What Local Law 196 is
Local Law 196 of 2017 amended the NYC Administrative Code to require Site Safety Training (SST) for most construction workers and supervisors on NYC construction sites. The law's stated goal is to reduce construction injuries and fatalities by ensuring that everyone on a NYC site has documented safety training.
The enabling provisions sit in the NYC Administrative Code, Title 28. The law also authorized DOB to adopt implementing rules through the Rules of the City of New York.
LL196 is enforced by NYC DOB. It applies in addition to OSHA training and any project-specific safety requirements. SST is documented through a wallet-sized card (the "SST card") that the worker or supervisor physically carries on site.
The law has been in steady operation since 2017 with phased enforcement and minor amendments. As of 2026, SST is a standard daily reality on NYC construction sites: card check at entry, card audit during DOB walks, and renewal as a routine part of every credentialed worker's career.
Card tiers: 10, 30, 40, 62, 100
LL196 recognizes several SST tiers based on the role:
| Tier | Hours | For |
|---|---|---|
| OSHA-10 + SST 10 | ~10 hrs SST | Limited-scope worker categories (varies) |
| 30-hour | 30 hrs SST | Some general worker categories |
| 40-hour SST | 40 hrs (cumulative) | Standard NYC construction worker |
| 62-hour SST Supervisor | 62 hrs | Supervisors, including SSM/SSC/CSM/FSM |
| 100-hour SST | 100 hrs | Some specialized supervisor / instructor roles |
The two most-cited tiers in daily practice:
- 40-hour SST card (worker). Required of construction workers on covered projects. Composed of OSHA-30 plus additional NYC-specific modules (fall protection, scaffold, confined space, etc.).
- 62-hour SST Supervisor card. Required of construction supervisors on covered projects. Includes the 40-hour worker content plus supervisor-specific modules.
Every DOB-licensed Site Safety Manager, Site Safety Coordinator, Concrete Safety Manager, and FDNY Fire Safety Manager working on a NYC LL196-covered project must hold a 62-hour SST Supervisor card in addition to their license.
Which projects are covered
LL196 applies to "covered projects," generally any NYC construction project that requires a Construction Superintendent, Site Safety Coordinator, or Site Safety Manager under Chapter 33. In practice this means:
- Most Major Buildings (10+ stories or 100+ ft)
- Many smaller projects with construction superintendent requirements
- Demolition projects of qualifying scope
Smaller alteration projects without a Construction Superintendent requirement may not be LL196-covered. Confirm against your DOB filing if you're unsure.
Renewal cadence and continuing education
SST cards are not "earn-once, hold-forever" credentials. They have a structured renewal cycle:
- Cards are valid for 5 years from the date of issue.
- During each year of the card, the holder must complete a required number of continuing-education (CE) hours, typically 8 hours/year for both 40-hour worker and 62-hour supervisor tiers.
- At the 5-year mark, the cardholder renews by completing additional refresher hours and a renewal application.
Missing a CE deadline can put a card into "delinquent" status, which means the holder cannot legally work on a covered project until cured.
Skilled Safety Management pays for and tracks the SST CE hours of every employee. Missing a renewal is not an option.
How to verify a card on site
Site superintendents and SSMs are required to verify SST cards at site entry. The process:
- Worker presents physical wallet-sized SST card.
- Verifier checks the cardholder's name and photo against ID.
- Verifier checks the card type (40 / 62 / etc.) is appropriate for the role.
- Verifier checks the expiration date.
- Verification is logged in the site's SST verification log.
A site without a current SST verification log on hand is a routine DOB violation. The log is one of the first things an inspector asks for during a Chapter 33 walk.
LL196 also allows for digital verification via the SST card's machine-readable elements. In-person physical verification remains the standard.
Penalties for non-compliance
LL196 imposes liability across multiple parties simultaneously. This is by design. The law's drafters specifically wanted the penalty exposure distributed so that no single party could transfer their responsibility onto another.
Parties subject to ECB violations:
- Worker. Performing work without a valid SST card on a covered project.
- Supervisor. Allowing a worker without a valid card to continue working, or working in a supervisory capacity without a current 62-hour Supervisor card.
- Construction Superintendent / SSM / SSC. Failing to verify cards on site entry or failing to maintain a current SST verification log.
- General Contractor / Site Owner. Permitting or allowing un-carded workers to be on the site.
ECB violations for LL196 non-compliance are classified as Class 2 violations.
Class 2 violations carry civil penalties and must be corrected promptly. Repeat violations within a project or within a GC's history carry higher penalties and can put the project on a DOB elevated-scrutiny list that produces more frequent unscheduled inspections.
The practical math: the fine for a single uncarded worker is far smaller than a single stop work order day. The incentive to maintain the log and verify on entry is economic, not just legal.
How to get a card
Workers obtain SST cards by completing approved coursework at a DOB-approved training provider. The standard pathway:
- OSHA-30 Construction. Federal 30-hour training, prerequisite for 40-hour SST in most cases.
- NYC-specific modules. Fall protection, scaffold, ladders, confined space, supported scaffold, suspended scaffold, etc.
- Application submission. Through the DOB-approved provider, who validates documentation.
- Card issuance. Wallet-size card mailed to the holder.
Total cost varies by training provider but is non-trivial. SSM pays for SST courses for every employee.
For supervisors, the same pathway plus 22 additional hours of supervisor-specific content (toolbox talk leadership, accident investigation, supervisory legal responsibilities) brings the total to 62 hours.
Bottom line
LL196 is a standard daily reality on NYC construction sites. Every worker on a covered project carries a 40-hour SST card. Every supervisor carries a 62-hour. Renewals run on a 5-year cycle with annual CE hours. Verification on entry is mandatory. Penalties land on every party that allows an un-carded worker on site.
Skilled Safety Management treats LL196 as a hiring filter. Every credentialed manager we hire arrives with a current 62-hour Supervisor card or completes one before deployment. License and SST renewals are paid by SSM.
Frequently asked questions
Does an out-of-state OSHA-30 count toward SST?
How long does it take to get an SST card?
Are SST cards transferable between employers?
What if I lose my card?
Do union members have a different SST pathway?
Are out-of-town workers exempt?
Can a 40-hour card holder act as a supervisor?
Where do I check if a provider is SST-approved?
Related resources
Working on a NYC project? Skilled Safety Management staffs licensed Site Safety Managers, Coordinators, Concrete Safety Managers, and FDNY Fire Safety Managers throughout the five boroughs. Send your project details through our contact form or call (212) 498-8863 for a fixed-fee proposal in 24 hours.