SHORTER FILING DEADLINES FOR BOILER & ELEVATOR REQUIREMENTS
AND WHAT IT MEANS FOR YOUR COMPLIANCE
2022 brought changes to your filing deadlines in two areas of your compliance. Both your boiler inspection requirements and category testing of elevator requirements have shorter deadlines making it even more difficult for property managers to ensure compliance with these laws.
So what are your requirements?
For Boilers, you have different requirements depending on if you have a high-pressure or low-pressure boiler.
Here’s the low down on those deadline changes.
NEW BOILER DEADLINES
|NEW DEADLINES||PREVIOUS DEADLINES|
|Annual Reports Filed
|14 days after annual inspection||45 days|
|Defects Corrected||90 days after initial inspection|
|Affirmation of correction
|Within 14 days of correction||60 days|
|Extension Requests||Up to two 45 day extensions|
NEW ELEVATOR DEADLINE
|NEW DEADLINES||PREVIOUS DEADLINES|
|Performing agency must notify the DOB 5 days in advance of tests||5 days in advance of tests||7 days|
|Category Test Report Submitted to DOB||21 days after date of the category test||60 days|
|Defects Corrected||90 days after date of the category test||120 days|
|Affirmation of correction||Within 14 days of correction||60 days|
|Extension Requests||Up to two 45 day extensions||One 180 day extension|
All in all, this means that you now a whole less time to complete these requirements. But in addition to these shortened deadlines, the DOB has also made some pretty significant changes to your compliance requirements.
WHAT ELSE HAS CHANGED?
New Boiler Requirements
Electric high-pressure boilers are now being classified as high-pressure boilers and must currently be inspected two times annually (as per article 303 of Title 28 of the NYC Administrative Code). Here’s a quick rundown of the difference in requirements between a low-pressure and high-pressure boiler.
|Must have 1 inspection annually||Must have 2 inspections annually. One internal & One external. They must be conducted in the same cycle but approximately six months apart.|
|Residential buildings with 6+ families
H-stamp boilers with an input of over 350,000 BTUs in residential occupancies
H-stamp boilers in commercial and mixed used buildings
Residential buildings classified as a single room occupancy dwelling (SRO)
|All High pressure boilers|
|Inspections can only be performed by authorized boiler inspectors licensed by the DOB, or by an authorized insurance company.||Inspections can only be performed by an authorized insurance company Inspectors must notify the DOB viaat least 10 days before performing the internal inspection.|
New Elevator Requirements
The DOB will no longer subcontract “Periodic Inspections” to PVT Agencies. Instead, these annually required inspections will be the responsibility of the building owners. They must be performed by an approved elevator agency NOT affiliated with the agency in charge of the elevator’s maintenance. And as you guessed, this puts an additional expense on property owners.
- Periodic inspections must be performed between January 1 and December 31 of each year, at least 90 days (3 months) from the date of any Category 1 testing or previous periodic inspection.
- Following the final acceptance test, initial periodic inspections on new installations must be performed in the calendar year.
- Witnessing agencies are not required to witness the periodic inspections
In short, the new requirement means that in addition to your Category 1 & Category 5 inspections, you now need to perform periodic inspections, as explained above. To quickly review, here is a short breakdown of the differences between Category 1, Category 5 and periodic inspection.
|CATEGORY 1||CATEGORY 5||PERIODIC INSPECTION|
|Must be performed annually||Must be performed every 5 years from date of installation||Must be performed Annually|
|No load safety test performed||During Category 5 inspections, inspectors will test
weights to verify full load
full-speed operation of buffers
car safety devices and tripping speeds
125 percent of the rated load tests
the ability to break and slip traction
|Devices that require annual testing – note the initial inspection on newly installed devices should be performed in the calendar year following the final acceptance|
|Owners and managers are responsible for hiring an approved elevator inspection agency to perform the test NOT affiliated with the agency in charge of the elevator’s maintenance.||Owners and managers are responsible for hiring an approved elevator inspection agency to perform the test NOT affiliated with the agency in charge of the elevator’s maintenance.||Owners and managers are responsible for hiring an approved elevator inspection agency to perform the test NOT affiliated with the agency in charge of the elevator’s maintenance.|
|Owners must also obtain the services of an impartial, unaffiliated third-party agency (typically an elevator consultant) to provide witnessing of the inspection.||Owners must also obtain the services of an impartial, unaffiliated third-party agency (typically an elevator consultant) to provide witnessing of the inspection.||No witness agency is required|
|Must be performed and submitted to the DOB by December 31st of each year||Due at the end of the month in which they were last performed.||Must be performed and submitted at least 90 days (3 months) from the date of any Category 1 testing or previous periodic inspection.
|Annual Inspection late fee: $150/month*||Inspection late fee: $250/month*||Annual Inspection late fee: $150/month*|
|Affirmation of Correction late fee: $150/month*
*Note that these are filing fees. If the inspection itself is performed late, you will be subject to a much greater penalty – up to $5000, dependent on the category.