Public comments for: Construction Site Safety Training Rules

Comments

Comment:
Please see attached testimony on behalf of the New York Electrical Contractors Association.
Agency: DOB
Comment:
On behalf of the New York Electrical Contractors Association.
Agency: DOB
Comment:
Please see the attached testimony on behalf of the New York Electrical Contractors Association.
Agency: DOB
Comment:
Please see attached comment
Agency: DOB
Comment:
See attached comment
Agency: DOB
Comment:
My name is Robert McCormick. I am currently the Safety Director of the Joint Industry Board of the Electrical Industry since 1995. We have a workforce of approximately 12,000 construction members. As I have reviewed the requirements this task force is considering and the timeline for implementation I am dismayed that it may not be possible to provide all this newly required training on time. For example; even if we allow for perfect attendance for a 4-hour supported scaffolding class for 40 members; that would require 300 different classes to be held. While we have OSHA-qualified instructors – we were unable to train our members in supported scaffolding because the DOB didn’t allow for any new training entities – so we had to place our training needs in the hands of NYC Technical College at great cost and inconvenience to our efforts; and we have to put our training needs in the hands of others. Similarly, we would have a difficult time to provide a fall protection class to the specifications and time constraints required for our entire industry. These are long term goals – not something that cannot be done overnight. I would like to see an advisory group put together to work with these larger non-profit training entities like ours, - like the unions and community groups - and look at the task of the training requirements of that particular group and come up with reasonable cohesive plan and schedule with incremental benchmarks to accomplish the goals. The Joint Industry Board has developed a Learning Management System to assist us in record keeping and providing online safety training to our members with a voice-recognition system to ensure those getting credit for taking an online class are actually the ones taking the class. As online systems can train any number of people at the same time I would like to suggest that an OSHA 10 or 30-Hour Course for Construction current within 3 to 4 years can defer the fall protection requirement of training for a period of up to 3 to 4 years from the date of the OSHA Course. Fall protection is one of the main focus points of the OSHA Course. Finally, regarding the additional training required of supervision beyond the OSHA 30-Hour training; in most cases our members in supervision have gone through a NYS DOL-approved registered apprentice training program; have completed an OSHA 30, Lockout/Tagout, NFPA 70E, GHS and Silica Awareness. I would like to suggest that the requirements other than those related to fall protection and scaffolding can be substituted by relevant safety training related to their particular trade; such as those I listed above relevant to the electrical construction trade. Our members are highly skilled and highly-trained. Those skills were acquired over years of training. None of it was done as a flash in a pan. It took time. Please allow us the adequate time to attain these goals.
Agency: DOB