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 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. Note that this document may not reflect the most recent interpretation of Local Law 152.
Click HERE for the most recent NYC Buildings (DOB) compilation of “FAQ: LL152 of 2016 – Inspections of Exposed Gas Piping” which is periodically updated by DOB.
Click HERE for the NYC Buildings (DOB) online version of FAQs.
If you have a question for which you do not see the answer then it is recommended that you email the DOB with your question to LL152of16@buildings.nyc.gov which is the official NYC DOB Local Law 152 email address.
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?
KeepMyGas analyzed several samples of data and we estimate 300,000 to 310,000 total buildings with and without gas piping systems will require an inspection during each 4 year cycle of 2020 to 2023, 2024 to 2027, Etc.
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.
Will KeepMyGas look up a list of buildings for me to determine which year the inspection is due?
Yes, of course we will. Just click HERE and attach a PDF, Word or Spreadsheet list of your buildings and click submit. We will look up the Community District # for each address for you and circle back to you with the year due results for each building.
Can the deadline of 12/31 for each year for the requirement to have an inspection and/or to complete the correction of conditions be extended?
For 2020 and 2021 the NY City Council legislatively extended the deadlines from 12/31/2020 to 06/30/2021 and from 12/31/21 to 06/30/2022.
In March of 2022 the DOB publish a Service Notice that provides for an automatic 6 month extension during any year in any cycle from 2022 on.
IE: You are due in 2024 and wish to extend the deadline to from 12/31/2024 to 06/30/2025.
If you choose to do this, we are happy to assist with no fee to do so. Click HERE to the Service Notice
IE: You are due in 2024 and wish to extend the deadline to from 12/31/2024 to 06/30/2025.
If you choose to do this, we are happy to assist with no fee to do so. Click HERE to the Service Notice
To access the DOB Service Updates site and see all updates – Click HERE.
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 is reduced to $5,000 as per DOB Adopted Rule. Click HERE to view the Rule page.
Effective 11/18/2024 the penalty for a 3 family is reduced to $1,500 as per the DOB Adopted Rule. 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.
On Page 2 of DOB Service Notice Follow-Up #5 there are instructions on how to comply when a building contains gas piping, but the building is not currently supplied with gas and has no appliances connected to the gas piping. On January 13th, 2023 the DOB published a Buildings News Update that provides more information on Gas Piping Inspection Reports and a link to “More Info on Periodic Gas Piping System Inspections”. See STEP 6: on that page for contact info to obtain the signed statement from the utility company referred to on page 2 of DOB Service Notice, Follow-Up #5.
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 or without 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 only 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.
NOTE that on February 28th, 2024 the NY City Council Committee on Housing and Buildings introduced Int 0429-2024.
Click HERE to see Int 0429-2024 on the Legislation page of the NY City Council website. You can download a word doc of Int 0429-2024 HERE.
Take note of page 4, § 28-318.3.2 Scope, lines 10 to 30. This appears to increase the scope of the inspection to include any commercial space with gas utilization equipment in any building to be inspected. While this additional space in a building has not previously been part of the Scope of a Local Law 152 inspection, the passing of Int 0429-2024 would change that.
The City Council Committee on Housing and Buildings has a hearing session scheduled on 10/08/2024 in the Council Chambers at City Hall.
Click HERE to see the calendar for the City Council Committee on Housing and Buildings and then click on Meeting Details & Agenda for the 10/08/2024 listing for more details.
We encourage you to attend on 10/08/2024 so you may have an impact on the final outcome of Int 0429-2024.
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.
What additional paperwork is required in the case where the original inspection resulted in conditions that required correction/repair?
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
NOTE: If a LMP other than the original inspecting LMP corrects the required conditions then another Local Law 152 Inspection is required. This as per Q14/A14 on page 7 of the most recent NYC DOB FAQs. Click HERE for that PDF.
There is no fee for this filing and the upload of the new GPS-2 to the portal 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.
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.
Local Law 153 also requires building owners to advise tenants what action to take when they suspect that a gas leak has occurred.
Tenants should receive a Suspected Gas Leak Notice describing the procedures to be followed when a gas leak is suspected with the first lease or first lease renewal from the property owner. Property owners may also choose to post the Combined Notice for smoke detectors/carbon monoxide detectors and gas leak notice.
Click HERE to access the Housing Quality/Safety/Gas page on the NYC Housing Preservation & Development website.
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 however 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?
IN addition to the Local Law 152 inspection that is performed by a Licensed Master Plumber, Consolidated Edison (ConEd) and National Grid will continue to complete the New York State required Service Line Inspections of jurisdictional piping which is the piping and apertures from the point of entry of the gas service to the outlet of the gas meter.
These inspections do not take the place of the Local Law 152 inspection that is performed by a Licensed Master Plumber.
In addition, the GPS-2 form that is part of the paperwork for a Local Law 152 inspection is only filed with NYC Buildings (DOB) and not with Consolidated Edison (ConEd) or National Grid.
Please click below to see more information on New York State required Service Line Inspections of jurisdictional piping by the utility. To be on the safe side, always communicate directly with the utility to arrange this inspection so you are certain that it is being done by an authorized employee or representative of the utility company.
National Grid
ConEd
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 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
