Emergency Planning Punch List provided by the Office of Emergency Management Spring 2020

The Office of Emergency Management has provided the following punch list to help residential building owners ensure that they have followed all City requirements as well as best practices in preparing building staff and residents for any emergency. The punch list includes information from and links for the Fire Department, the Department of Housing Preservation and Development and the Office of Emergency Management.

 

Published: Fall 2019

THE FIRE AND EMERGENCY PREPAREDNESS GUIDE, CHECKLIST AND NOTICES Amendments Effective NOVEMBER 15, 2019

Since 2018 buildings have been required to distribute a Fire and Emergency Preparedness Guide (“FEP”), entitled “NYC Apartment Building Emergency Preparedness Guide.” This Guide replaced the Fire Safety Guide and includes information on how to handle all emergencies, not just fires. The Guide consists of several parts and a checklist, including:

• The Building Information Form,  a one-page form that describes the building’s construction, fire protection systems, means of egress, and whether there is an emergency voice communication system in the building.
• The NYC Apartment Building Emergency Preparedness Guide is designed to educate building occupants how to prepare for and protect themselves in the event of ANY type of emergency. It also aims to facilitate emergency preparedness planning for individuals unable to evacuate the building independently; It explains how to develop individualized evacuation plans and form a network of support for assistance if necessary.
• The Individual Emergency Preparedness/Evacuation Planning Checklist is designed to help residents design their individualized emergency plans, with a focus on those who are likely to be housebound in an emergency.
• The Fire and Emergency Preparedness Notice, which tells residents when and how to evacuate a building based on whether they are in a non-combustible or a combustible building.
• An Annual Bulletin which the Fire Department will provide to ensure that the Emergency Preparedness Guide remains current

The Guide, Form, Checklist and Notices must be distributed as follows:

• The Building Information Form, Checklist and Annual Bulletin must be distributed building wide annually, either with the window guard notices in January or in October (Fire Safety Month) by itself.
• The Guide and the FEP Notice must be distributed building wide every three years, at the same time that the building distributed the Building Information Form and Checklist.
• The Guide, Building Information Form, Checklist and Notices must be distributed to apartment  residents at time that they first move into the building.  
• Additionally, an initial distribution of the Checklist and Annual Bulletin must be done by April 30, 2020, either with the rest of the documents (if distributed in January) or as a standalone.
• The documents may be distributed electronically (by e-mail or other electronic transmission) to residents and building staff that have provided e-mail addresses for the purposes of receiving building communication. The Building Information Form must by posted in the lobby annually.

In addition to the above, buildings must post a “Close the Door” Sign on the public hallway side of stairwell doors as part of the amendments issued in 2019. Specific wording and visuals for the sign are part of the regulation.

 

PERIODIC INSPECTIONS OF GAS PIPING SYSTEMS
Effective October 23, 2019

LL 152 of 2016 requires buildings to visually inspect all exposed gas piping and perform checks for gas leaks. The DOB finalized and adopted the rules regulating the inspections October 23, 2019. They are as follows:

• Inspections shall be performed and filed once every four years, according to the following schedule:
  

Buildings in Community Board Districts 1, 3 and 10 2, 5, 7, 13 and 18 4, 6, 8, 9 and 16 11, 12, 14, 15 and 17

Must File Between January 1, 2020 and December 31, 2020 January 1, 2021 and December 31, 2021 January 1, 2022 and December 31, 2022 January 1, 2023 and December 31, 2023

• Inspections must be done by a qualified gas piping system inspector
• Any necessary corrections must be performed and reported within 120 days of the initial inspection
• Buildings without gas piping must file a certification prepared by a Registered Design Professional stating that the building contains no gas piping and file their statement once every four years during the year before their inspection would be due.
• Buildings that fail to file in a timely fashion may be subject to a $10,000 fine

Additionally, the NYS Public Service Commission inspection requirements from 2015 mandate that gas utility providers perform a visual inspect of exposed gas piping up to the outlet of all gas meters and perform a gas leakage survey at each site on a three-year basis. Con Edison has hired Precision Pipeline Solutions to perform the inspections. Customers are required to grant access to Precision Pipeline Solutions and allow them to perform the mandated inspections.

 

LEAD PAINT REGULATIONS AND METHODS OF ENFORCEMENT

In 2019 the Department of Health amended Local Law 1 of 2004 to bring NYC’s lead paint regulations in line with new guidelines mandated by the EPA. For buildings built before 1978 the amendment to the regulations will:

• Change the definitions of “lead-based paint” and “lead-contaminated dust” to meet new EPA and HUD standards which reduce the percentage of lead allowable in both intact paint (as tested by X-Ray Fluorescence machines) and dust (as tested by wipes). The reduction in acceptable levels in “lead-contaminated dust” has taken affect, and will determine whether or not areas are considered clean following both abatement projects and general renovations. HPD is in the process of issuing rules for implementing the new standards for “lead-based paint” which will take effect after April 2020.
• Require buildings to modify their annual lead paint notices and forms, so residents understand that any child under the age of 6 who spends more than 10 hours a week in an apartment is considered to “reside” there for Local Law 1 purposes.
• Ensure that buildings are collecting and maintaining the annual lead paint notices through HPD audits, fines for failure to produce records, and requiring certification by buildings as part of the property registration process.
• Ensure that buildings are complying with the requirement to have renovation, repair and painting work that disturbs more than 6 sq. ft. of paint per room done by EPA Certified Contractors through increased oversight. This includes work done by building employees.
• Restructure the exemption process whereby buildings can be declared “lead paint free”