Cars in a parking garage

Changes to NYC Parking Garage Inspection Rules

An amendment to the NYC Rules requires every parking garage in New York City to undergo an initial inspection before August 1, 2024, even those that originally weren’t due for another three years.

Recap of Local Law 126

In brief, New York City passed Local Law 126 in 2021, which updated the Rules of the City of New York (RCNY) to require periodic inspection, repair, and report filing for all parking structures, at least once every six years. Inspection filing windows were set up in staggered subcycles, much like those of the New York City Facade Inspection and Safety Program (FISP). Garages in lower Manhattan (Community Districts 1-7) have the earliest deadlines, with a filing window from January 2022 through the end of this year (Subcycle 1A). Subcycle 1B opens in January 2024 and ends December 31, 2025; it encompasses the remaining districts in Manhattan, as well as Brooklyn. The Bronx, Queens, and Staten Island fall in Subcycle 1C, which doesn’t begin until January 2026 and closes at the end of 2027. For a color-coded map of these subcycles, along with the full requirements of the parking garage inspection rules, see “How to Comply with NYC Local Law 126 Parking Garage Inspection Rules,” issued October 2022.

To carry out these parking garage inspections, the rule established a new credential, Qualified Parking Structure Inspector (QPSI), which the NYC Department of Buildings (DOB) issues to licensed engineers with at least three years of parking structure experience who pass a formal certification process. As part of the periodic evaluation, the QPSI creates an Annual Observation Checklist with elements to be inspected each year between inspection cycles. In the filing report, garage conditions are categorized as Safe, Unsafe, or Safe with Repairs and/or Engineering Monitoring (SREM). Unsafe conditions must be corrected within 90 days, and SREM conditions need to be addressed within the timeframe set by the QPSI, with a follow-up condition assessment and amended report filing within three years.

Amendments to the Rule

On October 17, 2023, the DOB adopted a new rule, effective November 23, 2023, that makes important changes to the parking garage inspection requirements.

Initial Inspections Due August 1, 2024 for All Garages

For garages not slated to have an inspection until 2024 or as late as 2027, concerns that potentially unsafe conditions could go unnoticed for years led the DOB to mandate an additional, earlier inspection. Under the new rule, all garages must undergo an initial inspection no later than August 1, 2024. For parking structures in Subcycles 1B and 1C, this means a one-time initial inspection in addition to the regularly scheduled inspection during their filing cycle.

With Subcycle 1B starting January 1, 2024, owners of garages in upper Manhattan and Brooklyn are exempt from this extra initial inspection if they file an acceptable parking garage Compliance Report before August 1, 2024.

While not as prescriptive as the requirements for a standard Compliance Report, rules for the Initial Report stipulate that a QPSI must assess the parking structure’s condition, including evaluation of structural components, waterproofing systems, fireproofing/fire stop systems, and wearing surfaces. The rule reiterates that the QPSI’s observation must consider the garage’s age, type of construction, exposure, and appurtenances, as well as the history of maintenance and repairs. Examinations should focus on areas the QPSI finds deleterious and identify the probable cause of observed deficiencies. If the QPSI finds any Unsafe conditions during the initial inspection, they must immediately notify the owner and the DOB.

While the format and contents of the initial observation report are not explicitly stated in the amended rule, they are to be “in a form and manner acceptable to the commissioner,” and so likely conform to the basic elements of the report requirements laid out in RCNY §103-13 (c)(3).

An engineer inspecting a parking structure
Evaluating concrete damage in a parking structure

In the initial inspection, the QPSI must assess the garage's condition, including structural components, waterproofing systems, fireproofing/fire stop systems, and wearing surfaces.

Annual Inspections by QPSI

Part of the QPSI’s responsibility in preparing the periodic inspection reports is to develop an Annual Observation Checklist. Originally, these annual observations were to be completed “under the direct supervision of the owner or by a competent person.” However, the DOB revised the rule to stipulate that, like the formal periodic inspections, annual observations must be conducted only under the direction of a QPSI. Owners must now retain a certified QPSI not only for inspection, repair, and reporting during the six-year filing cycles, but also to complete the Annual Observation Checklist every year between reporting periods.

QPSI Qualifications

In what is likely an effort to expand the number of professionals able to carry out parking structure inspections, the DOB also updated the definition of Qualified Parking Structure Inspector. The new rule allows engineers with three years of relevant building structure experience to qualify for QPSI certification, overwriting the previous stipulation that candidates be specifically experienced with parking garages. A formal certification process is still required.

Action Plan

The addition of initial inspections prior to August 2024 will likely leave many garage owners scrambling to meet a deadline that could be as much as three years earlier than anticipated. Although the DOB seems poised to meet this demand by applying broader criteria to QPSI certification, the process for obtaining the credential is still lengthy, so newly credentialed QPSIs may be few and far between. Prudent owners would do well to retain a QPSI well ahead of the August deadline. For those with garages in Subcycle 1B, doing so will also avoid having to file multiple reports, as an acceptable Compliance Report filed by August 1, 2024 obviates the need for a separate, initial observation.

As part of the garage inspection program, establish a plan with the QPSI for the required Annual Observations. Now that the DOB mandates QPSI supervision for this yearly requirement, getting a QPSI on board ahead of time not only assures they will be available when it’s time for the Annual Observation, but also eliminates the hassle of remembering to fulfill this routine obligation. With a bit of planning, even these new requirements shouldn’t be too onerous, and, done right, they can support a robust maintenance program that prevents hazards and extends the life of the garage.

Close-up detail of pencil pointing to parking garage plan
Probe at parking deck with measuring tape

Regular evaluation and repair of parking garages prevents safety hazards and extends the lifespan of the structure.

Hoffmann Architects + Engineers was among the first to have a certified QPSI. We are one of a select few currently authorized to carry out NYC Local Law 126 parking garage inspections.

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Material provided is for informational purposes. Before taking action, consult a design professional.