NYC Site Safety Training in 2026: LL196, Card Renewals, and What Workers Need to Stay on Site

At an NYC site that requires a Construction Superintendent, Site Safety Coordinator, or Site Safety Manager, covered workers need an active 40-hour SST card. Designated safety professionals and competent persons need a 62-hour Supervisor SST card. If a card is expired, keep that person off covered work until it is renewed. OSHA 10 or OSHA 30 alone is not the SST credential.

Why was the worker turned away?

Check the credential in NYCDOB Training Connect, not only the image a subcontractor texted to the superintendent.

Confirm:

1. The card belongs to the worker.
2. It was issued through an approved provider in Training Connect.
3. It is active on the date of work.
4. It is the correct worker or Supervisor card for the person's designated role.
5. The site is subject to Local Law 196.

Since February 1, 2023, accepted SST cards must be issued through Training Connect. The permit holder must ensure compliance and keep the required onsite log for covered workers.

Example: two people in a six-person crew have expired cards

A concrete subcontractor sends six workers for Monday mobilization. The foreperson provides a roster on Friday, but two SST cards expired the prior month.

The one-year renewal window does not authorize those workers to enter covered work. The subcontractor must renew the cards through an approved provider or replace the workers with people who hold active credentials. The GC should update the roster before the gate opens, not resolve it during the morning briefing.

What does Local Law 196 require?

Local Law 196 of 2017 established the Site Safety Training program. Full compliance took effect March 1, 2021.

The requirement applies at sites that must designate a Construction Superintendent, Site Safety Coordinator, or Site Safety Manager.

Job title alone does not settle the answer. A project manager who starts performing covered work can become subject to the worker requirement. A foreperson does not automatically need the Supervisor card unless designated in a role that requires it.

Company size and subcontractor status do not create an exemption.

What is the difference between LL196, OSHA 10 or 30, and an SST card?

These terms are often used as if they mean the same thing. They do not.

OSHA's Outreach FAQ states that OSHA student cards do not expire and that Outreach courses do not replace hazard-specific training required by OSHA standards.

NYC uses OSHA 10 or 30 as part of certain paths to an SST card. NYC generally requires credited OSHA coursework to fall within the specified five-year window or be addressed through an approved refresher path. The resulting SST card expires five years after issuance.

What did Local Law 10 of 2026 change?

Local Law 10 of 2026 took effect May 3, 2026. It updated the SST program. It did not replace Local Law 196.

The law:

1. Added two training credits covering mental health and wellness, suicide risk and prevention, and alcohol and substance misuse to specified new-card paths.
2. Allowed a DOB-approved construction and demolition site-safety course of at least 40 hours as an alternative to OSHA 30 for specified worker and Supervisor paths.
3. Allowed eligible worker and Supervisor SST cards to be renewed up to one year after expiration.
4. Kept the five-year SST card term and the 40-hour worker and 62-hour Supervisor totals.

DOB's April 23, 2026 service notice created the transition to its named 2-Hour Mental Health Awareness course.

As of July 25:

• Either the Drug and Alcohol Awareness course or Mental Health Awareness course could count for the affected new-card path.
• DOB had announced that only Mental Health Awareness would be accepted after August 1, 2026.
• Active cardholders did not need to take the new course immediately just because the rule changed.

Do not confuse Local Law 10 of 2026 with the older facade-inspection law commonly called Local Law 10. In this article, LL10 means the 2026 SST amendment.

How do SST card renewals work now?

Check the expiration date first

• A card that expired before May 3, 2026 does not receive the new grace period.
• A worker or Supervisor card expiring on or after May 3, 2026 can be renewed through the first anniversary of expiration.
• The card remains expired during that period. It cannot be used for covered site access.

Complete the required refresher training

Worker renewal requires eight DOB-specified credits. Supervisor renewal requires 16.

As of July 25, DOB listed these paths:

Use DOB's current SST Card Information before enrolling. Course options can change.

Renew through the provider

The worker completes training through a DOB-registered course provider authorized to issue SST cards. The provider submits the renewed card through Training Connect. This is not a DOB NOW: Build transaction.

The GC should verify the renewed record in Training Connect before putting the worker back on covered work.

What should the GC verify before mobilization?

Use this checklist for every subcontractor crew:

• Site applicability under Local Law 196 is documented.
• Worker roster is received before the start date.
• Each covered worker has an active 40-hour SST card.
• Each designated safety professional or competent person has an active 62-hour Supervisor card.
• Card number, worker name, and expiration are verified in Training Connect.
• Renewal dates are entered in the project lookahead.
• The subcontractor knows who replaces a worker whose card lapses.
• The permit holder's onsite training log is ready and current.
• Crew changes must be reported before the replacement worker arrives.

For a broader pre-start sequence, use the mobilization compliance checklist.

What mistakes cause avoidable site delays?

• Accepting OSHA 30 as a substitute for an SST card
• Treating the one-year renewal window as permission to work
• Checking only the printed expiration date and not Training Connect
• Assuming every foreperson needs a Supervisor card
• Assuming office staff never need a card, even when they perform covered work
• Letting the subcontractor change the roster at the gate
• Tracking card expiration separately from COIs and mobilization status

If the safety issue is holding a permit rather than a worker, use the NYC permit delay guide. For permit and inspection workflows, see the DOB NOW guide.

How to prevent this from happening again

Most teams prevent gate delays by making SST verification part of subcontractor mobilization, not a check performed on the worker's first morning.

Keep the approved roster, active card status, renewal date, COI clearance, and site start date in one readiness process. Require subcontractors to submit roster changes before the replacement worker travels to site.

Policyhold is one way to manage the vendor compliance portion of that workflow.

What should you check next?

SST is one part of site readiness. Work through the mobilization compliance checklist for construction sites before releasing the subcontractor to field supervision.