JTGMP Local Law 152 Blog

Urgent: DOB Alert Concerning GPS2 Non-Compliance

kate@redocs.com (Kate Hoffer) — Thu, 30 Nov 2023 15:58:35 GMT

Have you received the following DOB alert for your building(s) filed by JTG Master Plumbing?

There's no reason for alarm! Please note, we have confirmed with the DOB that our GPS2 certificates are in their system. See below for communications straight from the DOB regarding the matter. It seems the above email went out in error as part of their automated system and should be disregarded.

The last thing building owners need close to the December 2023 deadline is worrying about past filings. Rest assured, JTGMP is assertively assuring that all GPS2 certificates are filed and that our customers are in compliance with the DOB.

If your GPS2 was corrected to no defects, you will have received the following alerts from JTGMP. Subject line "JTGMP: Urgent Update About Your LL152 Filing"

There is no action required at this time. Thank you for being a loyal customer of JTG Master Plumbing.

Local Law 152: December Deadline Update

Wed, 09 Nov 2022 19:20:04 GMT

Local Law 152 Recap

When the DOB first introduced and passed Local Law 152 Gas Pipe Inspections, the property management industry reacted with backlash. The law's original start date was set to January 2019, but what followed was a slew of subsequent revisions that delayed its implementation until January 1, 2020.

Based on the available data, we were able to understand that most of the industry was slow to comply with the law - as there was confusion, anger and frustration on our parts as building managers and owners. Not to mention, the DOB’s hand at organizing and executing the law has been unclear and inconsistent. As such, there have been deadline extensions and a noticeable lack of penalties issued to noncompliant buildings.

December Deadline - Our Expectations of DOB Not Moving the Deadlines

The reason the DOB has continually messed with deadlines and implemented extensions, we believe, was brought on by nuances of implementing a new law and low building compliance. Originally, there was no provision in the law or rules for applying for an extension. As of March 2022, the DOB has amended Local Law 152 to allow for 180-day extensions.

What we expect going into this latest deadline is that the DOB will not be moving any deadlines or issuing another statement on extensions. Reason being, they’ve already provided blanket 6 month extensions for the community districts to boost gas inspection compliance. On top of the fact that they haven’t been issuing any fines yet. And lastly, the DOB even dropped the fines in half, from $10,000 to $5,000 as you can read in this NYC Service Update .

How DOB Has Handled Late Filings with Other Laws in the Past

We’ve seen the DOB move deadlines and delay issuing fines for other Local Laws in the past. So, it is unsurprising to see that the DOB has moved deadlines and fines around in the way they have for Local Law 152.

That being said, at some point, the DOB has no choice but to start issuing fines for violations or noncompliance. Especially now, after the original set of standards has been years in the making. Our experience tells us that the DOB will eventually start issuing these, and we feel as if that time is rapidly approaching.

What We Learned From the Last Scheduling Deadline

Corrective Action and Extension Filing

We found many people who had corrective action had to file for an extension since their CA’s were not completed before the deadline. As we know that most people aren’t too happy to have to deal with gas line inspections, let alone take the time to schedule, file, complete corrections, etc. Our advice for this situation would be to eliminate some of the hassle and schedule early, so that when the deadline comes, having to file for an extension won’t be anything to worry about.

Scheduling

In the recent past, there was a huge influx of people rushing to comply with their deadlines at the last minute. The rush started 1-2 months out from the deadline, and we were booked past the due date at six weeks pre-deadline. We also know from past experience there’s always a rush at the end of the year. Our advice for this situation is simple: book your inspection early. You don’t want your back against the wall and risk having to schedule past the deadline.

In Conclusion: Schedule Early!

With just two months to the end of 2022, we know the DOB will likely not move the deadline again and will soon start issuing fines to buildings that aren’t in compliance. To be clear, the fine is $5000 per building that is noncompliant, which can add up fast if you own multiple properties.

Further, there will be a massive influx in scheduling before the end of the year. And we do book up fast. As we have experienced, it’s better to complete the inspection early and not have to hassle with going back and forth on corrective actions and re-inspection dates, not to mention the possibility of having to file an extension.

So, the earlier you book your LL152 inspection, the better.

Why is JTG the Leading Provider in Local Law 152 Inspections?

JTG is an NYC-based company that works with property managers to guide them in obtaining compliance with NYC Local Law 152, Periodic Gas Pipe System (GPS) inspection. We pride ourselves with knowing how to help our customers through the process of dealing with the DOB, handling paperwork, and overall making the inspection process simple. We know what the law says, so you don’t have to.

Contact JTG Master Plumbing today and let us set your mind at ease!

Getting Started With Local Law 152 + Compliance Checklist

Thu, 29 Sep 2022 16:39:59 GMT

As we come into LL152 filing season for your community district, JTG would be remiss if we didn’t give you some practical information to help your inspections go smoothly.

What happens when defects are found during an inspection?

When defects are flagged, JTG provides an outline of corrective action. Some of these errors are easy to complete yourself. Many require the expertise of a licensed plumber.

Is there a risk that my gas will be shut off as a result of the inspection?

When a defect in your gas piping is discovered during a Local Law 152 inspection, it doesn't mean we immediately alert utility or the DOB. It depends on the severity of the specific defect. There are only three scenarios in which the plumber is required to notify the DOB and the utility:

A gas leak
Evidence of an illegal connection
A condition which would be defined as a Class A hazard by the utility company.

What are some examples of non-code installations?
To give you more insight on what is happening during the inspection and what Local Law 152 plumbers are looking for, here are three examples of non-code installations:

Gas pipe corrosion
Inadequate pipe supports
Outdoor gas piping not painted or coated

$5,000 Penalties?!
To be clear, just because you find yourself with defects, having to hire your trusted plumber to complete the work listed in the corrective action, the DOB isn't going to fine you that $5,000 penalty. Even if you are late filing your deadline. Take a look at this post about LL152 extensions to understand more about extending your deadline.

How can you prepare ahead of time for a Local Law 152 inspections?

If you want to ensure you know some basics about the LL152 inspection before plumbers are coming in to investigate, we’ve put together a checklist to get you started on preparing for a smooth inspection.

DISCLAIMER: The directions contained on this document or website are provided for general information purposes only and do not constitute professional advice on plumbing or any other subject matter. JTG Master Plumbing Corp does not accept any responsibility for any loss or damage which may arise from reliance on information contained on this document or website.

Filing For An Extension In Accordance With New York City Local Law 152

Wed, 28 Sep 2022 20:04:43 GMT

If you’re confused about Local Law 152 Gas Pipe System Inspections , then you are not alone. It’s been a rough journey getting to where we are now.

Timelines for inspection, filing inspection reports and certifications, navigating due dates by Community District/boroughs that are all on a staggered pattern – the process can be complicated as you work to determine expectations! It’s part of the job of property management, and we know you want concise and accessible information so that you can stay in compliance, a few steps ahead of the DOB.

In this post, we will be examining the meaning of filing a Local Law 152 inspection extension, why you would need to file an extension, the difference between two different LL152 extensions, and much more!

So, Where Do We Stand Now?

If your building is due for an inspection in 2022, we have some good news for you. As of March 2022, the DOB has amended Local Law 152 to allow for a 180-day extension to submit your compliance paperwork.

If you have not contacted a Licensed Master Plumber to set up your inspection, you may already be out of compliance and facing a hefty fine. The penalty used to be $10,000 but they have since amended that penalty to $5,000 .

What Exactly Does It Mean To File For An Extension?

Filing an extension request relieves you from the stress of trying to meet an uncomfortable inspection deadline, giving you the extra time you need to put yourself together before contacting your Licensed Master Plumber for inspection. While filing for an extension request helps you avoid penalties, you may be subject to a fine should you miss the extended (new) deadline provided by law.

Why You Need To File An Extension

Filing an extension request for extra time is a by-product of unforeseen circumstances. If your building has not received its approved LL152 inspection certificate and is required to have one performed, you will have until December 31 of your required filing year to have the inspection paperwork completed and filed.

Here are some of the reasons why you need to file an extension for your gas piping inspection:

Faulty Conditions in Your Gas Piping System: In the event that your gas piping system develops a defective condition, you can apply for an extension to rectify these conditions. Some of these conditions may be due to gas leaks, worn or old parts affecting safe operations, illegal connections or non-code compliant installations, etc. Under the Service Notice of the New York Department of Buildings (DOB) page, an extension of 120 days can be allowed for the rectification or correction of such faulty conditions.
Timing and Schedules Interference: Another reason you may wish to apply for an extension is due to clashing schedules. Dealing with major life challenges can also cause you to miss your deadline. Events such as the loss of loved ones, marriage, or divorce can take up your time and energy. People get busy and keep telling themselves they will get their gas piping inspection done on time. However, the law is set, and fines are in place should you default in conducting your inspection within the established time.
Health Condition: If you are suffering from a health condition that renders you incapable of running an inspection, you can file for an extension pending when your condition improves. Section 28-116.2.4. of the New York local laws provide that the “final inspection shall be performed by the department in the presence of the permit holder, the registered design professional of record, or the superintendent of construction.”

Due Date Extension V S. 'Filing With Defects' Extension

There are two types of extension requests a homeowner can explore while filing for an extension; due date extension and ' filing with defects' extension . While both types of extension share certain similarities, they are, nonetheless, different and unique.

Due Date Extension

A due date extension request is filed before the expiration of the original date provided under the law. In most cases, the application or filing is made close to the deadline or when it becomes evident that they can’t make the deadline. The building owner can file for a due date extension and proceed with the gas piping system inspection without being late. Therefore, this extension filing is made before a Local Law 152 compliance inspection is conducted by the Licensed Master Plumber (LMP). It gives owners an option to extend their deadline, which is usually within 180 days. It is a preemptive application that seeks to forestall an incident.

'Filing With Defect' Extension

A filing for defect extension arises when an owner’s gas piping system is shown not to be in compliance with DOB criteria. Under such circumstances, the inspection results will be filed with the DOB as “filed with defects,” and the owner must then proceed to rectify the issues to pass the inspection. In other words, this extension filing occurs after an inspection showing the faulty state of the GPS. It is a retrospective application that is made to correct the defects observed in the Gas Piping System. Some common GPS defects include gas leaks, faulty gas supply installation, worn or old gas pipes, gas line blockage due to debris, and contaminants in the GPS like dirt, oil, or water. This extension is not automatic when one files their LL152 paperwork.

Our Thoughts On The Matter

We file these types of extensions requests for customers, and we believe this new extension (previously not in place) emerged as a result of the huge percentage of buildings that were due in 2020 and 2021 but yet to file their reports. The majority of past local laws (relating to façades, energy, elevators, etc.) applied to smaller classes of buildings, usually larger in size and having more professional owners.

The formal extension process applies to buildings due in 2022 and later years and is not intended to apply to buildings that are already supposed to comply. However, informally, the Department of Building (DOB) has offered hints, including an “off-the-record” email sent to us, that 2021 buildings can avail themselves of this extension.

We’re Here to Help.

Years of experience and a close relationship with the DOB allows us to quickly determine the best course of action for you. We have developed relationships that allow us to keep abreast of changes that could affect deadlines.

It can be a cumbersome process to navigate, to make sure you are dealing with it all correctly. We’ll ask you a few quick questions to see if you’re eligible for an extension or if you’re in a position where you’ll need to get an inspection ASAP.

Contact JTG Master Plumbing today and let us set your mind at ease!

Clearing Up Some Misconceptions About Local Law 152

Thu, 14 Jul 2022 20:45:20 GMT

Some of you know me as the President of ReDocs. I'm also Vice President of JTG Master Plumbing Corp.

We’ve noticed the lack of communication between the City and building owners/managers. It seems even though we’ve passed the June 30 deadline, there’s recurring questions and misconceptions about the law - and so I wanted to write this email to clarify a few things about Local Law 152 gas piping inspections.

Regarding Defects. A defect found during the inspection doesn't mean you FAIL or that the DOB and utility need to be immediately called in. There are only three scenarios in which the plumber is required to notify the DOB and the utility:

A Gas leak
An illegal connection
A condition which would be defined as a Class A hazard by the utility company.

Notifying the DOB/utility primarily comes from finding gas leaks and other IMMEDIATELY HAZARDOUS conditions.

DOB/City and Gas Detecting Devices. The plumber's gas detecting device does NOT connect directly to the DOB or the utility.

Gas Pressure Tests. There is no pressure test required in the LL152 inspection and JTG doesn’t look for it when reviewing your buildings.

Gas Piping Code. Gas piping systems need only meet the code at the time it was installed. For example, an old building is not necessarily required to meet today's Fuel Gas Code.