How to Comply with DOB's Gas Piping Inspections Requirements

In 2014 and 2015, New York City experienced two deadly gas explosions that prompted lawmakers to pass gas safety legislation in 2016. One explosion in March 2014 brought down two five-story apartment buildings in East Harlem, leaving more than 100 families homeless. And the other explosion occurred in March 2015, reducing an East Village building to rubble, killing two people and injuring four people critically. Inspectors found a flexible hose attached to the gas line that was used to divert gas to apartments upstairs.

As part of the larger package of gas safety regulations, Local Law 152 of 2016 was enacted. Local Law 152 requires that all buildings with gas piping, except R-3 occupancy buildings (which are mostly one- and two-family dwellings), must have their gas piping system inspected at certain intervals by a licensed master plumber (LMP). Although introduced in 2016, the DOB recently released its final rules, which cover inspection frequency, qualifications, scope, and more.

Inspection Due Dates

Beginning Jan. 1, 2020, gas piping systems in all buildings, except for buildings classified in occupancy group R-3, must be inspected by a LMP, or a qualified individual working under the direct and continuing supervision of a LMP, at least once every four years according to the schedule set out in 1 RCNY §103-10.

Inspection due dates for buildings depend on the community district in which the building is located and not by borough. You can get information about your community district at https://communityprofiles.planning.nyc.gov/.

Here are the date ranges for inspections for the four groups of community districts:

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

As of Jan. 1, 2024, the due dates for periodic inspections will be the four-year anniversary of the previous inspection, which will be indicated on the submitted certification. In addition, the inspection can’t be conducted more than 60 days before the due date.

For new buildings approved for occupancy after Dec. 31. 2019, the gas piping inspection must be completed during the 10th year after the DOB issues a Certificate of Occupancy for the building and subsequent inspections must follow the above schedule based on community district.

Submissions Process

The intent of this legislation is to ensure the safety of gas connections within the building. As such, Local Law 152 has a built-in enforcement measure that classifies failure to comply with its reporting requirements as a major violation that may result in penalties.

Within 60 days of the inspection, the owner must submit to DOB a Gas Piping System Periodic Inspection Certification signed and sealed by the licensed master plumber who conducted or supervised the inspection. Currently, there’s no filing fee for the submission of inspection certifications. All certifications must be submitted to the DOB through the DOB’s online certification submission portal. Failure to file an inspection certification before the applicable due date may result in a civil penalty of $10,000. In addition, building owners are required to keep all reports and certifications on file for 10 years and make them available to the DOB upon request.

Corrections. If the inspection certification submitted to the DOB indicates that conditions requiring correction were identified in the inspection report submitted to the owner, the owner must submit to the DOB, within 120 days of the inspection, an inspection certification signed and sealed by the LMP who conducted the inspection, stating that the conditions have been corrected.

If the inspection certification submitted to the DOB indicated that additional time was needed to correct the condition(s) identified in the inspection report, the owner must submit, within 180 days of the inspection, an inspection certification signed and sealed by a LMP stating that all conditions have been corrected. The correction of conditions identified in the inspection report must be performed in compliance with the NYC Construction Codes, including obtaining any required work permits.

Unsafe or Hazardous Conditions. If an inspection reveals any unsafe or hazardous condition(s), the LMP must immediately notify the building owner, the utility providing gas service to the building, and the DOB. The building owner must take immediate action to correct the condition(s) in compliance with the NYC Construction Codes and obtain any required permits.

Building with No Gas Piping

Owners of buildings that don’t contain gas piping must still comply with this law. Owners must submit to the DOB a Gas Piping System Periodic Inspection Certification (https://www1.nyc.gov/assets/buildings/pdf/gps2.pdf), signed and sealed by a registered design professional, stating that such building contains no gas piping. This inspection certification must be submitted once every four years by the end of the inspection date range for the community district in which the building is located.