Title 19 compliance: Essential guidance for parking garage owners in New York State

If you own a building containing a parking garage in New York State, compliance with Title 19 of the New York Codes, Rules, and Regulations (NYCRR) is not just a legal requirement—it’s a crucial step in ensuring the safety of your structure, tenants, and visitors. As the state continues to enforce inspections to mitigate structural failures, all parking structure owners must be proactive in meeting these obligations.
This article will guide you through the essential aspects of Title 19, including the definition of a parking garage as per the law, required inspection timelines, key compliance details, and why obtaining a professional engineering assessment is critical.

Understanding the Definition of a Parking Garage Under Title 19

The law defines a parking garage as any structure, or a portion of a structure, used for parking or storing motor vehicles. This applies to both open-air and enclosed garages and includes both standalone facilities and garages integrated into a larger building.
Under Title 19, different types of parking structures may fall under this classification, including:

• Multi-level parking decks.
• Underground parking garages.
• Podium parking levels within residential or commercial buildings.
• Open-air parking structures that have structural framing elements.

Exclusions: Some small-scale or private garages—such as those accessory to a single-family or two-family home—may not be subject to the same stringent requirements. Additionally, if the parking area of the building sits on grade it would be exempt. Owners should consult an engineer familiar with Title 19 to determine the applicability.

When and How Often Must Parking Structures Be Inspected?

Title 19 mandates that periodic inspections must be conducted by a licensed professional engineer. The frequency of these inspections depends on when the garage was constructed or last inspected.

• Initial Inspection Deadlines:
  • Garages constructed before 1984: First inspection was required by October 1, 2019.
  • Garages constructed between 1984 and 2002: First inspection was required by October 1, 2020.
  • Garages constructed between January 1, 2003 and August 28, 2018: First inspection was required by October 1, 2021.
  • Garages constructed after August 29, 2018: First inspection is required after construction but prior to a certificate of occupancy or certificate of compliance being issued for the structure.
• Ongoing Inspections:
  • All garages must be inspected at least once every three years after their initial report is filed. The engineer conducting the inspection may require more frequent inspections if there are potentially unsafe items found.

Failing to comply with these inspection cycles may result in fines, citations, and even closure orders from local building authorities.

What Happens During a Parking Garage Inspection?

A licensed professional engineer must conduct a thorough structural assessment and file a formal inspection report. The key elements of this inspection include:

1. Visual Inspection:
   • Review of concrete or steel deterioration, corrosion, cracking, and spalling.
   • Identification of drainage issues that may contribute to structural degradation.
2. Load-Bearing Evaluation:
   • Assessing the condition of beams, columns, slabs, and connections.
   • Identifying signs of stress or fatigue that could compromise structural integrity.
3. Water Infiltration and Protection Measures:
   • Identification of water damage and leaks that may cause structural degradation
   • Evaluation of waterproofing membranes, expansion joints, and sealants
4. Compliance with Previous Reports
   • Verification that previously recommended repairs have been completed
   • Identification of new issues that may have developed since the last assessment

After each inspection, the licensed professional engineer must submit a written report to the local code enforcement official. The report must:

1. Detail the current condition of the structure.
2. Identify any deficiencies or hazardous conditions.
3. Provide a recommendation for necessary repairs.
4. Specify a timeline for corrective actions.

Garage owners must also maintain the following records:

1. Copies of all inspection reports.
2. Documentation of completed repairs and maintenance.
3. Records of past assessments for reference in future inspections

These records must be available for review by local building authorities upon request.

Why Should Parking Garage Owners Prioritize Compliance?

Ensuring compliance with Title 19 is not just about meeting regulatory obligations, it’s about safeguarding your investment and protecting the public. Here’s why:

1. Preventing Structural Failures
   • New York’s enforcement of Title 19 was prompted by serious collapses and structural failures in older garages. Water infiltration, corrosion, and unaddressed damage can lead to catastrophic failures if left unchecked.
2. Avoiding Costly Fines & Liability
   • Failing to comply with the parking garage inspection requirements can result in serious legal and financial consequences, including:
     1. Fines and Penalties – Owners may face fines imposed by local code enforcement authorities.
     2. Enforcement Actions – Local governments can issue violation notices requiring immediate corrective action.
     3. Closure Orders – If a structure is deemed hazardous, authorities can restrict access or close the garage until necessary repairs are completed.
     4. Liability Risks – Owners may be held legally responsible for injuries or damages resulting from structural failures.
3. Extending the Life of Your Structure
   • Proactive maintenance—guided by regular inspections—helps prevent expensive emergency repairs. Early detection of concrete deterioration or corrosion can save thousands in rehabilitation costs.
4. Protecting Public Safety & Business Continuity
   • A structurally sound garage ensures the safety of vehicles, pedestrians, and tenants. By staying ahead of issues, owners can avoid unexpected closures that disrupt business operations.

How to Get Started: Next Steps for Parking Garage Owners

If you own a parking garage in New York, here’s what you should do:

1. Determine if your structure requires an inspection.
   • Consult with a licensed professional engineer to confirm whether Title 19 applies to your building.
2. Schedule an Inspection.
   • Engage a qualified engineering firm to conduct the required assessment.
   • Ensure your inspection report is submitted on time to the local authority
3. Review the Findings & Take Action.
   • If repairs are required, work with structural engineers and contractors to address deficiencies.
   • Maintain all documentation to prove compliance for future inspections.
4. Establish an Ongoing Maintenance Plan.
   • Routine maintenance and monitoring will help extend the lifespan of your parking garage.
   • Consider waterproofing solutions and corrosion control measures to prevent long-term damage.

Final Thoughts

As a parking garage owner, compliance with Title 19 NYCRR is more than just a legal obligation—it’s a strategic investment in safety, asset preservation, and risk mitigation. By staying ahead of inspection requirements, maintaining proper documentation, and implementing proactive repairs, you can avoid costly penalties while ensuring a structurally sound facility.
For further guidance, reach out to a licensed professional engineer who specializes in parking garage assessments. Taking the necessary steps today will help you maintain compliance, protect your property, and ensure the safety of everyone using your facility.

Kevin M. Duffy

Principal

Duffy Engineering