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LL152 of 2016: Inspections of Exposed Gas Piping

TIPS: Accessing the GPS2 Certification Submission Portal

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Be sure the GPS2 form is a PDF document and not an image.

When completing fields in the portal, be sure the address and contact information (phone number and email address) are correct.

Check DOB NOW to verify the address on file when completing the form fields in the portal.

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Inspections Generally

This inspection is a point in time inspection of a gas system. Assuming the inspection was conducted properly, at what point does the inspector’s liability end?

The licensee is responsible for the work performed and the accuracy of any forms completed and submitted to the owner and the Department.

Is it required to prove the legality of an existing gas installation?

While the licensee is not required to prove legality of an existing gas installation, the licensee is responsible for identifying illegal connections or any non-Code compliant conditions.

Does the inspection requirement include commercial spaces?

The inspection requirement applies to all buildings other than R-3 (ex. one- and two-family). The law outlines the scope of the inspection, starting at the point of entry into the building and up to, but not including tenant space. Tenant spaces are not included in the scope, regardless of their occupancy classification.

If there is a boiler room or mechanical room in a tenant space, is it exempt from the inspection and leak survey?

Yes, if there is a boiler room or mechanical room in a tenant space, it is exempt from the inspection and leak survey.

Are there any circumstances under which an appliance within any tenant space will be subject to an inspection or survey?

No. Appliances within tenant spaces are not subject to an inspection or survey.

What actions must the plumber take if access is not available to all required areas containing the exposed gas piping for the visual inspection or if access is not provided to public spaces, hallways, corridors, and mechanical and boiler rooms for the leak survey?

Local Law 152 requires periodic inspections of gas piping systems. It is a building owner’s responsibility to have that inspection conducted. If the owner fails to provide access to the areas subject to inspection requirements, the plumber should not certify the inspection as complete.

Are there any special actions to be taken if the plumber is refused access to an area that requires and inspection or survey?

If full access is not provided the inspector should not certify the inspection as complete.

If an inspection is not completed, must the entire inspection be repeated?

Yes, if an inspection is not completed, it must be repeated. To certify an inspection, the plumber must inspect all areas subject to the requirements of the law.

Who should I contact to report a condition that requires immediate notification?

Report conditions that require immediate notification to the owner, the appropriate utility [National Grid (718) 643-4050 or Con Edison (800) 752-6633] and the Department’s Plumbing Enforcement Inspections Unit at (212) 393-2557 or PlumbingEnfIR@buildings.nyc.gov.

The web form asks for the ‘Date of Initial Inspection.’ If repairs were made on a different date from the initial inspection, which date should be included on the web form?

The web form should include the date of the Initial (first) inspection.

How is DOB going to verify the 5 years' experience requirement in addition to the 7-hour training for LL152 gas inspectors?

Local Law 152 and 1 RCNY §103-10 allow an individual to perform Local Law 152 inspections so long as such individual holds the appropriate experience and training qualifications established by the Department. It is the responsibility of the employing inspection entity and Licensed Master Plumber to ensure that persons performing Local Law 152 inspections in their employ and under their supervision possess the appropriate qualifications per Local Law 152 and 1 RCNY §103-10. As such, the employing inspection entity may require whatever documentation necessary to verify the requisite experience of its staff.

If I have a building that has gas service that has been locked off by the utility company and all gas meters and associated gas piping has been removed, is the Licensed Master Plumber or Design Professional responsible for submitting the GPS2 Certification Form to the Department?

The Registered Design Professional (RDP) is responsible for submitting the GPS2 Certification Form by checking off item #4 Certification of No Gas Piping System. The RDP should reach out to the utility company to verify that the gas service has been cut from the street or shut at the curb valve.

Visual Inspections

What does exposed gas piping consist of?

Exposed gas piping includes gas piping that is open to view. It does not include gas piping above a drop ceiling or behind an access door.

Is the visual inspection limited to interior gas meters and gas piping only or is exposed gas piping, such as on a roof, also be required to be inspected?

Local Law 152 requires all exposed gas piping from point of entry of gas piping into the building, including building services meters, and all gas piping in public spaces, hallways, corridors and mechanical and boiler rooms inside and outside a building, including rooftops. This does not include gas piping within tenant spaces.

Should the inspection include all rooms (up to a tenant space) containing a gas appliance?

Yes, the inspection should include all rooms (up to a tenant space) containing a gas appliance.

Should sections of buried piping be inspected? (verification of proper sleeves, vents etc.)

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.

Should equipment such as regulator vents be inspected? (sleeves, termination points etc.)

Should equipment such as regulator vents be inspected? (sleeves, termination points etc.).

There are four levels of corrosion. Which levels must be reported to the Department?

Based on the Interior Gas and Safety Inspection Training, corrosion Levels 3 and 4 are required to be reported to the Department.

Illegal connections can be theft, diversion of service, cross connections or connections made with substandard parts or materials. Which version of the Code should be referenced to identify an illegal or non-Code compliant installation?

Theft, diversion of service, cross connections or connections made with substandard parts or materials are illegal connections and non-Code compliant installations. They create a safety hazard and do not meet 2014 Code requirements. As a baseline, the 2014 Code should be referred to.

Are buildings used exclusively for metering and regulating gas not considered the customer’s building for purposes of compliance?

Buildings used exclusively for metering and regulating gas must be inspected.

Leak Surveys (Tests)

Must the individual performing inspection also conduct a leak survey in all the areas where the visual inspection of exposed gas piping is required?

Yes, the plumber must conduct a leak survey in all the areas where the visual inspection of exposed gas piping is required.

Will the areas surveyed only use a combustible gas detector to assess the general atmosphere along the path of the piping and in public spaces, hallways and corridors on floors that contain gas piping or gas utilization equipment?

Yes, as indicated in the Interior Gas and Safety Inspection Training, the areas surveyed will utilize a combustible gas detector to assess the general atmosphere along the path of the piping and in public spaces, hallways and corridors on floors that contain gas piping or gas utilization equipment.

If the piping is not exposed, how will the plumber determine what areas of a building may contain piping in order to conduct a leak survey?

If the piping is not exposed, the plumber will operate the combustible gas detector in accordance with the Interior Gas Piping and Safety Inspection Training requirements, assessing the open atmosphere in the presumed path of the piping (in public spaces, hallways and corridors on floors that contain gas piping or gas utilization equipment) up to the tenant space.

Will the gas leak survey also terminate at the tenant spaces?

Yes, the gas leak survey will terminate at the tenant spaces.

Is the plumber required to take readings at the entry to the tenant spaces (around doors) or just in the public spaces?

The inspector is required to take readings at the entry to the tenants’ spaces, this does not include gas piping within the tenant spaces.

How will inaccessible crawl spaces be leak surveyed?

Combustible gas detectors shall be used to probe a crawl space to conduct the leak survey.

Reporting

What conditions require immediate reporting?

Unsafe and hazardous conditions such as a gas leak, illegal connection or non-code compliant installation require immediate notification shall be made to the Utility, the Department and the owner. In addition, any condition that if verified by the Utility would constitute a Class A condition, as defined in part 251 of Title 16 of NYCRR must be reported immediately.

What is the penalty for not immediately reporting a condition listed above?

The plumber will be subject to DOB violation(s) for not following inspection rules and requirements. (In addition, anyone who holds a LMP DOT Operator Qualification Status will be SUSPENDED pending a complete investigation and subject to revocation.)

Carbon Monoxide is defined as a Class A condition. Will the plumber also be required to check for carbon monoxide or is this exempt due to other existing regulatory requirements?

Carbon Monoxide falls outside of the scope of Local Law 152 requirements. If an inspector detects a Carbon Monoxide leak, he must immediately report it to FDNY. The FDNY will reach out to the Utility to investigate.

Class B conditions are also defined as immediately hazardous. Are these required to be reported immediately?

No. However, Local Law 152 requires that Class B conditions be included in the plumber’s report.

Is a phone call to the Utility all that is required to report an immediately hazardous condition?

To report an immediately hazardous condition, you should continue to follow the established protocols which were put in place even prior to Local Law 152.

What specific immediate notification is required to the owner?

The owner can be notified by phone call or via email.

Is the plumber responsible for notification of these conditions immediately from the field?

Yes, the plumber is responsible for notification of these conditions immediately from the field.

Is the plumber required to remain onsite when reporting an unsafe or hazardous condition?

Yes.

Is the plumber required to wait for the first responders or Utility?

The plumber should take the necessary steps, including notifications, as required by the Code. The plumber should rely on his/her professional judgement, based on the conditions observed, as to what further actions are warranted.

After the initial immediate notification, does the plumber have to follow-up and provide a copy of the GPS1 to the Department so that there is an official record of the inspection and the conditions found.

Local Law 152 does not require that the list of conditions (GPS-1) identified be submitted to the Department. Local Law 152 only requires that the certification be submitted to the Department.

Class C conditions are not considered immediately hazardous but may be required to be reported to be non-Code compliant. Are these conditions required to be listed on the GPS1 report?

Yes, Class C conditions are required to be listed on the GPS1 report.

The licensee is required to submit the GPS1 report form to the owner within 30 days following the date of the inspection. Is the licensee who conducted the inspection required to provide the owner with a GPS2 certification?

Within 30 days of the inspection, the Licensed Master Plumber (LMP) must provide to the building owner a Gas System Periodic Inspection Report (GPS1). Within 60 days of the inspection, the OWNER must submit to the Department a Gas Piping System Periodic Inspection Certification (GPS2) signed and sealed by the LMP who conducted or supervised the inspection. The GPS2 submission is to be completed by the Building Owner on the Department’s GPS2 submission web portal.

If the Department does not see the original GPS1 form, how would they know if the owner hires a different plumber to certify any conditions without doing any of the required work?

The owner is responsible for ensuring that any conditions identified are corrected. The licensee is responsible for completing a certification to be submitted to the Department that the conditions have been corrected. The licensee is responsible for the accuracy of the information submitted to the Department.

If the owner chooses to hire a different plumber to certify any conditions noted on the GSP1 form, will that plumber have to conduct another inspection upon completion of the work?

Yes.

The web form I submitted includes an error. Can I correct?

The applicant must resubmit the web form. The Department will review the most recent certification submitted.

The owner is responsible for submitting the GPS2, does that mean the owner must have a login to do so or can the Licensed Master Plumber submit on behalf of the owner in the portal?

No login ID is required to access the portal and complete the GPS2 Inspection Certification submission process. Local Law 152 and 1 RCNY §103-10 state that the owner must submit the Certification of Inspection (GPS2 form) that has been completed by the inspecting Licensed Master Plumber.

Is the physical form GPS2 to be filled out and then uploaded (rather than there being an electronic format in the portal)?

The GPS2 form is available for download as a PDF on the Department’s website. The GPS2 form is a PDF with fillable fields. The Licensed Master Plumber can download the GPS2 form, complete the fields digitally, print, sign and seal the form, retain a copy, and then − no later than 30 days from the date of inspection—provide the building owner with the completed GPS2 form. Alternatively, the Licensed Master Plumber can print the blank GPS2 form and physically complete the fields by hand. When submitting the GPS2 form via the submission portal, the user will be prompted to complete some information fields prior to uploading and submitting a digital copy of the form.

What buildings are subject to the Local Law 152 inspection requirements?

The law mandates the periodic inspection of the gas piping system in all buildings, except for R- 3 occupancies. The Building Code occupancy group classification should appear on the Certificate of Occupancy for the building. Additionally, the Department of Finance (DOF) classification appears on the property profile in the Buildings Information System for each address. Building Code Occupancy Group R-3 corresponds to the following DOF Classification Codes: A0, A1, A2, A3, A4, A5, A6, A7, A8, A9, B1, B2, B3, B9, M3, M4, N2.

I received notification of a required periodic gas piping inspection, but my house is a 2-family home that should be exempt from this requirement. How can I have this corrected?

Search by your address in the Buildings Information System and find the Department of Finance (DOF) classification that appears on the property profile. Only properties with the following DOF Classification Codes are exempt from the requirement: A0, A1, A2, A3, A4, A5, A6, A7, A8, A9, B1, B2, B3, B9, M3, M4, N2. To update your property classification, which is part of the property data maintained by DOF, follow the directions to Request to Update Property Description for Tax Class 1 Properties.

Are accessory structures subject to the Local Law 152 inspection requirements?

All buildings not classified as R-3 occupancy, including accessory structures like detached garages, are subject to Local Law 152 requirements. If the accessory structure does not contain gas piping, a Gas Piping System Periodic Inspection Certification, signed and sealed by a RDP or LMP, that states the building contains no gas piping must be submitted to DOB. stating that the building contains no gas piping must be submitted to DOB. Once submitted, the building will not be subject to further Local Law 152 inspection requirements unless gas piping is installed.

What if I am unable to have my building’s gas piping system inspected by the December 31st deadline that applies to my building?

1 RCNY §103-10 requires the inspection of a building’s gas piping system by December 31st of the cycle year that applies to the building. The cycles are based on the Community District in which the building is located. If an owner is unable to have their building inspected by the December 31st deadline that applies to their building, they may request a 180-day extension of the deadline through the online portal. Only one extension of the deadline will be permitted per cycle. Owners must have their building’s gas piping system inspected during the 180-day extension period and ensure a GPS2: Gas Piping System Periodic Inspection Certification is submitted within 60 days of the inspection.

Who can perform the gas piping system inspection?

If the building does not contain gas piping, a Gas Piping System Periodic Inspection Certification, signed and sealed by a Registered Design Professional (a New York State licensed professional engineer or registered architect) or a Licensed Master Plumber, stating that the building contains no gas piping is required to be submitted to DOB. If the building contains gas piping and the building is currently supplied with gas, hire a licensed master plumber to inspect the gas piping system in the building. Before hiring an LMP, use the License Search tool to make sure the LMP's license is active. Review the disciplinary actions taken against a licensee by DOB or voluntary surrender records by using the Know Your Construction Professional tool.

If I have additional questions, who can I contact?

Submit inquiries to the online help form at nyc.gov/dobhelp.