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While the Occupational Safety and Health Act sets the minimum requirements for workplace safety, employers must remain mindful that state and local regulations may impose more rigorous standards. For example, as of Jan. 1, 2026, New York City enacted its amended building code requiring construction Site Safety Training (SST) related to mental health and wellness, suicide risk and prevention, and alcohol and substance misuse.
The New York City building code requires most workers and supervisors on certain construction and demolition sites — specifically, those that require a Site Safety Plan or Site Safety Professional — to apply for and obtain an SST card. To qualify, applicants must complete at least 40 hours of training across various mandated subjects. The new law adds mental health training to these requirements.
Additionally, while the law expands the minimum qualifications for an SST card, it also eases the process for card renewal. SST cards may now be renewed up to one year after expiration, provided that the required SST credits are completed within the year prior to the expiration date and that the renewal application is submitted timely.
With the law now in effect, employers in New York City should promptly review their training protocols and ensure that their approved SST providers include mental health courses that meet the city's requirements. This will help avoid potential enforcement actions or civil penalties under the building code. Even for employers outside of New York City, this serves as a reminder to regularly assess whether any state or local regulations impose additional safety policy or training obligations beyond federal law.
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