Hon. Jumaane Williams

Chair, Housing and Buildings Committee

New York City Council

250 Broadway, Suite 1808

New York, NY 10007

July 21, 2017

Dear Chair Williams,

The Construction Safety Advisory Committee of New York (CSACNY) commends the diligent work of the New York City Council and its policy staff in drafting amended Intro. 1447-A, which seeks to combat the recent rise in preventable construction-related fatalities and accidents. CSACNY’s leadership and members include over 300 licensed, experienced site safety professionals who have served as former officials from the New York City Department of Buildings, FDNY, New York City Transit, School Construction Authority, as Safety Personnel for both Union and Open Shop Contractors and safety consultants for building owners and developers. CSACNY’s mission is to advocate for safety on and around New York City construction sites. We believe that the current epidemic of construction fatalities is unacceptable and cannot be allowed to continue. We therefore commend and applaud the Council for recognizing the issue and taking pro-active steps to stop this alarming trend.  

As a coalition of site safety professionals who work to keep workers and the public safe every day, we recognize the importance of this legislation. After careful review, we are submitting a comprehensive set of suggested amendments which will better address the problems we run into on our job sites all too often.  As such, we respectfully request to meet with you and your staff to discuss the changes we propose below.

The intent of Intro. 1447-A is to improve the training and safety of all New York construction workers, but the approach as currently written is overly complex, unenforceable and lacks the comprehensive approach needed to ensure that all workers – whether union or non-union – receive the instruction they need to protect themselves and others. Based on our decades of experience, CSACNY recommends a simplified approach be adopted in order to ensure any new law is (1) seamlessly adopted by the industry, (2) easy for workers to understand and comply with, and (3) effective in dramatically reducing New York construction injuries and deaths through improved training, effective oversight by the DOB and the elimination of fraudulent training and licenses.

CSACNY recommends the City Council require the levels of safety training on the next page for every construction worker and supervisor working on a New York City job site, excluding 1-, 2-, and 3-family homes. Workers and supervisors should be required to attend these trainings in-person through OSHA, DOB & IACET approved training providers, or under an Approved NYS Apprentice Program, in order to reduce the issuance of fraudulent ID cards and fraudulent training, which put all New Yorkers at risk. We recommend that continuing education courses be required every four years, which is a standard across industries for continuing education to ensure provisions are easily, quickly and effectively adopted by workers.

 

Click here to download the Recommended Construction Worker Training table

 

All of the above training programs are established, recognized, have independent agency approval, and cover the subject matter outlined in the most recent version of Intro 1447-A.

 

Thank you for your commitment to improving the safety of New York construction workers and the public. We look forward to further discussing our training recommendations, which are a simplified approach to better equipping our workers with the tools and knowledge they need to stay safe while building this great city.

We look forward to working with you as the industry experts on construction safety training and best practices. Please contact Jim Quent at JQuent@StatewidePublicAffairs.com or 917-797-6032 with questions and/or follow up.

Sincerely,