Public comments for: 3RCNY 115-02 Issuance of Proof of Compliance to Company Certificate Holders

Comments

Comment:
I STRONGLY DISAGREE WITH THE PROPOSED REGULATION. THIS IS GOING TO BE ANOTHER EXPENSE AND WITH THAT, THIS WILL AFFECT THE PRICES THAT WE HAVE. AS YOU MAY NOTICE, MAJORITY OF THE CLIENTS ARE HAVING A HARD TIME OF PAYING JUST FOR THE SERVICE. ON TOP OF THAT, IT IS THE RESPONSIBILITY OF THE CLIENT TO CHECK WHETHER THEIR SERVICING COMPANY IS LICENSED OR NOT. THIS PROPOSED REGULATION WILL ONLY BE FINE IF WE, LICENSED BUSINESSES, WILL NOT HAVE TO PAY AN EXTRA FOR THE DECALS AND TAGS THAT YOU WILL BE PROVIDING.
Agency: FDNY
Comment:
Good Afternoon: I do understand counterfeiting tags as it has happened close to home. However, I have been led to believe that the FDNY is a regulatory agency. Approved Companies buying Cleaning Certifications, Suppression Systems Tags, and Extinguisher Tags from the FDNY contradicts my understanding of the FDNY being a regulatory agency. If this proposed rule goes into effect, it is my perceptive that the FDNY would then become a participatory agency having a collaboration with all approved companies. In addition, the new rules suggest that these new tags would be designed with various security features to prevent counterfeiting… To me this sounds like an additional expense. This additional expense would be passed on to the customer.. who are already bemoaning at the industries prices. I do agree that fraudulent tags are in a deplorable order. Even So, I do not agree with the proposed rule as the end all be all solution. My Mother Told me if there is a will there is a way. Meaning in regards to this new rule, it is not going to stop fraudulent tags. If a person wants to make fake tags they will find a way. If someone can counterfeit one-hundred dollar bills, checks, parking placards they will counterfeit these tags as well.
Agency: FDNY
Comment:
We are a manufacturer of tags and labels with a specialization in the fire market and have many customers in the NYC area. The proposed regulation stipulating that all fire extinguisher service tags be purchased directly thru the FDNY is worrisome and is in direct violation of New York State's Donnelly Act regarding Unfair Competition. The act is the state's primary antitrust law and prohibits any contract, agreement, arrangement or combination that creates or maintains a monopoly or restrains competition. The laws of fair competition allow products to be purchased based on competitive pricing and the quality of the product. All tag manufacturers, except a single vendor chosen by FDNY, would lose all of their NYC business impacting their financial success.
Agency: FDNY
Comment:
We are a manufacturer of tags and labels with a specialization in the fire market and have many customers in the NYC area. The proposed regulation stipulating that all fire extinguisher tags be purchased directly thru FDNY is worrisome and is in direct violation of New York State's Donnelly Act regarding Unfair Competition. The act is the state's primary antitrust law and prohibits any contract, agreement, arrangement or combination that creates or maintains a monopoly or restrains competition. The laws of fair competition allow products to be purchased based on competitive pricing and the quality of the product. All tag manufacturers, except a single vendor chosen by FDNY, would lose all of their NYC tag business impacting their businesses financial success. Mark Klotzbach Allen Bailey Tag & Label
Agency: FDNY
Comment:
See attached letter
Supporting Document:
Agency: FDNY
Comment:
Kitchen fire suppression systems need to be added to this rule. It is not feasible to write in the serial number or job name/address of every portable fire extinguisher serviced on the tags, regardless of whether the tag is FDNY issued or not. The FDNY should meet with the local association of fire protection distributors to discuss & hammer out the details of this new rule as something does need to be done. Perhaps enforcement of existing rules & tougher consequences of those perpetrating fraud- both on individuals & companies.
Agency: FDNY
Comment:
I strongly agree with the above comments made by Joseph Duffy and Richard Melo.
Agency: FDNY
Comment:
I disagree with the proposal to have to use FDNY tags to service fire extinguishers. We are a well respected licensed fire protection company with highly trained and licensed technicians. We have been in service for over 60 years! To have theses regulations put on our company is a burden and expenditure to us.
Agency: FDNY
Comment:
I disagree with the proposal to have to use FDNY tags to service fire extinguishers. We are a well respected licensed fire protection company with highly trained and licensed technicians. We have been in service for over 60 years! To have theses regulations put on our company is a burden and expenditure to us.
Agency: FDNY
Comment:
The proposed rule does not enhance regulations against counterfeit tags or stickers. This rule would not address business owners ability to assess whether the companies are properly servicing their equipment. The FDNY company list already provides evidence of which companies are listed and which companies are not listed. It is the responsibility of the business owner to ensure they are familiar with the list to ensure they are using a compliant company. The business owner should be receiving violations if they are using a non compliant company, and not doing their due diligence to vet a company before allowing them to work on the premise. Fire inspectors should not only be looking at tags on extinguishers, but they should also be looking that company up in their records to ensure that the company is still licensed and compliant to conduct business. Purchasing Decals and tags specifically and only from the NYC Fire Department conflicts with NY state regulations against "Unfair Competition" legislation. Any current business offering service tags would immediately lose all of this business, and this business would go directly to the fire department which would be against state competition laws. The fire department cannot create a law to monopolize the industry by restricting the purchasing of tags only to their agency. The laws of competition allow for products to be purchased based on quality of service and competitive pricing. FDNY approved kitchen hood companies or fire extinguisher companies should be able to use a tag company that has competitive pricing, which this rule threatens to disallow. If the FDNY wants to regulate the service tags and decals, the best way to go about it would be to regulate the tagging industry. Tag & label providing agencies should be to be compliant with FDNY rules, and should be audited to ensure compliance. A listed number of companies should be allowed to ship fire department approved tags throughout New York City, and the fire department should be able to audit these agencies. In todays day and age, eventually everything can be counterfeited. Pushing all label and tag procurement funnel through the fire department would not solve a compliance issue.
Agency: FDNY

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