The 2022 Construction Codes featured guidelines for site safety at major buildings, including required roles for specific types of work. Here’s a chart laying out which roles are required at major buildings.

Additionally, beginning November 7th:

an individual who is designated as the primary construction superintendent on a major building job may not serve as the primary construction superintendent for any other job. Construction superintendents who are designated on both major building jobs and non-major building jobs can request to be withdrawn from the major job or from the other non-major building jobs; the permit applicant can renew the permit with change to issue the permit with a different construction superintendent; or a request can be submitted to release the site safety requirements from the job, which will also release the construction superintendent.

Per the DOB’s Service Notice, “The site safety requirements in the 2022 Construction Codes will apply to major building site safety projects that have not submitted site safety plans to the Department of Buildings in DOB NOW before November 7, 2022.”

As a reminder, major buildings include existing or proposed building 10 or more stories or 125 feet or more in height, or an existing or proposed building with a building footprint of 100,000 square feet or more regardless of height.

Proposed Changes

While the above changes are already in effect, the DOB has also proposed changes regarding the roles of Site Safety Managers (SSM), Site Safety Coordinators (SSC), Construction Superintendents (CS) and Concrete Safety Managers (CSM).

We’ve outlined the major three changes using abbreviations below:

• Proposed amendments will allow CSMs to hold CS registrations, in addition to SSM and SSC registrations.
• They will also prohibit SSM and SSC roles from “being designated, acting, or serving as the primary or alternate CS at the job for which they are the primary or alternate SSM or SSC or for any other job.”
• Finally, the proposed rules will “prohibit a CSM from simultaneously serving as an SSM, an SSC, or CS on the same job for which they are serving as the CSM.”

Based on the introduction of the proposed rules, these changes aim for two goals: create a process to allow CSMs to register as Construction Superintendents, and “make clear that the duties of a Construction Superintendent are too numerous for a Construction Superintendent to simultaneously serve in other Building Code mandated safety oversight roles at a construction job.” Basically, while people may be able to hold multiple registrations, they may not simultaneously perform certain safety oversight roles at a job.

The hearing for these proposed rules was on October 31, 2022, and changes may occur going forward. We’ll post an update when the proposed rules are adopted and finalized. In the meantime, you can read the full version of the proposed rules here.

Per a recent Service Notice, a “Technical Report (TR1) – Final” will no longer be required for the following work types:

• Sidewalk Shed (SH)
• Construction Fence (FN)
• Supported Scaffold (SS)
• Protection and Mechanical Means (PMM)

Per the DOB, “Submission of a notification of removal will sign off the permit and complete the filing.” Additionally, “A TR Final will no longer appear on new job filings and the TR Final has been removed from existing filings that are not in Letter of Completion status.”

For detailed steps on how to sign off on the above work types, check out the Service Notice.

While this isn’t a change, it’s a great improvement in transparency!

The DOB recently published a guide list of when buildings will receive partial or full Stop Work Orders (SWO), and why. You can view the full list here.

In addition to listing general reasons, the guide also cites the sections of law for each potential SWO issue. While many reasons seem obvious (serious injury or fatality, partial/full site collapse, equipment operated in an unsafe manner, etc.) some are more administrative. For example, Stop Work Orders may be issued for failure to have an onsite Site Safety Log, inadequate or missing construction documents, or failing to have said documents onsite.

If you’re undergoing construction – even if it’s under an LAA – check out this guide and ensure your team is avoiding any of these scenarios.

Bottom line with construction changes? Stay in communication with your responsible roles & onsite staff — ensure your experts are aware of DOB updates, and know their plan to stay compliant.