What is Local Law 152?

Local Law 152 of 2016 was part of a larger package of regulations concerning gas line safety. Specifically, 152 requires periodic inspections for gas piping systems. The DOB’s proposed rules clarify timing, filing requirements, and civil penalties for noncompliance.

The November 13, 2019 NYC Department of Buildings service update can be found here.

Which buildings does the law apply to?

Building gas piping systems except for gas piping systems classified in occupancy group R-3 must be periodically inspected.

Per code, occupancy group R-3 includes “buildings or portions thereof containing no more than 2 dwelling units,” like convents and monasteries with fewer than 20 occupants, group homes, and 1 & 2 family dwellings. If you’re unsure of your property classification, you can find your building’s occupancy group on the Certificate of Occupancy.

When are inspections due?

Inspections must be performed and submitted once every 4 years, with different due date cycles for each borough:

• January 1, 2024 – December 31, 2024 | Districts: 1, 3 and 10 in all boroughs

• January 1, 2025 – December 31, 2025 | Districts: 2, 5, 7, 13, and 18 in all boroughs

• January 1, 2026 – December 31, 2026 | Districts: 4, 6, 8, 9, and 16 in all boroughs 

• January 1, 2027 – December 31, 2027 | Districts: 11, 12, 14, 15, and 17 in all boroughs

Subsequent inspections must be completed no later than December 31st within every fourth calendar year thereafter. The inspection cannot be conducted more than 60 days prior to the due date.

For example, if you initially filed on March 1, 2020, you would have to file again by March 1, 2024. You would not be able to perform the inspection more than 60 days prior to March 1, 2024.

For new buildings (a building or any portion thereof approved for occupancy after 12/31/18), the gas piping inspection should be completed during the 10th year after the DOB issues a Certificate of Occupancy for the building (the rules make no distinction between temporary and final CO). Subsequent inspections would follow the above five-year rule – due five years after the first inspection was performed.

What if I don’t have a gas piping system?

If your building doesn’t have a gas piping system, you’ll still be required to comply with this law. 

Per the proposed rules, buildings without systems have to file a Certification (from a registered design professional) stating the building contains no gas piping system.

Similarly to the 4-year inspection cycle, this certification would follow the borough calendar (2019 for Staten Island, 2020 for the Bronx, 2021 for Manhattan, 2022 for Queens, and 2023 for Brooklyn). The biggest difference is that the due date for this certification would remain December 31st of every fifth year, as there is no inspection date to key off of.

If your property previously submitted this certification then subsequently installed a gas piping system, the due date will be the 5-year anniversary of that certification. For example, if your building submitted a certification of no gas piping system on November 1, 2019, then installed a gas piping system in 2021, the first inspection due date for the system would be November 1, 2024.

What’s the inspection and submission process like?

LL152 inspections must occur within the calendar year denoted in the Inspection Cycle for those applicable buildings.

Within 30 days of the inspection, the licensed master plumber (LMP) must provide to the building owner a Gas Piping System Periodic Inspection Report (GPS1).

​Within 60 days of the inspection, the OWNER must submit to DOB a Gas Piping System Periodic Inspection Certification (GPS2) signed and sealed by the LMP who conducted or supervised the inspection. GPS2 submission is to be completed by the Building Owner on the NYC Department of Buildings GPS2 submission portal. There is no filing fee. According to DOB, no login will be required but DOB reiterated that the law & rule state that the owner must submit the GPS2 form that has been completed by the LMP.​

If the Inspection Certification submitted to DOB indicates that conditions requiring correction were identified in the Gas Piping System Periodic Inspection Report submitted to the owner, the owner must submit to DOB, within 120 days of the inspection, an Inspection Certification signed and sealed by the LMP who conducted the inspection, stating that the conditions have been corrected.

If the Inspection Certification submitted to DOB indicated that additional time was needed to correct the condition(s) identified in the Inspection Report, the owner must submit, within 180 days of the inspection, an Inspection Certification signed and sealed by an LMP stating that all conditions have been corrected.

Correction of conditions identified in the Inspection Report must be performed in compliance with the NYC Construction Codes, including obtaining any required work permits.

Building owners are required to retain the inspection reports for 10 years and the LMP who conducted the inspection should maintain reports.

What Must Be Inspected?

LL152 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. This does not include gas piping within apartments.

What happens if an unsafe or hazardous condition is observed?

If an inspection reveals any unsafe or hazardous condition(s), the LMP must immediately notify the building owner, the utility providing gas service to the building, and DOB. The building owner must take immediate action to correct the condition(s) in compliance with the New York City Construction Codes and any required permits.

LMPs should immediately report such conditions by calling 311 or by contacting the DOB Plumbing Enforcement Unit during regular business hours at (212) 393-2557.

What are the penalties for noncompliance?

Per the proposed rules:

A building owner who fails to submit a certification required to be submitted…on or before the filing due date specified…will be liable for a civil penalty of ten thousand dollars ($10,000).