Lock in Your LL152 Inspection

Local Law 152 requires that certain building owners in NYC have their gas piping inspected from time to time. It does not apply to all buildings, but it does apply to a significant percentage of New York City’s structures (an estimated 280,000).

The law was originally passed in 2016, but it was updated and finally implemented in 2019. To explore the Local Law 152 of 2016, you can check here. To view the Local Law 152 update in 2019, you can go here.

While the law passed in 2016, it did not go into effect immediately. In fact, it was not officially implemented until after the Local Law 152 update in 2019 and the final adoption by the New York City Department of Buildings the same year. However, inspections under the law did not begin until January 1, 2020.

All building owners in New York City must have the Local Law 152 gas inspection with one exception. Buildings in the R-3 group are not required to do so. These are residential buildings that hold two or fewer families. It is estimated that 280,000 buildings throughout NYC will need the Local Law 152 gas line inspection.

The city is following a staggered approach to Local Law 152 gas inspection by doing it in cycles based on districts. The following cycles apply currently:

• Districts 1, 3, and 10: Inspections are required from January 1, 2020, through December 31, 2020.
• Districts 2, 5, 7, 13, and 18: Inspections are required from January 1, 2021, through June 30, 2022.
• Districts 4, 6, 8, 9, and 16: Inspections run from January 1, 2022, through December 31, 2022.
• Districts 11, 12, 14, 15, and 17: Inspections run from January 1, 2023, through December 31, 2023.

Note that this schedule applies to districts in all boroughs.

LL 152 stipulates that building owners must have subsequent inspections conducted every fourth calendar year after the initial inspection. It should be completed no later than December 31 of that year. So, a building that was inspected in 2020 will need another inspection in 2024, then in 2028, and so on. Note that this only applies until 2024 when all buildings will have their inspections due on the anniversary date of their initial inspection every four years. So, if your building was inspected on December 20, 2021, after 2024, that will be your due date moving forward. It’s also important to note that gas inspections cannot be conducted more than 60 days before the official due date.

According to subsection § 28-318.3.1 Inspection entity, “inspections of gas piping systems shall be conducted on behalf of the building owner by a licensed master plumber or by an individual under the direct and continuing supervision of a licensed master plumber, with appropriate qualifications as prescribed by department rule.”

No, you cannot. All building inspections must be conducted and submitted in the year they are due. What this means is that if you own buildings in multiple districts across several boroughs, you will need to have each building inspected when it is due, rather than having them all inspected at once.

Yes, any building without a gas piping system is still affected. While you are not required to have an inspection, you will need to file a certification stating that your building contains no gas piping system according to the same schedule listed above. However, you do not need to obtain your certificate from a licensed master plumber. Instead, you must work with a registered design professional.

Under Local Law 152, all exposed gas piping from the point of entry into the building must be inspected. This includes gas piping at service meters, as well as in public spaces, hallways/corridors, and in boiler/mechanical rooms. Note that it does not include piping within any apartments/living areas unless it is an owner-occupied unit.

If you do not submit your Local Law 152 gas inspection form on time, you face penalties. According to the rules adopted, you could be liable for a civil penalty of $5,000. You can challenge the penalty, but must do so within 30 days of the date of your violation and will require that you submit proof that you did in fact file on time.

It’s important to understand the timeline involved with inspection, submission of the report, and further steps. The breakdown for what building owners need to know regarding an LL 152 gas inspection is as follows:

• Have your inspection done on or before the due date.
• Within 30 days of the inspection, the licensed master plumber will provide you with a gas piping system periodic inspection report. This report details the findings of the inspection and any actions that must be taken on your part.
• Within 60 days of the Local Law 152 inspection, you must submit Local Law 152 forms to the NYC Department of Buildings. It must be signed and sealed by the licensed master plumber conducting the inspection. It does not cost anything to file (note that it does cost to have the inspection conducted).
• Within 120 days of the initial inspection, the owner must submit an LL 152 gas inspection certification signed and sealed by a licensed master plumber conducting the original inspection stating that any required corrections have been made (only applicable if corrections are needed).
• Extensions are available for corrections, but only up to 180 days from the inspection, and by that date, you must submit a signed and sealed certification stating that the corrections have been made. Note that all corrections must adhere to NYC construction codes.
• Keep all certifications and reports for 10 years.