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Public Testimony

Samuel Ludo of Building Trades Employers Association on SST card verification

New York City Council · Oct 21, 2026 · starts 2:19:19 · 2 min 12 sec

Samuel Ludo, Director of Member Relations for the Building Trades Employers Association representing 1,200 union contractors, praises Local Law 196 but flags operational problems with SST card checks, urging the Council to allow employers to verify cards by ID in advance and to define site-control due diligence; he also raises PVC pipe code discussions and a coming construction superintendent shortage.

Member of the Public - Samuel Ludo

Sorry about that.

Member of the Public - Samuel Ludo

Good morning.

Member of the Public - Samuel Ludo

I'm Samuel Ludo, Director of Member Relations for the Building Trade Employers Association.

Member of the Public - Samuel Ludo

Thank you, Chair Sanchez and Council Member Zhuang for being here and for holding this hearing.

Member of the Public - Samuel Ludo

Our 24 associations represent more than 1,200 union contractors, and we have long worked with the DOB on safety, and we value the council's strong work on keeping New Yorkers and construction workers safe.

Member of the Public - Samuel Ludo

I'd just like to focus on the SST card verification discussion.

Member of the Public - Samuel Ludo

With local law 196,

Member of the Public - Samuel Ludo

Council made New York the first city in the nation to really streamline the safety training tracking for every construction worker.

Member of the Public - Samuel Ludo

There's just a few operational problems.

Member of the Public - Samuel Ludo

I just wanted to flag on the SST card program.

Member of the Public - Samuel Ludo

The only way to accept, to check a card is to tap it with a phone while the worker stands there.

Member of the Public - Samuel Ludo

And so contractors can't really check workers who are dispatched the night before.

Member of the Public - Samuel Ludo

It's very difficult to check the cards the day of because the daily checks don't work at scale.

Member of the Public - Samuel Ludo

And liability falls on subcontractors who often don't really control the gate of the actual construction site.

Member of the Public - Samuel Ludo

And so we urge the council to amend the law and work with the Department of Buildings to let employers check a card by its ID ahead of time and get back only if it's valid or if it's invalid.

Member of the Public - Samuel Ludo

And also to define the due diligence of who really controls the site and to be able to have a plan.

Member of the Public - Samuel Ludo

On how to check cards at scale when you have tens or hundreds of people, you know, on a construction site, this can get very difficult.

Member of the Public - Samuel Ludo

I just also want to flag a few things.

Member of the Public - Samuel Ludo

I know that the mayor's block by block report in there's a lot of discussion about PVC pipes, plastic pipes.

Member of the Public - Samuel Ludo

We think that the codes committee is a great place to do, you know, have these discussions with with experts at.

Member of the Public - Samuel Ludo

And we think that there really needs to be a substantive discussion that and through the experts.

Member of the Public - Samuel Ludo

We also are concerned about the construction superintendent shortage.

Member of the Public - Samuel Ludo

that's coming up.

Member of the Public - Samuel Ludo

And so there needs to be more routes and more ways to support the pipeline of future construction superintendents.

Member of the Public - Samuel Ludo

And we'll submit more things into writing.