The Department of Buildings (DOB) is proposing a new rule (§101-18) that would allow the New York City Department of Parks and Recreation (DPR) to perform specific types of plumbing and construction work without a permit. Their stated reason for this change is so that the work can be completed more quickly while maintaining public safety.
The proposed work scopes related to plumbing are:
1.Site storm water drainage systems. Site storm water drainage systems, including manholes and catch basins that do not require a Department of Environmental Protection permit.
2.Replacement in kind of domestic hot water systems.
3.Replacement and reconfiguration of plumbing fixtures.
We oppose this rule.
This proposal has the potential to harm public safety. The DOB’s mission is to promote worker and public safety through its review and approval of building plans, permitting, licensing functions, and inspections. By removing the permit requirement, the DOB will not be aware this work is taking place. They lose the ability to ensure the work is done in compliance with the Code by a qualified employee of a licensed plumbing company. The purpose of the NYC Construction Codes is to provide a reasonable minimum requirements and standards for the regulation of building construction in the interest of public safety. Selectively removing one section of the Code (permits) for “convenience” essentially removes other sections (inspections, oversight and enforcement) and can endanger public safety. Allowing DPR to design, build and self-inspect projects is a recipe for disaster. Codes only work when all sections of a Code are followed.
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