintendents, concrete safety managers and competent persons must have SST supervisor cards during this period and beyond.
After the Full Compliance Date, permit holders must ensure each worker has a temporary or full SST card.
Site Safety Training Cards
There are also several levels of Site Safety Training cards. They are:
Temporary SST cards: Card issued to a new worker that has complete an OSHA-10 class. Valid for six months and not renewable.
Limited SST cards: Workers must complete one of the following for work occurring before the Full Compliance Date. These cards all expire before the Full Compliance Date.
- An OSHA-10 class along with 20 additional SST credits, which must include 8 credits related to falling workers and objects.
- An OSHA-30 class
- A 100-hour training program.
Full SST Card: Full SST cards are valid for 5 years and are renewable. Workers must complete one of the following:
- An OSHA-10 class, an additional 30-45 OSHA credits determined by the department, which must include 8 credits related to falling workers and objects.
- And OSHA-30 class, an additional 10-25 OSHA credits determined by the department, which must include 8 credits related to falling workers and objects.
- A 100-hour training program.
It’s the responsibility of building owners, permit holders and persons who hired workers to ensure all workers have the proper SST prior to commencing work. Those parties will receive violations for each respective worker without proper SST. Workers do not receive violations.
It’s the responsibility of building owners, permit holders and persons who hired workers to ensure all workers have the proper SST prior to commencing work.
Upon violation, owners and permit holders must ensure workers receive proper SST at no cost to the worker. Furthermore, workers must remain employed, paid up to 40 hours per week, under the same terms for 60 days or until training or work is complete, whichever is earlier.
Permit holders can also receive violations for not completing their daily log complete with SST cards for all workers. Permit holders who violate BC 3321 a second time will receive an unannounced inspection at their site at least once every three months until two consecutive visits report no violations. Owners, permit holders, and workers who violate BC 3321 a second time also receive unannounced inspections of every active job site they are working.
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