PIPS Annual Observations: A QPSI Must Sign Off Every Year

If your building has a parking garage in New York City, filing the Periodic Inspection of Parking Structures (PIPS) report with the Department of Buildings (DOB) is only part of the job. Every year after that report is accepted, the garage needs an annual observation, and the DOB requires that observation to be performed by or under the direct supervision of a Qualified Parking Structure Inspector (QPSI). A superintendent, porter, or property manager walking the garage with the checklist does not satisfy the rule on their own.

This requirement has been on the books since November 2023, but many owners are still unaware of it. With more garages now holding accepted reports, it’s worth confirming that your annual observation for 2026 is scheduled before the end of the year.

What Is the Annual Observation?

Local Law 126 of 2021 requires NYC parking structures to undergo a full condition assessment by a QPSI on a recurring cycle. As part of that assessment, the QPSI develops an annual observation checklist specific to your garage. It lists the baseline items that need to be looked at every year, or more often if the QPSI calls for it, such as slab cracking, spalling, exposed or corroded reinforcing, leaking joints, drainage, and the condition of railings, barriers, and other appurtenances.

The annual observation is the check between full assessments. Its purpose is to catch deterioration early, before a condition that was Safe or Safe with Repairs and/or Engineering Monitoring (SREM) worsens into an Unsafe one. Parking structures take a beating from vehicle traffic, water, deicing salts, and freeze-thaw cycles, and conditions can change noticeably in a single winter.

Completed checklists are not filed with the DOB each year. They must be kept at the building, made available to the DOB and the QPSI on request, and submitted with the next cycle’s condition assessment report. If an Unsafe condition is found during the observation, the owner and the DOB must be notified immediately.

Who Can Perform It?

When the PIPS program first launched, the annual observation was intended to be done by the owner or the owner’s “competent person,” which in practice often meant building staff. The DOB changed that in a rule amendment that took effect on November 23, 2023. The same rulemaking created the one-time Initial Observation requirement that many Upper Manhattan, Brooklyn, Bronx, Queens, and Staten Island garages had to meet by August 1, 2024.

Under the amended rule, 1 RCNY §103-13(d), the annual observation checklist must be completed by or under the direct supervision of a QPSI on the owner’s behalf, every year after the current cycle’s report has been accepted. A QPSI is a New York State licensed professional engineer with parking structure experience who has been credentialed by the DOB.

“Under the direct supervision of” leaves room for trained field staff to assist, but a QPSI has to be responsible for the observation. An unsupervised walkthrough by building staff, however thorough, does not meet the requirement.

Does Your Garage Owe One This Year?

The obligation starts once your current cycle’s PIPS report has been accepted by the DOB. Where your garage stands depends on its sub-cycle:

If you own a 1B garage, 2026 is likely your first annual observation year, which makes it an easy one to miss. If you own a 1A garage and your checklists have been completed by staff alone, those observations may not meet the current rule.

Because timing depends on when your report was accepted, confirm the exact schedule for your building with your QPSI. You can also check which sub-cycle your garage falls in on the Local Law 126 map, and see our full range of garage inspection services, on our Periodic Inspection of Parking Garages page.

What’s at Stake?

Failure to conduct a required annual observation is its own violation under the PIPS program, separate from the penalties for late or missed report filings. Those filing penalties are already steep: $1,000 per month for a late filing and $5,000 per year for failure to file.

The bigger cost usually shows up at the next condition assessment. The QPSI must review all of the prior cycle’s annual observation checklists. Missing or noncompliant checklists leave a gap in the garage’s record, and any SREM condition that has not been corrected by the next cycle must be reclassified as Unsafe. An Unsafe filing starts a 90-day repair clock, requires protective measures, and carries penalties of $1,000 per month if it isn’t addressed. Annual observations are the best way to catch these conditions while they are still inexpensive to repair.

Plan Ahead: Schedule Before Year-End

The simplest approach is to treat the annual observation like any other recurring building obligation. Put it on the calendar each year, and ideally schedule it in the fall so that any items needing attention can be addressed before winter. If your garage’s checklist was prepared by another firm, any QPSI can perform the observation using that checklist.

Duffy Engineering’s QPSIs can perform your annual observation, complete and sign the checklist, and flag anything that needs attention before it becomes a larger problem. If you’re not sure whether your garage is due, or whether past checklists were completed correctly, reach out and we’ll help you sort it out.

Sources

• 1 RCNY §103-13, Periodic Inspection of Parking Structures (NYC DOB)
• Promulgation Details for 1 RCNY §103-16, effective November 23, 2023 (NYC DOB)
• Amendment of Rules Relating to Inspection of Parking Structures (NYC Rules)

Michael Olayo

Building Envelope Consultant

Duffy Engineering