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Plumbing Fixture Count - Minor Variations

Last Updated: September 20, 2006
Supercedes All Previous Notices

To reduce the need for Plumbing Post Approval Amendments (PAAs), the Department will no longer require a PAA to revise the Schedule B when there are minor variations in the fixture count from the approved plans. The Schedule B is a reference tool used by the Department's plumbing inspectors while at a job site.

By reducing the need for filing an amendment, this new process will reduce the time required for plumbing work type and job sign-offs, and minimize the time for issuing a final Certificate of Occupancy (C of O).

Effective Date:
This program will be in effect on a pilot basis in all boroughs.

This initiative supersedes the "10% Fixture Count Allowance" pilot. All other procedures issued previously remain in effect unless specifically superceded by this Fast Track Initiative.


  1. A PAA is no longer required to account for Minor Variations in the plumbing fixture count (described below).
  2. Significant changes to the scope of work or approved plan will require the submission of a PAA, amending the plans and revising the Schedule B before the sign-off of the plumbing work type.
  3. An applicant may file one PAA at the end of a job to account for significant changes noted at the time of inspection.
  4. This initiative does not change any code or Certificate of Occupancy (C of O) requirements.

This initiative shall not apply to the following work types:

  • Gas (PL)
  • Medical (PL)
  • Fire Standpipe (SD)
  • Sprinkler (SP) *
  • Sprinkler(PL) *

*Except for the relocation/replacement of existing sprinkler heads up to a maximum of 30 Heads.

  • The addition or removal of fixtures must be related to the work filed on the approved plans. It can not be in an unrelated open area or space The Licensed Master Plumber (LMP) shall ensure the adequacy of pipe sizing for the added load.
  • All work must be code compliant.

Minor Variation Guidelines For Plumbing Work

The following are considered Minor Variations:
  • For eligible fixtures listed below, fixture counts differing from the approved plan.
  • Relocation of a fixture within the same room and within ten (10) feet from the original fixture as shown on the approved plans (except health care facilities).
  • Relocation or replacement of existing sprinkler heads under Sprinkler (PL) work type.
  • Roughing work relating to fixture differences within the same spaces where plumbing fixtures are established in the approved plans.

The following maximum allowances apply:
  • Up to two (2) fixtures per dwelling unit are allowed for residential spaces.
  • Up to two (2) fixtures per room are allowed for commercial spaces.
Minor Variations - Eligible Fixtures:
  • Kitchen (Residential or Commercial): the addition or removal of a sink, in-sink garbage disposal unit (Residential only), or drinking fountain.
  • Bathroom (Residential): the addition or removal of a lavatory (common washbasin), toilet (water closet), urinal, or substitution of bathtub with stall shower or vice versa.
  • Appliances (Residential): properly capped piping for dishwasher, washing machine, Dryer or BBQ grill - shown on approved plan, but uninstalled/disconnected at time of inspection.
  • Bath/Rest Room (Commercial): the addition or removal of a lavatory (common washbasin), toilet (water closet), or urinal (in permitted facilities).
  • Utility Room/Space (Commercial): the addition or removal of a slop sink in janitor's closet.

Minor Variations - Installation Guidelines:
Plumbing inspections of Underground (UG), Roughing, and Fixtures will be accepted for installations with minor variations. Such installations shall be limited to work related to plumbing fixtures. All work must comply with NYCBC RS-16, LL58/1987, and Table 16-5 as it relates to the required number of fixtures based on occupancy group and occupant load of the space, and with other applicable code requirements.

Minor Variations - Self-Certification/Spot-Check (OP 98) Guidelines:
For self-certification of inspections, Minor Variations must be noted on Form OP-98 as follows:

  • Notice of Inspection - check the minor variation box.
  • Certification of Inspection Results - check the minor variation box, note minor variation discrepancies in the "inspection data - comments" section.

Note: Differences in fixture count exceeding the maximum allowance will require the submission of a PAA. Amending the plans and revising the Schedule B before sign-off of the plumbing work type.

Significant Change Guidelines for Plumbing Work
The following are considered significant changes and will require the submission of a PAA:
  • The addition of a new bathroom, kitchen, or pantry, or removal of planned stack(s).
  • The addition of a fixture to a room that had no fixture noted on the approved plan.
  • The relocation of a fixture beyond ten feet from its original location.
  • Changes to gas-related piping before the service valve, including the number of meters.

Other Related Links:
Service Notice - September 20, 2006 (33 kb pdf)