Q: Are there any new regulations I have to worry about for the new year?

JA: I’m glad you asked. Because what would a new year be without new regulations, right?

So here are some new laws you have to worry about for 2024.

1. New Parapet Inspections
2. New Penalties for Failure to File a Statement of Registration
3. New XRF Inspections – Okay, this one is technically not new for 2024, but with a deadline in 2025, you better start worrying about these inspections NOW.

Which brings me to something else that is new for 2024!

New regulations also mean new services from the Jaffa team. So, now we are providing the following services, helping you stay compliant no matter what the new year brings.

1. XRF Inspections
2. Parapet Inspections
3. TPP Inspections

For a quick review of everything new (and old) in 2024, check out our compliance calendar, which includes a list of all your deadlines, a to-do list of compliance tasks, and a synopsis of all your new requirements. You can view it online or download and print it as a reference throughout the year.

Q: Is it true that I have to inspect my parapets?

JA: Great question, and right on time. Starting in January 2024, all buildings with parapets fronting the public right-of-way, regardless of height, must have their parapets inspected to identify and correct hazards. 

The only exceptions to this new law are detached 1- or 2-family homes or buildings with a fence or other barrier preventing access to the exterior wall.

The good news? Jaffa Permit Service will be offering Parapet inspections under the supervision of our in-house architect, Jeff Akerman. You can reach out to the head of our Permit Services, Chase, with any questions or to schedule your inspection.

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.

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.

Collecting Dust: Lead Dust Standards to Change This Year

As a property owner, it’s always important to be informed and up to date on laws and regulations to ensure that you remain in compliance and to protect the occupants’ safety and health. With NYC’s laws constantly in flux, it’s even more vital to stay in the loop at all times.

According to a proposed law that is scheduled to go into effect at the end of this year, lead-based paint standards may be changing in the near future.

Under Local Law 66 of 2019 by the Department of Housing Preservation and Development (HPD), the new standards are defined as:

• Paint will be considered lead-based at a level of 5 mg/cm² (formerly defined as 10 mg/cm²)
• Lead dust wipe standards have been lowered, effective June 11, 2021, to:
  • 5 ug/ft² on floors
  • 40 ug/ft² on windowsills
  • 100 ug/ft² on window wells
• Lead-free exemptions issued based on the older definition (1.0 mg/cm²) will be revoked at turnover on or after December 1, 2021; new exemptions must be requested
  • Owners may submit exemption applications according to the current definitions until March 1, 2022 only if
    • Testing was performed prior to December 1, 2021 and
    • Unit turnover will not occur prior to March 1, 2022
  • Lead poisoning levels in children have been lowered from 10 ug/dl to 5 ug/dl as per the CDC’s definition

The law will not go into effect until December 1, 2021

Additionally, August 9, 2021 marks one year since the implementation of Local Law 31 of 2020. All XRF Unit Inspections must be completed within the next four years.

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