Gas Piping Inspections

Online comments: 8

• Ania

  Inregards to Notifying the DOB prior to a inspection, will you still be able to schedule a gas inspection during the week and on a weekend or Holiday. Many building owners and tenants work so access to there home is challenging, in addition they are reluctant and struggling financially to pay for the inspections and there are many cases where they only will schedule a inspection on there day off from work because they don’t want to lose a days pay of work. Please don’t allow this safety inspection to turn into a huge financial burden for the homeowner and tenant many times the homeowner and tenant will have to be present together to allow access to a stranger in our home to conduct a inspection, let’s not make this safety inspection a call out of work inspection for one hundred thousand people. Living in New York comes with many challenges already. Please allow this inspection to be conducted with understanding that it is very hard to get access to tenants space, many times if not most you need permission and schedule coordination from the tenant to get to some or all parts of a gas piping system. We need safety at all corners but we also need flexibility in scheduling New Yorkers are struggling at this time, and many are not happy with these inspections.

  Thank you for your time

  Respectfully,

  Ania

  Comment added September 25, 2025 9:03pm

• Anonymous

  I am the owner of a licensed plumbing company based here in New York City. I’ve been in this business for over 30 years, and my company has been conducting Local Law 152 gas inspections since the beginning of the program.

  I want to raise serious concerns about the proposed change requiring us to notify the Department of Buildings at least two days prior to performing a gas inspection with a building owner.

  This might seem like a minor procedural change on paper, but in the field, it’s a significant obstacle. Many of our clients include hospitals, private schools, and commercial buildings—critical institutions that cannot always accommodate inspections during regular business hours. They often require inspections during evenings, weekends, or with very little lead time, especially when coordinating multiple vendors or responding to internal scheduling issues.

  Right now, we do everything we can to work around our clients’ needs while staying compliant with DOB regulations. Requiring a two-day advance notice to the Department would drastically reduce that flexibility. In many cases, it could delay inspections, frustrate building owners, and even result in clients falling out of compliance simply because the scheduling window didn’t line up with DOB notification requirements.

  I respectfully ask the Department to consider how this change would impact real-world operations—not just for plumbers like myself, but for the property owners, managers, and institutions we serve.

  Please consider building in some kind of flexibility

  Thank you for your time and for listening to the concerns of the small business owners who help keep this city safe and running.

  Comment added September 26, 2025 8:40am

• Anonymous

  I’m writing as a concerned daughter on behalf of my aging parents, who own a small building in New York City. The rising costs and ever-increasing compliance requirements are making it harder and harder for them to hold onto something they’ve worked their whole lives for.

  As usual, the cost of compliance with this proposed filing will fall squarely on the shoulders of homeowners like my parents. These are not large landlords or corporations — just ordinary people trying to maintain a property they’ve owned for decades. Every new requirement adds another layer of expense, time, and stress, and it’s becoming unsustainable.

  We recently went through the latest round of gas inspections at the end of last year. It was incredibly difficult to even find a plumbing contractor who would do the inspection — most were either fully booked or told us they don’t perform that specific inspection. We only managed to get an appointment because someone else canceled at the last minute. The costs were significant, and the stress it caused my family — especially my parents — was even greater.

  On top of that, accessing the gas valve required going through a tenant’s apartment, and we had to work around their limited availability. Coordinating with a busy contractor, a tenant’s schedule, and now potentially the Department of Buildings as well? That kind of complexity doesn’t just cost money — it wears people down.

  If this new step is added to the process, I worry it will make an already difficult situation even worse. My parents want to do the right thing and follow the rules, but every added requirement makes it feel like the system is working against them.

  I urge you to consider the financial and emotional impact on small property owners and families like mine. These aren’t just filings and inspections — they are real burdens on real people who are doing their best to stay compliant.

  Thank you for listening.

  Comment added October 15, 2025 11:13am

• Mark

  I respectfully ask the Department to reconsider the proposed rule requiring several days’ advance notice before a gas piping inspection. While the goal of enhancing safety is appreciated, this requirement would create significant scheduling and coordination challenges without improving oversight.

  Gas inspections often involve accessing tenant spaces, coordinating with building management, and aligning the availability of licensed Plumber’s. Requiring advance notice would limit flexibility, delay inspections, and increase project costs significantly, on an already expensive inspection.

  The Department already has strong safety measures — including strict qualification reqiurements for inspecting entities and persons, inspection recordkeeping, and audit authority — that ensure compliance and accountability. Adding an advance notice requirement would introduce unnecessary administrative burden without added safety benefit.

  Comment added October 19, 2025 9:51pm

• Anonymous

  Last year we couldn’t get a appointment to do the gas inspection in December every company was busy we had to call Department of buildings to complain, this will practically make it even more difficult for the building owner scheduling and notifying the department of buildings, in addition adding cost to this it will be a terrible result to the building owner

  Comment added October 24, 2025 12:24pm

• george bassolino

  October 27, 2025

  Mona Sehgal, Esq.
  Associate Commissioner and General Counsel
  NYC Department of Buildings
  280 Broadway
  New York, NY 10007

  Re: Proposed Rule Amendment §101-03 and §103-10

  Dear Associate Commissioner/General Counsel Seghal:

  I offer the following comments to the Department of Building’s (DOB) proposed rule amendments.

  §2. Paragraphs (2), (3), (4) and (5) of subdivision (a) of section 103-10 of chapter 100 of Title 1 of the Rules of the City of New York are amended to read as follows:
  1. Inspection requirements.
  (2) Buildings that contain no gas piping system.

  The term building contains no gas piping system is easily confused with the term no active gas piping system and which have different fees associated with them. The Department should provide a definition for this term to avoid confusion among stakeholders so that it is clear that a building that does not have an active gas system will not be misclassified as a building that never had a gas piping system. This is critical for public safety. On March 12, 2014 there was a gas explosion that killed 8 persons, injured 50 and leveled two buildings. The source of the leak emanated from outside of the building. Owners that are not using gas within their building can easily be confused into believing their building has no gas piping system when in effect the potential for a similar disaster exists. The gas piping inspection was specifically designed to identify and respond to issues such as this.

  Suggested definition: A building shall be deemed to contain no gas piping system if it was constructed without any gas service and has never had an active gas piping system.

  §3. Subdivision (a) of section 103-10 of chapter 100 of Title 1 of the Rules of the City of New York adding a new requirement for notification prior to inspection.

  Requiring the inspections to be performed under the guidelines of Advanced Notice procedures (during normal business hours only) will prove to be a hardship for many owners. These inspections require coordination to ensure access is provided to all covered spaces. When submitting the notification, the licensee is required to designate a meeting spot where the licensee’s authorized representative would wait to provide access for an inspector. Generally, the window for an inspection is 30 minutes. A gas safety inspection may take between 1-8 hours to complete. It is not feasible to expect the designee to wait for an inspector. The requirement for an Advanced Notice inspection does not exist for any other safety inspections such as Annual boiler inspections.
  I respectfully request, unless the Department can demonstrate the necessity for providing notification, that this recommendation not be adopted. If the Department’s intent is solely to be informed that an inspection has been completed, then they require the licensee to submit notice that an inspection has been conducted within 24 hours of performing the inspection. Then I suggest that LMPs submit said notice within 24 hours that the inspection was done.

  The following recommended amendment was not included in the proposed Rule change. If adopted this change would provide further clarity to the inspection process and be in conformance with the recently enacted Int. 429-A.

  §3. Recommended changes to Subdivision (b) of section 103-10 of chapter 100 of Title 1 of the Rules of the City of New York adding a new requirement for notification prior to inspection.

  2. Inspection Entity Qualifications.
  1. Persons qualified to perform such gas piping system inspections shall be either:

  (ii) Individuals, working under the direct and continuing supervision of a licensed master plumber, with at least five (5) years of full-time experience holding a journeyman plumber registration issued in accordance with article 409 of chapter 4 of title 28 and working under the direct and continuing supervision of a licensed master plumber and who has successfully completed a training program acceptable to the Department. Proof of such qualifications shall be demonstrated by listing the inspector’s worker wallet and Journeyman Registrations numbers on the GPS-1 and GPS-2 forms.

  Adding the Journeyman registration also aligns with Int 429-A. Utilization of the Worker Wallet identification number provides verification that the inspector has completed the required training program.

  The following recommended amendments were not included in the proposed Rule change. Article 318 was created to prevent future fatal incidents such as the East Harlem (03-12-2014) and Second Avenue (03-26-2015). Performing this gas safety inspection at these locations would have identified the conditions that caused those explosions. Unfortunately, today this important safety law is mired in uncertainties. Some Licensees interpret it that they must shut down a gas system to remove a non-Code compliant condition and others are just recommending that hangers and supports be added. Owners are concerned that they will face outages and expensive repair and renovation costs. These concerns have led to a low compliance rate. Gas safety inspections can be broken down into three distinct segments, Reaction (work scope), Reporting and Remediation (conditions requiring correction.). The Reporting and Remediation segments have never been clearly defined and are the primary reason why the compliance rate is low. The proposed changes would provide clarity for all stakeholders.

  §3.Recommended changes to Subdivision (c) of section 103-10 of chapter 100 of Title 1 of the Rules of the City of New York (Inspection Scope)

  Inspection scope. Inspections of a building’s gas piping system pursuant to this section must be completed in accordance with requirements in Section 28-318.3.2 of the Administrative Code and any other requirements prescribed by the Department. The 2022 Building Codes shall be utilized as the basis for the inspection.

  It is essential that there is a baseline Code to be utilized for these inspections. Utilization of the most current Codes and standards is consistent with manner in which utilities perform these federally mandated inspections. Standardization provides clarity and requires to look at gas systems under the same lens. Any parts of the existing gas piping system that are not in compliance would be listed and reported.

  §3.Recommended changes to Subdivision (d) of section 103-10 of chapter 100 of Title 1 of the Rules of the City of New York (Report and Certification Process)

  (ii) ……Such inspection report shall include, for each gas piping system inspected, the following information
  1. A list of conditions requiring correction, including instances where one or more parts of such system is worn to an extent that the safe and reliable operation of the system may be affected;
  2. Gas leaks;
  3. Observed non-code compliant installations or illegal connections;
  4. Observed conditions described in Section 28-318.3.4 of the Administrative Code; and,
  5. Any additional information required by the Department.

  1. Hazardous conditions such as gas leaks or illegal connections.
  2. Observed conditions constituting a Class A condition as described in part 261 of title 16 of the NYCRR constituting an immediately hazardous condition.
  3. Observed conditions representing non code compliant conditions.
  4. Observed non code compliant conditions requiring remediation as identified by the Department to an extent that the safe and reliable operation of the system may not be affected.
  5. Any additional information required by the Department

  These proposed changes clarify the REPORTING and REMEDIATION sections. They mirror the existing Rule with one modification. It provides for the remediation of any non-compliant condition providing it would not harm the system or cause the gas to be shut off unless there is an immediate danger.

  The Department is in the process of preparing to require reporting of these inspections to DOB NOW SAFETY. While that will simplify the reporting process and increase transparency it will not resolve the issue regarding Reporting and Remediation.
  If adopted and incorporated these changes will simplify the three step process, provide clarity and should increase compliance. The clarity provides owners with confidence that they will not be faced with unnecessary repairs and their buildings won’t be shut down unless there is a hazardous condition and thus it will increase compliance.

  Simplified process
  1. REACTION (work scope): Inspect. Immediate danger handled at the inspection.
  2. REPORT: Report all non-compliant items
  3. REMEDIATION: (Conditions requiring correction) Only correct conditions for items that will not harm the gas system. Remainder is listed and would be required only if the system is shut down for repairs or alterations.

  REACTION:
  1- Inspector finds a hazard or illegal connection. Immediately resolved. Next is Report.
  2- Inspector finds No immediate hazards. Next is Report.

  REPORT:
  Any parts of the gas piping system not in compliance with the 2022 Codes shall be reported.
  This creates a list for future reference and use. Next is Remediation.

  REMEDIATION (Conditions requiring correction)

  1. Hazardous conditions such as gas leaks or illegal connections.
  Consistent with the law and current rule. Handled immediately in the field.
  2. Observed conditions constituting a Class A condition as described in part 261 of title 16 of the NYCRR constituting an immediately hazardous condition.
  Consistent with the law and current rule.
  3. Observed conditions representing non Code compliant conditions.
  Consistent with the law and current rule.
  4. Observed non Code compliant conditions requiring remediation as identified by the Department to an extent that the safe and reliable operation of the system may not be affected.
  Takes items that are listed in #3 that can be safely be remediated. Items are identified by Department. We report others decide.
  Gas is NEVER SHUT. No retroactive requirements.
  5- Any additional information required by the Department

  Sincerely yours,

  George Bassolino Plumbing Ltd

  George Bassolino
  President

  Comment attachment
  Document22.pdf

  Comment added October 27, 2025 2:42pm

• Arthur Klock, Plumbers Local 1 Trade Education Fund

  To support effective implementation of Local Law 142 of 2025, I recommend the Department consider including within this rule the addition of fields on the GPS-1 and GPS-2 forms to capture the inspection entity’s name and signature. In cases where the inspection entity is not a licensed master plumber, adding fields for the Journeyman Plumber Registration number and Worker Wallet number will bring these forms into compliance with the requirements of the new Local Law. Including the Worker Wallet number would confirm completion of the required 7-hour Periodic Gas Inspector training, as outlined in department rule §103-10. While the original proposed rule was written prior to the enactment of Local Law 142, I think it would behoove the Department to incorporate the new requirements of the law within this proposed rule prior to adoption.

  Comment added October 27, 2025 4:28pm

• The Master Plumbers Council

  The following comments are presented on behalf of the Master Plumbers Council of the City of New York, Inc. (MPC) in response to the NYC Department of Building’s (DOB) proposed rule amendments.

  Comment attachment
  MPC-Comments-on-Amendment-of-Rules-Relating-to-Periodic-Gas-Piping-Inspections-004.doc

  Comment added October 27, 2025 5:10pm