New York City Gas Piping System Inspection and Certification Deadlines Approaching

November 24, 2020

While many believe that 2020 can’t end fast enough, there is an important upcoming deadline before the Times Square ball drop for owners of buildings, except one- or two-family homes, in certain Community Districts that, if missed, could lead to a significant civil penalty.

What is Required to be Inspected and Who is Subject to the Inspection Requirement?

Pursuant to a local law passed in 2016 (a lifetime ago in these challenging COVID times), gas piping systems in all buildings except those classified in occupancy group R-3 must be inspected by a Licensed Master Plumber (LMP) or a qualified individual working under an LMP’s direct and continuing supervision at least once every four years pursuant to a schedule set forth in the Rules of the City of New York (1 RCNY Section 103-10).

When are the Inspection and Report Due?

If you own a building subject to this law located in Community Districts 1, 3 and 10 in any of the five boroughs, then an LMP must conduct the inspection and report the findings by December 31, 2020 (and no later than December 31 within every fourth calendar year thereafter).

For buildings in Community Districts 2, 5, 7, 13 and 18, the inspection and report are due by December 31, 2021 (and, as above, within four years thereafter).

For buildings in Community Districts 4, 6, 8, 9 and 16, the inspection and report are due by December 31, 2022 (and, as above, within four years thereafter).

For buildings in Community District 11, 12, 14, 15 and 17, congratulations – you win the prize for furthest deadline for the inspection and report – December 31, 2023 (and, you guessed it, within four years thereafter).

If you are new to town and don’t know what Community District your building is in, then welcome. New York City is a fun, vibrant place with plenty of regulations to keep you on your toes. You can identify your Community District at the link here.

What do the Inspection and Report Cover?

If the building contains a gas piping system, the LMP inspects the exposed gas piping in non-tenant spaces and provides a Gas Piping System Periodic Inspection Report (GPS1) to the building owner within 30 days of the inspection. The owner then submits to the Department of Buildings (DOB) within 60 days of the inspection and no later than the appropriate December 31 deadline set forth above the Gas Piping System Periodic Inspection Certification (GPS2) signed and sealed by the LMP certifying whether any conditions identified to the building owner in the GPS1 have been corrected or if additional time is needed to correct such conditions (up to 180 days from the original inspection). The GPS2 is to be submitted through the DOB online portal.

What if my Building Does not Contain Gas Piping?

New York City still has a form for you. A registered design professional must sign and seal a GPS2 form certifying that the building does not contain gas piping. The form should be submitted in accordance with the schedule set forth above.

What is the Penalty for a Failure to Comply with this Law?

DOB notes that the failure to file the appropriate forms by the corresponding deadlines will result in a civil penalty of $10,000.

Where can I find more Information About this Law and what I Should Do?

You may review the guidance posted by DOB on its website or contact the Compliance and Administrative Law practice at Tarter Krinsky & Drogin LLP.

Attorney Advertising. The information contained in this Legal Alert provides a general summary of the topics covered and is not intended to be and should not be relied upon as legal advice. You should consult with your legal counsel for advice and before making legal, business or other decisions.

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Kilduff, Patrick J. Partner and Chair of Compliance and Administrative Law Practice and Outdoor Advertising Practice Partner and Chair of Compliance and Administrative Law Practice and Outdoor Advertising Practice 212.216.8019 VCard

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