August 1 Filing Deadline is Four Months Away
Arising from a tragic incident in lower Manhattan, New York City’s Initial Observation Inspection requirement, enacted in addition to the Periodic Inspection of Parking Structures (PIPS) program, reflects the city's dedication to improving safety standards in parking facilities. In this FAQ, we delve into the specifics of this requirement, addressing common inquiries regarding compliance and procedural aspects, to help you keep your parking structure in compliance with the upcoming August 1 deadline.
Frequently Asked Questions: Periodic Inspection of Parking Structures (PIPS) - Initial Observation Requirement
What is the Initial Observation requirement?
The Initial Observation mandate, outlined in rule 1RCNY §103-16, requires owners of parking structures within designated Community Districts to have a single comprehensive visual observation of their structures by August 1, 2024. This requirement was established in response to the fatal garage collapse in lower Manhattan last April.
Who is required to comply with the Initial Observation requirement?
Owners of parking structures located in Manhattan Community Districts 8, 9, 10, 11, and 12, as well as all Community Districts in Brooklyn (Sub-cycle 1B), Queens, Staten Island, and the Bronx (Sub-cycle 1C).
Who can perform the Initial Observation?
The Initial Observation must be conducted by or under the direct supervision of a New York State licensed Professional Engineer (PE) designated by the Department of Buildings (DOB) as a Qualified Parking Structure Inspector (QPSI).
What does the Initial Observation entail?
The QPSI must assess the condition of the structural components, waterproofing systems, wearing surfaces, fireproofing and fire stopping systems, as well as areas directly above or below the parking structure. Visual inspection of 100% of these elements may suffice, unless deficiencies observed warrant further investigation, in which case the QPSI must employ an inspection program that permits a complete examination to determine the cause of the defects. The QPSI also is responsible for filing an Initial Observation Report with the DOB.
What is the difference between the Initial Observation and the DOB’s Periodic Inspection of Parking Structures (PIPS) Program?
The Initial Observation Report is a one-time requirement focusing on immediate safety concerns. In contrast, PIPS inspections, required by Local Law 126/01, are recurring assessments conducted every six years to ensure ongoing compliance and safety. These periodic inspections are more comprehensive, covering structural components and safety systems, and their results are documented in a Condition Assessment Report submitted to the DOB. For more information on PIPS compliance, see our PIPS Fact Sheet.
If I already had a PIPS inspection filed for my Sub-cycle 1B garage, do I still have to comply with the Initial Observation requirement?
Buildings in Sub-cycle 1B are exempt from the Initial Observation requirement if they have a full PIPS report filed before August 1 of this year.
What if I have not yet had my Sub-cycle 1A garage inspected? Do I need an Initial Observation performed?
Parking structures in Sub-cycle 1A require submission of a complete Periodic Inspection of Parking Structure (PIPS) report as soon as possible, not an Initial Observation Report.
What happens if an Unsafe condition is found during the Initial Observation?
If an Unsafe condition is discovered, the DOB must be immediately notified, and appropriate protective measures taken as recommended by the QPSI.
Once a building has an Unsafe status, owners must either complete required repairs to correct all Unsafe conditions within 90 days, or submit an extension request to the DOB where 90 days is not a sufficient amount of time to complete the work.
Contact RAND
With the deadline looming, it's critical to act swiftly. Given the high demand for Initial Observation Inspections, we recommend scheduling your inspection as soon as possible to meet the deadline. RAND’s Structural Team QPSIs can assist garage owners and managers in navigating these critical processes. Our structural engineering services for parking structures include:
- PIPS/Local Law 126/01 inspections and Initial Observation Inspections conducted by experienced QPSIs
- Compliance assistance to ensure adherence to regulations
- Comprehensive parking garage inspections to identify structural issues
- Customized repair programs tailored to address specific maintenance needs
- Structural assessments and maintenance recommendations
- Emergency inspections for structural failures or urgent situations
- Damage assessment and repair services following emergencies or natural disasters
To schedule an inspection or consultation regarding your property, contact us at (212) 675-8844 or info@nullrandpc.com. We look forward to speaking with you.
Additional Resources for Compliance and Garage Maintenance:
- Periodic Inspection of Parking Structures (PIPS) Fact Sheet
- Maintenance Best Practices for Parking Structures
- Ask the Engineer: Garage Repairs
- New York State Parking Garage Inspections Fact Sheet
