New Training Requirements About to Go Into Effect In Philadelphia

Posted by: Bill Auxer (wauxer@kaplaw.com)

Beginning April 11, 2016, the Philadelphia Department of Licenses & Inspections (L&I) will be strictly enforcing the Working Training Requirements under Philadelphia Code provisions A-1001.3 through A-1001.5. The Working Training Requirements are summarized as follows:

Philadelphia Dept. of License and Inspections.png• Any workers, regardless of position, directly involved in permit-required construction or demolition work are required to have OSHA – 10 hour training (or equivalent). This requirement applies to all employees and workers of licensed contractors (including plumbing, electrical, fire-suppression and warm-air contractors).

• All contractors licensed under Philadelphia Code, Section 9-1004(4)(c.1) involved in working at a demolition site (as defined in Philadelphia Code, Section 9-1008) are required to employ a minimum of one supervisor who has completed an OSHA approved 30-Hour safety training program (or equivalent) within the past 5 years of the date of application for a contractor's license or renewal. This requirement does not apply to licensed plumbing, electrical, fire suppression contractors and warm-air contractors.

• General Contractors (i.e., contractor listed on the primary building permit) are required to have a Site Safety Manager with OSHA – 30 hour training present on the construction or demolition of a "Major Building". This requirement applies to any alteration to the building façade or any demolition activity which impacts the exterior of the building that is performed at a level above the 3rd story or above 40 feet from grade. A Major Building is defined as any building that is (i) more than 3 stories in height; (ii) more than 40 feet in height; (iii) covers 10,000 square feet or more of lot space, regardless of height. The following projects are not required to have a Site Safety Manager: (a) new construction, structural alteration or demolition of 3 story buildings with rooftop access structures; (b) new construction, structural alteration or demolition of 3 story buildings with an average roof height less than 40 feet (parapet walls shall not be included in determining the height of a building); (c) alteration or demolition limited to the interior of buildings of any height, which alteration or demolition does not impact the exterior of the building, including such fire sprinkler, plumbing, electrical or mechanical work; (d) alterations or demolition of building façades that are neither at or above the 4th floor level nor above 40 feet; and (e) additions to existing structures where the addition is constructed to a height of less than 40 feet above grade, regardless of the height of the existing structure.

Be aware of these pending changes and prepare accordingly.

Original Article


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