Everything you want to know about NYC Local Law 152 (AKA LL 152, New York City Periodic Gas Inspections) but were afraid to ask.
We asked for you – so you can keep your gas.
There is no doubt that the City of New York is as diverse in its built environment as it is diverse in every other aspect of what contributes to the unparalleled uniqueness of this place we call home.
As Keep My Gas navigates the process of Local Law 152 we find that every day there are new situations that not only bring up more questions but also new answers to old questions.
The answers below are compiled based on direct communication with Consolidated Edison, National Grid, the NYC Department of Buildings and trusted, qualified third parties.
As more questions arise KeepMyGas will ask them, get a qualified answer and post them here.
In September 2020 NYC Buildings compiled and posted “FAQ: LL152 of 2016 – Inspections of Exposed Gas Piping“. This was in response to questions submitted to NYC Buildings from the Master Plumbers Council of the City of New York.
In December of 2021 the DOB updated this resource. To access that PDF Click HERE.
In May of 2021 The Plumbing Foundation published “Local Law 152 of 2016 – Periodic Inspections of Building Gas Piping FREQUENTLY ASKED QUESTIONS”. To access that PDF Click HERE.
Disclaimer:
All information present throughout this site is relied on by us to the extent of our interpretation and is not in any form intended to be relied on as legal advice by any user of the information.
For legal advice all users are directed to review with their legal counsel.
How many buildings with and without gas piping systems which will require an inspection over the 4 year cycle of 2020 to 2023?
Neither the DOB or the utilities definitively answered this question as there are many variables in the data that could skew the results. KeepMyGas analyzed several samples of data and we estimate 300,000 to 400,000 total buildings with and without gas piping systems will require an inspection over the 4 year cycle of 2020 to 2023.
If a property owner has a building which is in a Community District that is not requiring an inspection for the current year can they have the inspection done in the current year instead of waiting until the year in which that inspection is required?
The DOB indicated that an inspection may only be completed during your listed time frame in order to satisfy the filing requirement in the specified year.
Have the deadlines for the requirement to have an inspection and/or to complete the correction of conditions been extended?
On Thursday 12/17/2020 the NY City Council enacted Int 2151-2020-B that extended the deadline to complete a Local Law 152 inspection in Community Districts – 1, 3, and 10 in all boroughs from 12/31/2020 to 06/30/2021. In addition any buildings that had a Local Law 152 inspection between 09/01/2020 and 12/01/2020 are not required to file are not required to submit the GPS-2: Gas Piping System Periodic Inspection Certification that will certify correction of the conditions until 06/30/2021.
Click HERE to access the legislation page.
Click HERE to access the PDF of the December 2020 DOB Service Notice extending the deadline.
On Thursday 10/21/2021 the NY City Council enacted Int. No. 2259-A that extended the deadline to complete a Local Law 152 inspection in Community Districts – 2, 5, 7, 13, and 18 in all boroughs from 12/31/2021 to 06/30/2022. In addition any buildings that had a Local Law 152 inspection between 09/01/2020 and 12/01/2020 are not required to file are not required to submit the GPS2: Gas Piping System Periodic Inspection Certification that will certify correction of the conditions until 06/30/2021.
Click HERE to access the legislation page.
Click HERE to access the PDF of the Bill.
Click HERE to access the PDF of the December 2021 DOB Service Notice extending the deadline.
On Thursday 10/21/2021 the NY City Council enacted Int. No. 2321-A which stipulates that the DOB may grant additional time to submit a certification, beyond 180 days, if additional time is needed to ameliorate conditions that must be corrected. Finally, this bill provides a 180 day extension to comply with both the inspection and certification requirements of Local Law 152 for any building owner who requests an extension.
In either case you may email the DOB at LL152of16@buildings.nyc.gov to request more time. Include the amount of time you need, the address, the Block and Lot and the Building Information Number BIN of the building. If you would like assistance with this then please feel free to contact us using the website contact page.
Click HERE to access the legislation page.
Click HERE to access the PDF of the Bill.
Click HERE to contact us.
What is the penalty for non compliance of Local Law 152?
In the original law a penalty of $10,000 could be applied for failure to execute an inspection by the deadline for the respective community district-year and/or failure to repair conditions observed at an inspection within 120 to 180 days of the date of the original inspection.
Effective 08/11/2021 the penalty will be reduced to $5,000 as per the DOB Adopted Rule regarding “Certifications of Inspection for Gas Piping Systems”. Click HERE to view the Rule page.
Can an owner have a visual only inspection in advance of an official Local Law 152 inspection to determine if illegal or hazardous issues exist?
An owner may hire a Licensed Master Plumber to perform a visual survey of the gas piping system prior to the Local Law 152 inspection. While on site, a Licensed Master Plumber is required to follow the established gas protocols which were put in place even prior to Local Law 152 and is required to report illegal and/or hazardous conditions. Therefore it is recommended that the complete Local Law 152 inspection be the first and only inspection to avoid the extra cost of what could have been accomplished with just the local Law 152 inspection.
Who is qualified and permitted to conduct a NYC Local Law 152 Inspection?
As per the law, a NYC Licensed Master Plumber (LMP) OR a technician with 5 years experience who is working for an LMP with who has completed an approved 7 hour training and passing of written/practical knowledge check exam.
The Plumbing Foundation City of New York has a flow chart that clearly spells out who is qualified to do what when it comes to gas work and inspections. For that Click HERE.
The law originally indicated that only a Registered Design Professional (RDP); Professional Engineer (PE) or Registered Architect (RA) can complete an inspection on buildings without gas piping to certify that there is no gas piping. May a Licensed Master Plumber (LMP) also perform an inspection on buildings without gas piping to certify that there is no gas piping?
Originally, as per LL152, only a design professional can certify that a building does not have a gas system.
On 10/21/2021 The NY City Council amended LL152 to additionally allow a Licensed Master Plumber (LMP) may also perform an inspection on buildings without gas piping to certify that there is no gas piping.
Click HERE to see the PDF of the amendment.
Click HERE to see the December 30, 2021 DOB Service Notice Follow-Up #5 – Local Law 152 of 2016: Licensed Master Plumbers Allowed to Certify a Building Does Not Contain Gas Piping;
What if there is more than one building, each with its own DOB Building Identification Number (aka BIN), on a single tax lot and there is a mixture of buildings with gas piping and buildings without gas piping?
As per the DOB each building requires a separate inspection and filing of paperwork to be associated with the unique BIN (Building Information Number). This would include any and all out buildings, IE: Garages and/or Sheds.
Originally the buildings with gas would be inspected by a Licensed Master Plumber and the buildings without gas needed to be inspected and certified to not have gas by either a Professional Engineer (PE) or Registered Architect (RA).
On 10/21/2021 The NY City Council amended LL152 to additionally allow a Licensed Master Plumber (LMP) may also perform an inspection on buildings without gas piping to certify that there is no gas piping.
Click HERE to see the PDF of the amendment which also describes the process for buildings that have gas piping but no gas service.
What type of insurance policies should a Local Law 152 inspector have?
A Licensed Master Plumber (LMP) for inspecting buildings with gas and a Professional Engineer (PE) and/or a Registered Architect (RA) for inspecting buildings without gas should have at a minimum a General Liability policy. It is recommended that they would additionally have a Professional Liability Policy also know as Errors and Omissions Insurance. The Professional Liability Policy is the policy that covers the LMP, PE or RA for an error or omission with regard to information provided and performance of the inspection. This can be verified by asking the inspector to show proof of General Liability and Professional Liability insurance by providing you with a Certificate of Insurance (COI) for each policy.
Which portable combustible gas detector is approved for use when performing a Local Law 152 inspection?
The popular device that is used when performing a Local Law 152 inspection is the LMP200. This device can only be purchased by a Licensed Master Plumber (LMP). The serial number of all purchased devices are registered to the license number of the LMP. This device is only available through City Calibration Centers.
This is a list of other approved devices on the New York State Department of Public Service website.
Are individual tenant spaces such as apartments, leased offices and leased retail space inspected?
The DOB interprets the City Council’s intent that the inspection include spaces not subject to tenant control or access restriction. As stipulated in the law, the inspection scope ends at individual tenant space – regardless of whether that tenant space is occupied as an apartment, an office or leased retail space as in a restaurant. Also any gas meters in tenant controlled or access restricted space is not inspected. An example would be residential apartments that have the gas meter in the apartment.
However if the point of entry of the gas service or exposed gas piping or building gas equipment is in a commercial tenant controlled space then access to that area is required to perform a complete inspection. In addition if a commercial building is owner occupied then access to that area is required to perform a complete inspection as well.
Is it permissible for the Licensed Master Plumber (LMP) to correct conditions at the time of the inspection?
The DOB indicated that all work on gas piping is subject to the requirements of the Fuel Gas Code and must be performed in accordance with the requirements of the Administrative Code – including those for qualifications, permits, and inspections. Provided that the corrections are performed in accordance with the code, there is no prohibition that the licensed master plumber cannot identify and also correct conditions while onsite.
Is there paperwork and filing involved and if so, who is responsible?
In the case of a building with gas piping the Licensed Master Plumber (LMP) will complete a GPS-1 and a GPS-2, apply their embossed hard seal and wet signature to the originals and deliver those to the owner within 30 days of the inspection date. While per the law it is the building owner’s responsibility to scan the originals and electronically submit the GPS-2 to the DOB using this PORTAL. The LMP or other authorized building owner representative may, on the building owner’s behalf, electronically submit the GPS-2 to the DOB using this PORTAL.
In the case of a building without gas piping the Registered Design Professional (RDP) or Licensed Master Plumber (LMP) will complete a GPS-2, The RDP or LMP will apply their seal and signature and deliver that to the owner within 30 days of the inspection date. While it is the building owner’s responsibility to scan the originals and electronically submit the GPS-2 to the DOB using this PORTAL. The RDP. LMP or other authorized building owner representative may, on the building owner’s behalf, electronically submit the GPS-2 to the DOB using this PORTAL.
There is no fee for this filing and the upload to the portal of the GPS-2 by the owner or an authorized representative satisfies all filing requirements. There is nothing else for the owner to do except retain the hardcopy or electronic scan for 10 years. Either a hardcopy or an electronic scan is acceptable provided that all the necessary information is included and all the required signatures are provided.
If the original inspection resulted in conditions that required correction is there more paperwork?
This would occur only in a building with gas piping. Another GPS-1 is not required and the correcting Licensed Master Plumber (LMP) will complete a new GPS-2 that certifies the conditions have been corrected, apply their embossed hard seal and wet signature to the original and deliver this to the owner within 30 days of the correction date. It is the building owner’s responsibility to scan the original and electronically submit the new GPS-2 to the DOB using this PORTAL The LMP or other authorized building owner representative may, on the building owner’s behalf, electronically submit the new GPS-2 to the DOB using this PORTAL
There is no fee for this filing and the upload of the new GPS-2 to the portal by the owner or am authorized representative satisfies all filing requirements. There is nothing else for the owner to do except retain the hardcopy or electronic scan for 10 years. Either a hardcopy or an electronic scan is acceptable provided that all the necessary information is included and all the required signatures are provided.
Under what conditions is the Licensed Master Plumber (LMP) required to make an immediate notification and to whom during an inspection?
In the event of any gas leak or immediately hazardous condition, standard notifications requirements apply.
To report an immediate hazard, the LMP is to follow the established protocols which were put in place even prior to Local Law 152 and will contact the building owner/manager, the governing utility for the location and the Plumbing Enforcement Inspections unit at the DOB.
What are the options for a building owner when the building owner does not agree with the items that require repair or replacement that are observed by the Local Law 152 inspector?
Within 30 days of a Local Law 152 inspection, the LMP company that performed the inspection must provide to the building owner a GPS Periodic Inspection Report (GPS-1) showing the results of the inspection and a GPS Periodic Inspection Certification (GPS-2). If a building owner does not agree with the items observed by the Local Law 152 inspector that are listed on the GPS-1 that require repair or replacement then the owner can email the GPS-1 to the DOB dedicated Local Law 152 email of LL152of16@buildings.nyc.gov
DOB has indicated that they will review the findings listed on the GPS-1 on a case by case basis. This may require a follow up visit from the DOB and the utility company. If the DOB finds that items originally indicated do not require correction then the LMP may update the GPS-1 and GPS-2 as appropriate.
Is there a place in the record of the building on the DOB website in either DOB BIS and/or DOB NOW where one can see a record of the GPS-2 submitted to the DOB PORTAL by the Licensed Master Plumber (LMP) or the Registered Design Professional (RDP) for properties that have been inspected?
The DOB indicated that filed GPS-2 forms will not be publicly accessible through a DOB look up function.
Note that in a webinar presented by The Plumbing Foundation City of New York in February of 2021 it was said that as of December 2020 only 8,000+/- GPS-2 forms had been filed.
In a live presentation with the DOB in October of 2021 it was said that to date 57,000+/- GPS-2 forms had been filed and that some of the filed GPS-2 forms could be duplicate filings to correct mistakes and/or to certify corrected conditions. It was also indicated that the DOB updates the internal record of GPS-2 filings every Monday.
To request verification of a Local Law 152 GPS-2 filing, you can email LL152of16@buildings.nyc.gov with the address, block, lot and BIN of the building in question and ask if a GPS-2 form has been filed. Always feel free to CONTACT KeepMyGas if you need a lookup of the block, lot and BIN of a building.
If a jurisdictional piping inspection has already been completed by Consolidated Edison (ConEd) or National Grid do I still need the Local Law 152 inspection?
Consolidated Edison (ConEd) and National Grid will continue to complete their required Service Line Inspections of jurisdictional piping which is the piping and apertures from the buildings point of entry to the outlet of the gas meter
These inspections do not take of the place the Local Law 152 inspection that is performed by a Licensed Master Plumber.
In addition, the GPS-2 form that is part of a Local Law 152 inspection is only filed with NYC Buildings and not with Consolidated Edison (ConEd) or National Grid.
Where can I go to see the most current actions that the NY City Council has taken regarding Local Law 152?
On 12/17/2020 the New York City Council enacted legislation that extended the deadlines for inspection and correction of building gas piping systems in Community Districts 1, 3 and 10 in all 5 Boroughs.
Click HERE to access the KeepMyGas page dedicated to New York City Council proposed and enacted legislation and adopted DOB Rules relevant to Local Law 152.
Also to access the most current DOB Service Updates site and see the list of updates – Click HERE.
Is there an official source of information and education around Local Law 152?
YES THERE IS!
These 3 incredibly informative webinars were hosted by The Plumbing Foundation of the City of NY and moderated by its Executive Director, April McIver in February 2021.
Local Law 152 – Periodic Inspections of Gas Piping Systems is complex. After watching these webinars you will come away with an understanding of not only Local Law 152 but Local Laws 150, 151, 153, 154, 157 and 159. Every plumber, building owner, property manager, registered design professional and real estate attorney should watch all 3.
Guests include representatives from NYC Buildings (DOB), ConEd, National Grid and The Northeast Gas Association.
How NYC Gas Laws Impact Building Owners & Managers
Seminar date: Feb 18, 2021
Click HERE to watch. (If the video has expired, email info@plumbingfoundation.nyc and ask for an extension)
How NYC Gas Laws Impact Professional Engineers
Seminar date: Feb 17, 2021
Click HERE to watch. (If the video has expired, email info@plumbingfoundation.nyc and ask for an extension)
How NYC Gas Laws Impact Licensed Plumbers
Seminar date: Feb 11, 2021
Click HERE to watch. (If the video has expired, email info@plumbingfoundation.nyc and ask for an extension)
Is there an official NYC Buildings (AKA Department of Buildings DOB) web page that has a Step-by-Step Guide to Complying with Local Law 152 of 2016 Periodic Inspections of Gas Piping Systems?
Yes there is!
NYC Buildings, AKA The NYC Department of Buildings (DOB) has set up a special page for homeowners to help them navigate the requirements of LL152 and coach you on the diligence to complete when you hire a Licensed Master Plumber to Inspect Your Building’s Gas Piping System.
You may access that page here: https://www1.nyc.gov/site/buildings/homeowner/local-law-152-of-2016.page
