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Natural Gas System Inspections Definitions

Has all the recent talk about LL 152 Gas Inspections, Pre-Inspections (Non-Statutory Inspections), Utility Conducted Jurisdictional Inspections and Utility Recommended Inspections left you in a state of confusion?

Do you find yourself asking:

What are the differences between these inspections?
What do I have to do and why should I do it?
Who do I need to contact?

See below for clarification on what each inspection is and why it is recommended.

Please submit all questions to The Par Group’s dedicated LL 152 email address,
Par would be happy to provide you with more information and answers to all of your questions.

Natural Gas System Inspections Defined

LL 152 2016

Local Law 152 of 2016 requires the inspection, reporting of defects and correction of those defects for all natural gas systems installed within buildings in the City of New York.  It also requires that all buildings that do not have gas service be certified as such by a Licensed Design Professional.

In NYC all Local Laws are accompanied by rules which dictate the enforcement parameters.  Although Local Law 152 became effective in January of 2019, the final rule was not published until 9/23/19.

In the final ruling,  the year of the first required inspection(s) is determined by the community board in which each property is located; the inspections will repeat on a four-year cycle.  The first cycle is 2020 – 2023 and repeats every four years thereafter.

Pre-Inspection (Non-statutory Inspection)

A Non-statutory inspection is the same gas safety inspection that we have always done.   With the enactment of LL152 and the publication of the final rules, we have added the “Non-statutory” moniker to the title.  This distinguishes a non-statutory safety inspection from that required by law.  The other main difference is that the Non-statutory is strictly visual and is conducted on accessible pipe and equipment located in common areas.  The criteria for this inspection, like that required by LL 152, includes utility defined “abnormal operating conditions”.  A combustion gas indicator (CGI or “Sniffer”) is not utilized unless specifically requested by the customer.

Just like any gas inspection, identification of any severe hazard or leak requires us to contact the utility company.

Our inspectors are Operator Qualified (Tasks 86 & 87); they are participants in a DOT drug testing program and are certified to perform repairs on both jurisdictional and non-jurisdictional pipe.

Utility Jurisdictional Inspection

The utilities have been ordered by the Public Service Commission to conduct a baseline inspection of all jurisdictional pipe in their service territories.  This is defined as all pipe up through the outlet of customer’s meters.  In NYC, where meters are located indoors, this means that Con Ed may contact you to arrange an inspection of the jurisdictional pipe from the head of the service valve through the outlet of all meters.  They will not inspect any other pipe within the building.  Currently, this is separate and distinct from LL 152 inspections.  The plumbing industry is working with the utilities to include this inspection within the scope of LL 152 inspections, in order to limit the inconvenience to building owners and managers.

Utility Recommended Inspection

You may have received a letter from your utility company stating that they recommend that a safety inspection of your natural gas system be conducted yearly and that you should contact a licensed master plumber for this inspection.  They are doing this under order from the Public Service Commission to recommend these yearly inspections. This work is covered by our non-statutory Inspection service, as defined above, and is voluntary.