As a New York City building owner, it isn’t easy to avoid HPD violations. There are so many ways you can misstep the law and so many regulations and deadlines to keep up with. Getting a violation is serious business. It can be used as a premise for a criminal court summons and may carry high penalties and fines. In addition, an open violation on a building can get in the way of the building’s sale and will halt all construction plans until the violation is removed.

As the City’s leading compliance service, we can guide you through your coding and safety procedures and ensure you always remain compliant. Let’s take a look at five common HPD violations and how to remove them.

HPD VIOLATION #1: SELF CLOSING DOORS

The requirement: In an attempt to prevent the spread of fires, LL62 of 2022 mandated that all doors providing access to interior corridors or stairs in R-1 and R-2 occupancy groups must be self-closing. In addition, LL63 of 22 amended the law that owners are required to keep and maintain these door in good condition.

If you are non-compliant: Failure for maintaining a self-closing door may make you liable for a class C immediately hazardous violation. These violations can result penalties as steep as $250-$500 a day from the date set for correction until the violation is corrected. LL63 changed the time to correct a violation from 21 days to 14 days. Falsely certifying a correction can run as steep as $500- $1000 per violation. In addition, if the violation remain open and not corrected, the City can assign an HPD Emergency Crew to complete the repairs and invoice the fees, costs and charges back to the Owner. So non-compliance can come with a pretty hefty price tag.

To remove the violation: Complete a COC and retain a photo of the repaired door for your records

HPD VIOLATION #2: Lack of Proper Heat and Water

The requirement: Building owners are legally required to provide heat and hot water to their tenants. Hot water must be provided 365 days a year, and maintained at a minimum temperature of 120 degrees Fahrenheit. Heat must be provided throughout “Heat Season”, which runs from Oct. 1^st through May 31^st each year. During the daytime hours of 6 a.m. through 10 p.m., if the temperature outside falls below 55 degrees, the inside temperature must be at least 68 degrees. At night, from 10 p.m. though 6 a.m., the inside temperature must be maintained at a minimum of 62 degrees.

If you are non-compliant: Failure to comply with the heat and water requirement can result in a Notice of Violation (NOV) as well as penalties, which are effective on the posting date until the violation is corrected. Penalties can run from $250-$500 per day for each initial heat or water violation. Each subsequent violation in the same building during the same or the next calendar year can result in a penalty of $500-$1000 per day. If the owner fails to pay the penalties, HPD will enter a judgment against the owner and the property.

To remove the violation: Eligible property owners can fix the violation within 24 hours of the violation posting, and submit the penalty amount within 10 days, along with a timely Notice of Correction.

HPD VIOLATION #3: Failure to Provide Smoke and Carbon Monoxide Detectors

The requirement: New York City law requires the installation and maintenance of smoke detectors and carbon monoxide detectors in all multiple dwelling units. As of April 2019, all smoke detectors must be powered by a sealed, non-removable battery with a minimum of 10 years or hard-wired to the home. Carbon monoxide detectors must be equipped with an end-of-life alarm. All detectors must be audible from all rooms in the dwelling. Property owners must ensure the detectors are always in working order and replace them as soon as they expire. In addition, the owner must post notices regarding carbon monoxide and smoke detectors in each building.

If you are non-compliant:  If a property owner fails to install smoke detectors, they can be facing fines of up to $1,000 per day of violation and even possible imprisonment.

To remove the violation: Install or replace the detectors. Keep, and provide upon request, records relating to the installation and maintenance of these detectors.

HPD VIOLATION #4: Lead Paint Hazards

The requirement: Ensure all units in buildings built pre-1960 are complete free of lead-based paint. If lead is presumed to be present in your building, or was actually found, you’ll need to provide copies of the abatement paperwork and lab test results of the dust wipes taken after any work was performed in your building. As per LL31, ALL units must undergo XRF testing by August 9, 2025. In addition, as per LL123, ALL units must undergo lead abatement steps, including friction surface removal on doors and windows by July 2027.

If you are non-compliant: If you fail to perform any of these remediations, you may be issued a Class C violation and may be required to produce your lead-related records. In addition, as per LL123, having any lead-based violations can cause your property to be chosen for a proactive inspection and audit.

To remove the violation: First, remediate the lead-based hazard. Next, have a dust wipe clearance test performed by an EPA-certified lead inspector or risk assessor. Submit a Certificate of Correction (COC) to the HPD, along with sworn statements from the Lead Abatement Contractor and Dust Wipe Contractor, the results of the dust wipe clearance testing, as well as the EPA certifications of both contractors. After you submit all the required paperwork, the HPD will arrange for a re-inspection to confirm that the hazard has been successfully removed. If the lead hazard has indeed been eradicated, the violation will be removed. As per LL123, you may also be required to provide up to 10 years of documentation.

HPD VIOLATION #5: Lack of Proper Pest Control

The requirement: Building owners must keep their properties free of all pests, including bedbugs. They must know how to best treat a bedbug infestation, frequently check for the presence of pests and eliminate any conditions that can trigger an infestation. Property owners of multiple-dwelling buildings must also file an annual bedbug report with the HPD.

If you are non-compliant: If your tenants are aware of the presence of bedbugs in one of your buildings, they can file a bedbug complaint with the HPD by calling 311. They will then be given the option of having an inspection performed by an HPD inspector. If a visual inspection confirms the presence of bedbugs or eggs, an NOV will be issued. In addition, if you fail to submit a bedbug report by the annual Dec. 31 deadline, an NOV will be issued as well.

To remove the violation: Record all the remedial actions you take and present the City with an HPD NOV Certificate of Corrections, which you can obtain by making a sworn statement testifying that you’ve followed the corrective actions issued in the Order.

HPD violations are never fun, but with identifying the key problem areas, you can hopefully avoid these violations altogether.  However, if you do receive an HPD violation, there’s no need to sweat it. Using Jaffa’s powerful compliance tools and services, we can help you resolve them as quickly as possible and avoid additional penalties.

Q: What are the differences in my requirements for a low vs. high-pressure boiler?

JA: Great Question.

The short answer? There are a lot of differences. Low-pressure and high-pressure boilers should NEVER be treated the same. As per the NYC, they are different entities and therefore, have very different requirements.

But before you get all HEATED up, check out this blog by our DOB Supervisor, Alexandra Schwab for a clear breakdown of the different requirements for each type of boiler.

 

Why You Should Be Digitizing Your Inspection Process

New York City is notorious for its rigorous compliance landscape. With frequent audits and strict regulations governing what seems like almost every aspect of property management, navigating these compliance requirements can be a daunting task for property owners and managers, often leading to headaches, stress, and, most painfully, violations. However, embracing digital solutions like the Jaffa deFINEd app can offer a transformative approach to compliance management, revolutionizing operations while ensuring adherence to NYC’s complex regulatory environment.

In addition, the high frequency of audits in NYC underscores the importance of digitizing your compliance management, as traditional manual processes are time-intensive and susceptible to errors and delays, putting properties at risk of non-compliance and penalties. By adopting the Jaffa deFINEd app, property owners and managers can proactively address these challenges, reducing the likelihood of mistakes and streamlining their compliance efforts.

Digitization brings several key advantages, particularly in the context of audits.

1. Seamless Audit Preparation: The Jaffa deFINEd app centralizes compliance-related data, documentation, and tasks, facilitating comprehensive audit preparation. Property owners and managers can easily access and present the necessary information during audits, reducing the stress and time required to compile and submit physical documents.
2. Document Management: The Jaffa deFINEd app facilitates seamless document management by allowing property owners and managers to capture, upload, and store photos, signatures, and files directly within the app. This feature eliminates the need for physical paperwork, making documentation easily accessible during audits and inspections.
3. Accurate and Transparent Reporting: Digitizing compliance management ensures accurate and transparent reporting. The app’s robust record-keeping capabilities maintain precise compliance records, eliminating discrepancies and providing an audit trail for regulatory authorities.
4. Real-time Collaboration: The app promotes real-time collaboration among in-office and in-field team members. Property owners or management companies, on-site managers, inspectors, and contractors can communicate, share updates, and collaborate on compliance-related tasks, ensuring streamlined operations and efficient decision-making.
5. Proactive Compliance Monitoring: The Jaffa deFINEd app’s automated reminders and notifications are crucial in staying ahead of compliance requirements. Property owners and managers receive real-time alerts for upcoming inspections, certifications, or renewal deadlines, reducing the risk of missed deadlines and non-compliance issues that could trigger audits.
6. Multilingual Support: NYC is a diverse city with a multicultural workforce. The Jaffa deFINEd app offers multilingual support, ensuring employees from different linguistic backgrounds can effectively use and navigate the app. App users can choose English, Spanish, Albanian, and Russian, making it accessible to everyone on your team. Clear communication in their preferred language fosters understanding and improves compliance management across the board.
7. Remote Access and Data Sync: The app allows property owners and managers to access compliance data anytime, anywhere, through secure remote access. Real-time data sync ensures that all team members are working with the most updated information, enhancing collaboration and streamlining compliance management processes.
8. Complete overview of your portfolio: The Jaffa deFINEd dashboard provides a comprehensive overview of all your buildings, upcoming deadlines, tasks, upcoming HPD violations, ECB hearings, and open corrections, so you’re always confident of the status of any of your properties.
9. Geo-location Verification: The app incorporates geo-location verification, enabling property owners and managers to validate inspections and document their occurrence at specific locations. This feature adds an extra layer of accuracy and accountability, enhancing the integrity of compliance management.

 

But the Jaffa deFINEd app is about more than just inter-team communication and staying ahead of your audits. Its complete set of features allows for in-app compliance task completion. That’s right! Those pesky tasks that used to involve hours of work and mountains of paperwork you can now do with a few clicks of a button on your phone.

1. Customizable Inspections with Automated Recurring Inspections: The Jaffa deFINEd app allows you to schedule, perform, and track inspections directly on your phone. It also offers customizable inspection templates, empowering property owners and managers to tailor inspections to their specific compliance requirements. And with the ability to combine inspections and automate recurring inspections, keeping up with all your required and preventative inspections has never been easier.
2. Work Orders Management: With the app’s streamlined work order management feature, property owners and managers can easily assign tasks, track progress, and communicate with their team members who are completing work orders. This automated system ensures that compliance-related work orders are efficiently executed, reducing the chances of errors and delays and ultimately contributing to overall compliance.
3. Safety Mailing Processing: For NYC property owners and managers, safety mailings are a tedious task they must complete once a year. And if the initial job of sending out these mailings isn’t annoying enough, chasing after tenants for their responses makes this one task we all genuinely dread. The Jaffa deFINEd app allows for in-app responses, making it easy to both record your attempts (in the case of those aforementioned audits) and get your tenants’ responses.
4. In-App Support: Because we all need some help sometimes, the Jaffa deFINEd app offers plenty of that. Featuring a complete help section with resources for the NYC property owner or manager, the ability to view open violations on BIS, and an Ask-a-Question button to ask a Jaffa representative your compliance questions, the Jaffa deFINEd makes it easy to get you the help you need. You can even hire Jaffa to resolve your violations for you directly in the app.

 

As NYC property owners and managers continue to be inundated with NYC’s high audit frequency and stringent regulations, the Jaffa deFINEd app has emerged as a powerful and revolutionizing tool. Embracing digital solutions is the key to simplifying NYC property compliance, and through digitizing compliance processes, property owners and managers can focus on delivering exceptional property management services while ensuring full compliance with NYC’s ever-evolving requirements. As NYC’s compliance landscape continues to evolve, adopting digital solutions like the Jaffa deFINEd app is a strategic investment that paves the way for efficient compliance management and success in the property management industry.

Q: I’ve sent out my annual safety mailings with the January rent bill, and I still have not received a response from several tenants. What do I do now?

 

JA: We’re glad you asked! As part of the annual safety mailing process, you are required to make an effort to obtain a response from each of your tenants. If you did not get a response to your initial mailing, you must make additional attempts via phone, email or in person. The good news….if you are using the Jaffa deFINEd app, you can actually make these attempts with mass email/text/robo-calls directly from the app. One button, and you’ve fulfilled you’re requirement. If there is still no response, you will need to inspect their apartments for proof of child(ren) living in the unit. If you cannot get into their apartment, you must document and retain proof of your attempt.

Hold onto this proof for ten years to avoid criminal charges and fines. More good news about the Jaffa deFINEd app, all your attempts can be recorded, stored and created into a report right on your phone.

You’ll also need to notify the DOHMH of all non-responsive tenants and attempts to acquire information as part of the annual safety mailing process by March 1 of the same year.

So, if you’re still waiting on some tenant responses, don’t forget to notify the DOMH before the deadline! Again, using the Jaffa deFINEd app makes this requirement significantly easier to complete.

You can learn more about these requirements with our Jaffa Minute, which provides a quick overview of everything you need to know about your Annual Safety Mailing.

The DOB’s recently made a total of 26 changes for small businesses as part of an executive order to help NY’s small businesses recover from setbacks caused by the COVID-19 pandemic. All new changes take effect on Nov. 20, 2022. As a NYC building owner, you’ll need to know about these changes to the NYC compliance code so you can avoid getting slapped with a violations and incurring a penalty. No worries, though; we’ve done the legwork so you don’t have to. Here’s what you need to know about the recent DOB changes.

Who do these changes affect?

The DOB’s recent changes apply to small businesses. Small businesses, as defined by the DOB, generally refer to businesses that employ fewer than 100 workers. However, in regards to specific requirements and regulations, the definition expands to include more kinds of businesses. As we explore the recent DOB reforms, we’ll note the exact criteria for businesses to which each DOB change applies.

Changes to violation enforcement

As part of the recent changes, the City extended the cure period for all Class 2 (Major) and Class 3 (Lesser) violations from 40 days to 60 days from the date of NOV service. This change will provide more time for named respondents to submit a Certificate of Corrections (COC) and avoid getting hit with a penalty or hearing.

It’s important to note that this change does not apply to Class 1 violations, in which a COC must be submitted immediately. In addition, Aggravated I and Aggravated II penalties are never eligible for a cure.

The DOB will eliminate the following violations:

• Approved Place of Assembly plans not available for inspection (Class 2)
• Failure to conspicuously post electrical work permit while work is in progress (Class 3)
• Place of Assembly contrary to Approved construction documents (Class 2)
• Electrical closet not dedicated to electrical distribution equipment only (Class 2 and 3)
• Failure to provide cover/faceplate/lampholder/luminaire canopy for electrical outlet (Class 2)

The DOB is reducing penalties for the following violations:

• Electrical work without a permit (Class 3)
• Work without a permit (Class 3)
• Failure to post or properly post permit for work at premises (Class 2)
• Change in occupancy/use of C of O as per §28-118.3.1 – §28-118.3.2 by operating a Place of Assembly as per when current C of O does not allow such occupancy (Class 2)
• Luminaires and Lampholders not installed in an approved manner (Class 2)

Most penalty reductions are 50% or more.

There are no qualifiers for differently-sized business in regards to the above in the DOB’s notice. Also, all language extending the cure period for one- or two-family homes have been removed. It is therefore assumed that these changes apply to all named respondents.

Civil penalties for work without a permit

Small businesses may be granted a waiver of civil penalties for work without a permit after demonstrating (as per the DOB’s requirements) that they are a small business. The DOB specifies here that a small business refers to a business that employs fewer than one hundred employees.

High-pressure and low-pressure boilers

Small businesses may now be granted a first-time waiver of penalties for failure to file an annual boiler inspection report for both low-pressure and high-pressure boilers. These penalties are typically seen in the form of LBLVIO and HBLVIO violations, as issued by the DOB.

The penalty waiver applies to small businesses that employ fewer than one hundred employees. Owners can take advantage of the penalty waiver by demonstrating, in the manner specified by the DOB, that they are the owner of the business.

Don’t forget—annual boiler inspections are due by Dec. 31 each year.

There are lots of changes detailed here, but all of them were established to help your business recover from the COVID-19 pandemic. Read the full update on the DOB reforms here.

If you’re still confused about what you need to know, we can help. We’re always happy to work with you and make sense of NYC’s compliance code. Don’t hesitate to contact us today.

8 Reasons You Should Be Digitizing Your Inspection Process

Unless you’ve been living on a different planet, you know that the business world is moving online, one industry at a time. And property management isn’t far behind. Across the City and beyond, dozens of property managers have gone mobile, turning to apps that use cutting-edge technology to make their job easier. Team management, annual mailings, and more are quicker and more efficient when digitized.

While every part of property management is more manageable when digitized, the inspection process, which can be tedious and time-consuming, can significantly benefit from being digitized. It’s time to stop stressing about inspections and go mobile. If you haven’t already made the switch, here are eight reasons why you should.

1. Customized Inspections

Does anything say easier to manage than the ability to customize? You and I both know that with inspections, there isn’t a one form fits all. Not only will inspections vary from property manager to property manager, but what you need to inspect will vary unit to unit. So why would you want to deal with tons of paperwork that has nothing to do with YOUR inspection.

Plus, there are so many times that your inspection is not just for one purpose.  After all, why would you visit the same apartment multiple times for multiple inspections if you don’t have to? Apps such as the Jaffa deFINEd app allow you to customize your inspection on their platform so you can choose what inspections you are performing and what information you need included. You can find out more about the Jaffa deFINEd app HERE.

With the Jaffa PredeFINEd Inspection module, you can even create, track and document preventative tasks and inspections on your properties and devices, such as inspections for elevators, boilers, backflow, sprinkler, water towers, cooling towers, HVAC systems, and so much more.

The app also allows you to customize the frequency of inspections, so you can enter precisely how often you need or want to inspect each item.

With the ability to customize the inspection according to YOUR needs, apps allow you to create in-app inspection forms that have everything you need to inspect without anything you don’t need.

2. Never Miss a Step in the Inspection Process

Your team is in the process of completing an inspection, and it’s Bob’s turn to do his job. There’s just one issue: Bob is out on sick leave, or maybe he’s sunning himself on a beach in Cancun. And no one knows the exact details about Bob’s role in the inspection process.

Digitizing your inspections means that every step of the process is clearly detailed and accessible to all team members. When one or more team members are out, you can still get the job done perfectly and on time, too. How’s that for a hassle-free inspection?

3. Communicate with Your Team throughout the process

You’ve got enough on your plate without being on-site at every building, all the time. And when you digitize your inspections, you no longer need to. When your team runs into a hurdle while getting a job done—and they will—they can instantly reach out to you and update you on the latest. You can view their progress on an app. Or, better yet, with apps such as the Jaffa deFINEd app, which automatically syncs their app with their online portal, you can even check the status, pictures, or files your team in the field has uploaded without even leaving your desk. Using an app, especially one integrated with a more comprehensive online portal, can help keep your entire team in the loop about the next step with one quick communication.

Playing phone tag is so last year. 2022 is all about instant communication and easily shared data, files, and images.

4. Instantly Record and Track Inspections

Do you spend half your workday searching for important files and forms? If you’d made the change to a digitized property management app, you wouldn’t have to. When your management is digitized, every filled-out form and captured photo is instantly recorded, tracked, and organized in your platform. There’s no longer a need to search through piles of papers to pull up the one you want; your tech tool will do the job for you with just a few swipes.

Plus, some property management apps, like the Jaffa deFINEd app, allow you to perform inspections directly in the app, so there isn’t any paperwork to fill out, file, scan, or find. That’s definitely saving you a lot of time, stress, and heartache.

Even more incredible, the Jaffa deFINEd app complies all the date from your inspections and auto-prepares all required city forms for a truly 1-step inspection process. These customized (there’s that magic word again) forms (you can check them out HERE) help you file your inspection reports with complete ease and assurance that nothing has been left out of your report.

5. Centralize Operations for Optimal Oversight

Managing a large team of employees is always challenging. When those employees are spread across several sites, proper oversight becomes next to impossible.

Again, it’s the mobile management model to the rescue! When operations are centralized in one online platform, checking on a team member’s work is a matter of a few swipes—and employee management is easy again. You can check up on anyone at any time and review and appraise all kinds of jobs as they’re being completed in real-time.

When your team is working through a multi-step inspection process, centralized oversight is key to its success. Nothing can fall through the cracks when it comes to inspections. With a digitized process and employee oversight at your fingertips, it doesn’t.

6. Get More Work Done, Anywhere and at Anytime

Insomnia got you tossing and turning at 3 a.m.? Stuck on the train for a half-hour ride in rush hour traffic? Instead of battling with frustration over the wasted time, you can use the opportunity to get some work done! Review and approve recent inspections, communicate with team members about an ongoing job, or simply look over your schedule for the next month or week to see what’s coming up on the compliance calendar.

When your office is in your pocket, you can get work done anywhere and at any time.

7. Ease of Use

Some inspection forms can seriously put a cramp in your hand for all the writing you need to do. With an in-app inspection, many tasks are as easy as pressing yes or no to the provided questions. Plus, the ability to take pictures in the app, obtain signatures, and upload files, allow you to easily have all the information right where you need it.

8. Everything is Going Digital

There’s no denying it. The world is going digital. And in the world of property management, it’s no different. Some of the biggest property managers firms have already switched to mobile management and are enjoying the benefits of a quicker, more streamlined inspection process. Our clients already on the app are blown away by how much the apps’ capabilities are making their compliance, especially inspections EASIER, BETTER & LESS STRESSFUL.

If you’re ready to digitize your compliance management, ask a Jaffa representative about the Jaffa defined app or DOWNLOAD it today. Want to see how our app works? Check out our Video tutorials HERE for a quick run-through of all the Jaffa deFINEd features and functions

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

You can download the Annual Report form HERE and Affirmation of correction HERE.

NEW ELEVATOR DEADLINE

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.

LOW-PRESSURE	HIGH-PRESSURE
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 via hpboilers@buildings.nyc.gov at 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 electrical equipment 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*	$250/month	$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.