Attention Philadelphia Contractors: Do You Comply with OSHA Training and Supervision Requirements?

Cohen Seglias Pallas Greenhall & Furman PC
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The City of Philadelphia has issued new code requirements for construction worker safety training. The new rules went into effect on October 1, 2015, and the Department of Licenses and Inspections has announced that strict enforcement will begin on April 1, 2016.

Under the new regulations, all contractors and employees (including subcontractors) performing construction or demolition work in the City of Philadelphia for which permits have been issued are now required to complete OSHA 10 safety training, or an approved equivalent. This requirement applies to all trades, as well as state-registered home improvement contractors. Workers are required to carry written proof establishing that they have completed an OSHA 10 training course while on the job site, and their employers must also maintain on-site proof of completion for each worker. This information must be furnished to the Department of Licenses and Inspections upon request. The OSHA 10 training is only required to be completed once and does not expire.

Additionally, all contractors licensed under Section 9-1004 of the Philadelphia Code must employ at least one supervisory employee who has completed OSHA 30 safety training, or an approved equivalent, within the past 5 years. Construction or demolition of major buildings requires continuous oversight by a site safety manager who has completed an OSHA 30 course. The designated site safety manager must carry an identification card or certificate of completion issued by the provider of the OSHA 30 training course.

The identification of an employee with OSHA 30 training and written proof of completion were required for new contractor license applications made on or after October 1, 2015, and must be submitted with applications for the renewal of contractor licenses set to expire on or after March 31, 2016. Licensed plumbing, electrical, fire suppression, and warm-air contractors are exempt from this requirement.

Effective April 1, 2016, failure to comply with these new regulations will result in the issuance of a violation notice and will subject the contractor to a fine. Repeated or egregious violations may result in the suspension or revocation of the contractor’s license.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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