The 10 Days of Compliance have officially come to a close, so it’s time to recap our annual quiz! Here are the answers to the 2023 annual compliance quiz, complete with explainers & helpful resources.

Question 1: December 31st, 2023 due dates

We gave 9 choices with a possible due date of 12/31/23 – here’s what’s correct, and what’s due by the end of 2023:

• Annual boiler inspections – Due each year on December 31st.
• Periodic elevator inspections – These are also due each year by the end of the year.
• Local Law 84 Benchmarking – Benchmarking isn’t due until after the year is complete. Properties have until May 1 of the following year to submit Benchmarking information for the full calendar year. So this year, it’d be May 1, 2024 for 2023 data (with quarterly fine deadlines after that for any missing filings).
• Parking garage inspections for subcycle A – This is true: the first subcycle of parking structure inspections is due at the end of 2023. This first cycle of parking structure requirements has a lot going on, so check out our infographic breaking it down here.
• Water tank inspections – Water tank inspections are due on January 15th each year for the preceding year – not quite December 31st.
• Local Law 87 for “Block #4 buildings” on the covered list – Close, but no cigar: buildings due on December 31, 2023 have a block number ending in 3, not 4. This group of buildings will be due on December 31, 2024.
• Elevator CAT 5 inspections – This one’s tricky. Category 5 inspections aren’t uniformly due at the end of the year, though some of them may be due on December 31st depending on the month of their installation/last CAT 5. Here’s the specific text of the law:
  • Category 5 tests shall be performed every five years on or before the month of the final acceptance test for new elevators or the anniversary month of the last Category 5 testing
  • Don’t forget – the number of days to submit periodic tests was reduced a few years ago from 60 to 21 after the inspection date.
• Bedbug reports – These are due at the end of the calendar year. In order to make that date, bedbug information goes up to October 31st, 2023, and next year’s filing (2024) will start with information beginning from November 1, 2023. That pattern repeats every year.
• Local Law 152 for subcycle D – This year marks the end of the very first full cycle of gas piping inspections (another question in the quiz!) Next year, we start all over again with the second filing for subcycle A – Community Districts 1, 3, and 10.

Question 2: Early parking structure observation

In addition to the first set of parking structure due dates, structures in subcycles B and C are required to submit an early one-time observation (annual observations typically have to be performed, but not filed) by August 1, 2024.

If your structure is in subcycle B, you may elect to perform and file the full inspection ahead of that date. It’ll satisfy both the early observation requirement, and the filing requirement (due for this group on December 31, 2025). If your structure is in subcycle C, you’ll have to file the one-time early observation plus the full inspection, done between 1/1/26 – 12/31/27.

Don’t forget to check out our infographic – it’s a handy way to remember all the above.

Question 3: Parapet observations

The new requirement for parapet observations goes into effect in 2024. As of now, parapet observations have to be performed and recorded annually. They do not have to be filed with the DOB. That said, the DOB can request records at any time.

You can assign, track, and store parapet observations using Compliance Manager. Reach out to your Customer Success Manager or support@sitecompli.com to learn more.

Question 4: HPD penalty increase

HPD revamped penalties recently (check out our blog post here reviewing the changes).

One of their biggest changes was adding daily penalties for Class A violations, which are now $50 – $150, plus $25/day.

Question 5: Which Agency Saw A Violation Count Drop?

We ran the numbers for 2022 and the first half of 2023 (you can see them here, in our report), and the DOB is the only agency that saw a drop in violations year-over-year…so far. We’ll take another look in 2024, and will report back to see how the year turned out.

Question 6: Local Law 132 covers what lead-related changes?

A number of new laws related to lead are going into effect in 2024 and beyond. Local Law 132 specifically touches on record production requirements for violations and friction surface abatement (by July 2027, or dependent on the knowledge of a child in a unit).

Learn more about the latest HPD-related local laws here, in our roundup from December 2023.

Question 7: 2023 marks the end of which law’s first full cycle?

After some extensions at the beginning of the cycle, the first full cycle of Local Law 152 (gas piping inspections/certification) is coming to an end. What’s next? The second round of inspections and certifications for subcycle A – Community Districts 1, 3, and 10, as shown on the DOB’s site.

Question 8: Curbside composting

Barring any future changes, DSNY’s curbside composting program will be officially rolled out to all boroughs in October 2024. This program ties into mandatory source separation, along with other Sanitation requirements. You can learn more about what’s available in your borough here, on their website.

Question 9: DOHMH violations

Per our report, Manhattan far and away had the highest number of DOHMH violations tied to OATH tickets this year. We’ll see how things finalize once the year is over, but DOHMH trends were unique compared to some other agencies.

Question 10: What’s the newest HPD enforcement program?

The program is so new, it’s not even on HPD’s website yet.

A new program will require HPD to annually select 300 buildings for inspections of self-closing doors. Criteria for inclusion varies, but will also be selected “in consultation” with the FDNY. Stay tuned for more updates here as this program goes into effect.

Just because the 10 Days of Compliance are over doesn’t mean compliance education stops! We’ll be here for your team in 2024, sharing the latest updates, best practices, and new features for taking action on NYC local laws.

See you in the new year!