Enough to reconstruct, months later and for someone who was not there, that the cited condition was corrected and the required work practices were performed.
This page is in two parts, and the split matters. The first is what the forms and rules actually ask for. The second is the evidence model we recommend, which is our practice rather than a legal requirement. A page that blends the two is not useful to you.
What the forms and rules require
Each item below is asked for by a named instrument. If you are assembling one list, start here.
- The identity of the signer, and current registration The certification is made under oath by the registered owner, a registered officer or director of a corporate owner, or the registered managing agent. For a multiple dwelling, the form asks the signer to affirm they are currently registered with HPD's Division of Code Enforcement for the property. It is notarized, with the notary signing and affixing a stamp. Source Administrative Code §27-2115(o)(2); HPD form CIV 194 PEST, items 1 and 2
- Per violation: NOV ID, violation number, and date corrected The certification form has a row for each violation being certified. Source HPD form CIV 194 PEST
- Per violation: the name and address of the agent or employee who performed the work The form asks for both, for each violation. This is the requirement owners most often discover on the day the certification is due. Source HPD form CIV 194 PEST
- An affirmation that the required work practices were performed The certification includes a statement that the violation was corrected in compliance with Administrative Code §27-2017.8, and the pest certification form affirms compliance with the integrated pest management and work practices under §27-2017.8 and 28 RCNY §54-04(a), including hiring certified pest management professionals if necessary. Source 28 RCNY §54-05(a)(2); Administrative Code §27-2115(o)(2); HPD form CIV 194 PEST, item 4
- A sworn statement from the person who performed the work, where that person is an employee or agent of the owner The certification of correction is to be supported by a sworn statement saying the violation was properly corrected, from the person who performed the work, where the work was performed by an employee or agent of the owner. Source Administrative Code §27-2115(o)(2)
- For an access-based postponement: the notice and the delivery proof A description of the steps taken to gain access, including the written notice sent to the tenant informing them of the hazard and the need for access, proof of delivery of that notice by certified or registered mail, and an explanation of why access could not be gained. Source 28 RCNY §54-03(c)
- For an inspection fee objection: documentation of attempted access The recurring complaint-based inspection fee does not apply where an owner has objected under §27-2129, provided documentation regarding attempted access for the purpose of making repairs to the unit subject to the fee, and HPD has reviewed and approved the objection. Source Administrative Code §27-2115(f)(8)(ii)(E)
The rule provides that HPD may require additional documentation with a certification of correction. What is listed above is the floor, not a complete answer to any particular request.
The model we recommend
Nothing in this section is required by HPD. It is what we keep, because of what the file is asked to do later.
The violation
The Notice of Violation itself, the cited apartment or common area, the specific condition, the correction date and the certification date. Four facts that determine every deadline on the file, kept in one place rather than reread off a scan each time.
The scoping record
What the inspection found, before any work was ordered. Which holes, which cabinets, which door, which fixture, which leak. This is what the work order should have been written from, and it is what makes it possible later to show that each identified item was addressed rather than that a visit occurred.
The access record, in two forms
Ordinary operational logging of calls, texts, emails and attempted visits with dates and outcomes. Separately, the written notice and certified or registered mail proof described in the required section above. The first tells you where your gaps are. The second is the one the rules ask for by name, and a log of phone calls does not substitute for it.
The physical correction, item by item
For each cited location: what debris was removed and by what method, each entry and passage point identified and how it was sealed, each door sweep fitted and the gap achieved, each moisture condition found and the repair performed, and any saturated material removed and replaced. If a contractor or building staff did the sealing or the plumbing, their invoice belongs here too.
Photographs, before and after, for each item
Covered on its own below, because it is the part most files are missing.
The applicator's records, and your access to them
NYSDEC separately requires registered pesticide businesses and certified commercial applicators and technicians to maintain detailed application records, including the product and EPA registration number, quantity, date, place, dosage rate, method and target organism, and to retain them for at least three years. That is the applicator's recordkeeping obligation, not an HPD certification-file requirement.
What portion of it the building receives, with each service or on request, is something to settle in the vendor agreement rather than to discover when you need it. We ask for the technician's name and DEC credential, what was found and where, what was applied, and the recommendations, on every visit.
A named closeout
One person confirming the cited condition is corrected before anything is signed, the submission record and date, and a check for any outstanding charges owed to the Department of Finance related to HPD activities, because HPD states those can prevent certification.
The program that continues after the violation closes
A violation closes. A building does not. HPD has said in its own reports that eradicating an infestation can take several treatments over months, which is longer than any correction period. What happens after the file is closed belongs in the file.
Why photographs of the physical work
A treatment record documents a visit. Photographs of a sealed penetration, a fitted door sweep and a repaired fixture document a correction. When the question is whether the §54-04(a) work practices were performed, the second set is the evidence that directly shows the physical correction.
The door sweep is the clearest case, because the rule gives a number. Gaps reduced to no more than one-quarter inch, on doors leading to a hallway, basement or outside. A photograph with something of known size against the gap answers that question in one frame. A line on an invoice does not.
What the file gets used for
Three specific uses, and each asks for a different part of it.
- An audit or a tenant challenge HPD may audit any certification, and a complainant who is notified of your filing may challenge it, which triggers an audit inspection. What stands behind the affidavit is the record of the physical work.
- A postponement application The access evidence, in the specific form the rule names. It cannot be built retroactively, which is why the letter goes out early rather than when the deadline approaches.
- An inspection fee objection Documentation of attempted access to the unit subject to the fee, under §27-2129. The same access log, put to a third use.
Building the file after the certification rather than during the work. Every item above is straightforward to capture in the moment and difficult or impossible to reconstruct afterwards, which is the argument for a process rather than a folder.
Sources
- NYC Administrative Code §27-2017.8, §27-2115 and §27-2129 (PDF)
- 28 RCNY §§54-03, 54-04, 54-05 — Indoor Allergen Hazards rules (PDF)
- HPD form CIV 194 PEST — Certification of Correction of Violation(s) (PDF)
- HPD form AF-6 — Pest Affidavit of Compliance (PDF)
- HPD — Clear Violations
- HPD — Emergency Repair Program
- NYSDEC — Compliance with the Pesticide Reporting Law, commercial applicator records
- HPD — Indoor Allergen Hazards (Mold, Mice, Roaches and Rats)
We work inside this code every day. We are a pest control company and not your attorney, and this is general information rather than advice about your building. For anything with a filing deadline or a dollar figure attached, involve counsel. Where our sources conflict with each other, we say so on the page rather than picking one quietly.
Want to see what a complete file looks like?
Send us a violation you are working. We'll tell you what is missing from the file and show you the record we would hand you for that correction.
Email us the detailsNo Bug Pest Control · NYS DEC certification C0899591 · Pesticide business registration 15553 · Multifamily buildings in the Bronx and Brooklyn.