The Department of buildings has a long history of allowing Design Applicants or a designated Third-Party Inspectors the ability to conduct a final construction inspection on their projects. For the same duration the DOB has allowed alterations to be performed that would not require a change to the Certificate of Occupancy but may constitute a change in exits to be filed as a Non-Directive 14 (Directive 2) alteration type 2 application. In the latter case the DOB would not require a new Certificate of Occupancy, however a Department of Buildings inspector would be performing a final inspection upon completion of construction.

With a one-time final inspection by a DOB inspector there can often be work that is concealed behind partitions that is not possible to inspect at construction completion. For the design professional performing a self-inspection, scheduling intermediate inspections prior to construction completion is more feasible. For this reason, the Department of buildings recently issued a buildings bulletin that will rescind the option of filing non-directive 14 alteration applications.

As stated in the new bulletin, “Building’s Bulletin 8 of 2018”, it is the responsibility of the permit holder to ensure that all work remains accessible for inspection during the course of construction. Additionally, any cost associated with altering a space to make completed work must also be incurred by the permit holder. This presents a challenge for work contained within walls such as insulation and fire blocking and stopping. Where the DOB inspector previously may have required removal of completed work to conduct their inspection, the design applicant or third-party inspector can consider the project phasing and complete the inspection prior to elements becoming inaccessible.

To summarize, alteration applications including minor modification to existing egress that do not propose a change in the buildings’ certificate of occupancy shall be filed with a final inspection (Alt2-Directive 14) to be conducted by the design application or third-party inspection agency.