Gas piping and meters in a multi family building

Avoid Local Law 152 $10K civil penalty. December 31st deadline approaching

Local Law 152 was introduced in 2016  for the regular inspection of gas piping systems in all buildings except  those in an R-3 occupancy group.  Buildings in all other occupancy groups  that  contain a gas piping system must have a licensed master plumber (LMP) or a non-licensed plumber under the supervision of a LMP.  It is estimated that approximately 280,000 buildings are affected by regulation. 

In affected buildings, gas piping systems must be inspected at least once every four years according to the schedule with  is set out in RCNY 103-10.  The inspection dates range from January 1st thru December 31st of each calendar year.  Buildings to be inspected in each calendar year are determined by the community districts in which the buildings are located. December 31, 2020 is the last day that required buildings in community districts 1, 3, and 10 in all boroughs must be inspected.

The first due dates for the gas piping inspections are as follows:

  • Community Districts 1, 3, and 10 in all boroughs: January 1, 2020 – December 31, 2020
  • Community Districts 2, 5, 7, 13, and 18 in all boroughs: January 1, 2021 – December 31, 2021
  • Community Districts 4, 6, 8, 9, and 16 in all boroughs: January 1, 2022 – December 31, 2022
  • Community Districts 11, 12, 14, 15, and 17 in all boroughs: January 1, 2023 – December 31, 2023

For example, if you initially filed on February  1, 2020, you would have to file again by February  1, 2025. You would not be able to perform the inspection more than 60 days prior to February  1, 2025.

Local Law 152 requires that all exposed gas lines from point of entry of gas piping into a building, including building service meters, up to the individual tenant spaces are to be inspected. Buried piping does not require inspection, nor does piping concealed by suspended ceilings.   Gas piping in Individual tenant spaces is exempt from testing.

Within 30 days of the inspection, the licensed master plumber (LMP) must provide to the building owner a Gas Piping System Periodic Inspection Report (GPS1).

Within 60 days of the inspection, the building owner  must submit to the Department of Buildings (DOB),  a Gas Piping System Periodic Inspection Certification (GPS2) signed and sealed by the LMP who conducted or supervised the inspection. GPS2 submission is to be completed by the Building Owner on the NYC Department of Buildings GPS2 submission portal. No filing fee is associated with the GPS2 submission. 

Owners of buildings without a gas piping system need to file a GPS2 form completed by  a registered design professional, ie, a a registered architected (RA) or professional engineer (PE) stating that your building does not contain a gas piping system. Owners of these buildings  need to follow the same 4-year cycle detailed above for this certification.

If the inspections reveal any unsafe or hazardous conditions, the inspector is required to notify the building owner, the utility company providing gas service to the building, and the Department of Buildings.  The building owner must take immediate action to correct these conditions as required by the NYC Building Code.

Owners who miss their designated cycle deadline  will be hit with a $10,000 civil penalty. 

Building owners  and inspectors must maintain inspection records on file for a minimum of 10 years and make them available to the DOB upon request.

DOB NOW: Safety Boiler

DOB NOW: Safety Boiler Violations

Starting July 22, 2020, the Dept. Of Buildings (DOB) will be launching a new DOB NOW: Safety Violation portal. Under this portal, users can search for open boiler violations on a given property. They will also be able to see amounts due on any penalties on these properties. 
From that date forward, it will be mandatory to make payments online for “Failure to File” annual boiler inspection reports. 
The procedure to make payments for boiler violation penalties on DOB NOW: Safety is below: 

• Use an eFiling account to log in at If you need to create an eFiling account, click on the following link.
• Select DOB NOW: Safety and then the Violations portal.
• From the dashboard select +Violations Payments.
• Search by Violation Number, Device Number, Address or BIN. When a device number, address or BIN is entered, all active violations will appear along with the amount of the civil penalty due for each violation.
• Select the violation for which you want to submit payment. Only one violation can be paid per application.
• Save the application to proceed. The respondent information on the request is populated from the information found in the eFiling account that was used to log into DOB NOW.
• Complete the Statements & Signature section and Save the application again.
• The last step is to select Proceed to Pay to enter the payment in the CityPay portal.
Violation Dismissal

Boiler violation payments made in (DOB NOW: Safety Boiler Violations) Safety by credit card for boiler violations for issued for the years prior to and including 2016 will be processed immediately and the violation(s)status will change to dismissed in the Buildings Information System (BIS). Payments made by eCheck will take up to 10 days to be processed. An email notification will be sent when the payment has processed and the violation has been dismissed.

Boiler violations issued in 2017 or later require an annual boiler inspection report to be in accepted status in DOB NOW: Safety. Once payment has been made, the violation will not be dismissed unless an accepted inspection report has been submitted. If an inspection report is submitted, an email notification will be sent and the violation will be updated to dismissed status in BIS within 24 hours.

COVID-19 Violations

Avoid COVID-19 state and city violations during Phase 1 restart. Starting July 8, 2020, Department of Buildings (DOB) inspectors will be issuing covid-19 related violations. Inspectors will look for job sites that are not in compliance with Covid-19 state/city Phase 1 restart requirements. 
If any violations are found, penalties of $5000.00 will be doled out. The site may be issued a Stop Work Order. Penalties for continued non-compliance can be as high as $10K for each offense. 

Job sites will be issued Stop Work Orders if they are without a Safety Plan or a State affirmation conspicuously posted, or without a proper hand washing station.
DOB inspectors will look for compliance with the following: 

– Compliance with social distancing protocols
– Appropriate face coverings worn by all site personnel and visitors
– Readily available hand hygiene stations. These stations must have soap, running water and paper towels. Alcohol based hand sanitizers in lieu of hygiene stations are acceptable.
– Visibly posted Covid-19 signage to remind all personnel to follow the proper hygiene and social distancing rules. Signs that show appropriate use of PPE and cleaning and disinfecting protocol.
– Properly completed and updated cleaning and disinfection logs
– Capacity signage at confined spaces, must be posted within the cab and at each landing.
– A communication plan for employees, visitors, and clients on site.
– Logs that are completed and updated. These logs must list each person on the site to ensure effective contact tracing.

Local Law 87

Local Law 87 (LL87)

Local Law 87 (LL87)

Do you know your number? It could be your year of the EER

No matter what industry you are in, there is a push for energy efficiency. It’s no different when it comes to building maintenance, even in a city as old as New York. A few months ago we mentioned how New York City is leading the nation when it comes to energy efficiency. One of the things helping this positive change is the Department of Buildings. The DOB has a long list of Local Laws, and among them is Local Law 87 of 2009 (LL87).
So let’s say you’re a building owner. What is Local Law 87 and what does it mean to you?

As part of the Greener, Greater Buildings Plan (GGBP), LL87 requires large building owners to submit an Energy Efficiency Report (EER) every ten years. Covered buildings, those that are required to comply with LL87, are those over 50,000 square feet, and single lots with two or more buildings larger than 100,000 square feet.

If you own a big building that falls within these categories, you should expect to file an EER once a decade and pay close attention to your tax block number. The year in which you have to comply with LL87 is determined by the last digit of that tax block number. For example, if the number ends in “7” you have until December 31st, 2017 (and once every ten years after that) to file the EER. If that number is “8” then it’s 2018, and so on and so forth.

Okay, so you have until December 31st to file your EER. What exactly is that?

The main components of the EER are the Data Collection Tools, and the Professional Certification forms, EERC1 and EERC2. The former is for the energy audit component, the latter for retro-commissioning. The energy audit is a survey and analysis of energy use in a building to identify ways to reduce energy consumption without compromising normal operations. Retro-commissioning is the process of ensuring that energy systems are correctly installed and functional.

The Professional Certification Forms are signed by the Registered Design Professional (RDP) or Approved Agent who conducts the energy audit and retro-commissioning, as well as by you, building’s owner. The forms require the seal of the RDP and a signed and dated statement from you including basic information and indicating owner type.
The accompanying Data Collection Tools for the EER can be done by you without the RDP. With two separate tools for the energy audit and retro-commissioning, they both contain similar fields for information on the building and the team conducting the survey, and more specific fields for each respective survey. Together all these forms complete the EER, which can then be e-filed with the Department of Buildings. Once the DOB receives the EER, an email will be sent to you with instructions on how to pay the $375 filing fee.

Now, there are exemptions when it comes to LL87. One to three family dwellings that are not condominiums, or are condos of three stories or less do not have to comply. Covered buildings may be exempt from a either the energy audit or retro-commissioning if certain criteria is met.
At this point you are probably relieved you only have to do this once every ten years. While it seems like a lot, it isn’t anything S&M Expediting can’t handle. Let’s talk about getting your EER filed or help you take action in any of these following ways.

If you are not exempt from filing an EER and are unable to meet the December 31st deadline, you can file for a deferral or extension.
A ten year deferral may be an option for you if the base building systems comply with the NYC Energy Conservation Code, and if the building is less than ten years old or has undergone a substantial rehabilitation in the ten years prior to the year the EER is due. To file for a deferral, you use the EER1 Application and file it with the DOB. If you can’t meet the deadline due to financial hardship of the building or are unable to meet it despite documented efforts, you can file an EER2 by October 1st of the due year, and every October afterward for which an extension is requested. Accompanying the EER2 is a fee of $155 for the extension.

In the event of the DOB requests you to amend a submitted EER, you will have to submit a revised EER, indicating on the EERC1 and EERC2 that the filing is an amendment. You would also be subject to an amendment fee of $145.

Rather than run the risk of needing to pay for an amendment for a misfiled EER, or even worse, face a Class 2 violation and a penalty of $3000 for the first year (or $5000 for subsequent years) for not filing at all, let S&M save you the headache and get it done for you. Reach out to us and have your EER done by expediters who understand the forms and do the hard work for you.

Contractor Insurance Update

Insurance update (Service Update)

Insurance Update
Insurance Update

Attention Contractors, Plumbers, Fire Suppression Contractors and Electricians. Insurance Update change.

Beginning on January 2, 2018, the Department of Buildings Licensing unit will no longer accept insurance submission at the counter.  All insurance updates and new tracking number issuance will be done electronically.

S&M Expediting can still provide this assistance when required.