March 31, 2019 – Late Fees & Violations

Service follow-up #6 outlined an update for Category 5 inspections that were completed more than 6 years after the last filing. Per the Notice, it’s now possible to file these reports via DOB NOW: Safety. That said, DOB NOW: Safety will not accept Category 5 inspection dates older than one year from the filing date: “For example, if a filing is submitted on January 15, 2019, the oldest inspection date that can be entered is January 15, 2018.”

All reports due in 2018 need to be submitted before March 31, 2019 – that’s the original grace period date listed in follow-up #4 for ELV3 and ELV 29 filings. The DOB previously announced that in an effort to facilitate the transition to electronic submissions, filings submitted before this date will not be subject to late fees. Follow-up #6 states that “If the required report is not filed by March 31, 2019, the device will be subject to a violation for failure to file.”

Based on this update, it’s important to ensure that any outstanding reports for your devices are currently in process or ready to be submitted by that date at the absolute latest. Have a conversation with your elevator vendor & consultant to review progress – and check your SiteCompli account to confirm the status of submitted reports.

Please also note that submitting reports is different than performing inspections – while reports can be submitted through the date as listed above, 2018 inspections cannot be performed in 2019.

Filing Dates, Updates, and Exceptions

• ELV3 reports can now be filed without a witnessing agency (for specific circumstances outlined in Appendix K, Table N1 of the Building Code) – read more in follow-up #5
• The deadline for resubmissions of ELV3 reports and ELV29 Affirmation of Corrections for 2017 & prior year reporting cycles is extended to June 30th, 2019. After this date, any violations for failure to file/failure to submit AOCs (EVCAT1 & ACC1) will not be dismissed upon resubmission. You can see the full announcement here in follow-up #3.

DOB NOW: Safety Resources

• Here’s the main page for DOB NOW: Safety Elevator Resources
• The DOB has created a Help Form for online submissions.  Per the form, most inquiries will receive a response by email within one business day.

2018 is almost at an end – make sure your team is in contact with your elevator vendor & consultant regarding last-minute or outstanding submissions.