NYC Tenant Protection Plan (TPP), explained

What a TPP is

A Tenant Protection Plan (TPP) is the DOB-required document that protects tenants in an occupied building during construction or alteration. Under NYC Administrative Code §28-104.8.4, an applicant filing for a permit to alter an occupied building must submit a TPP describing how the building's occupants will be protected throughout the work. The DOB reviews it as part of the permit application. Without an approved TPP, the permit doesn't issue.

The TPP sits alongside the Site Safety Plan but covers different ground. The SSP (governed by BC §3304) addresses how the construction site is managed safely. The TPP addresses how the people living or working in the building during construction are kept safe. For projects with both scopes, both filings are required.

This guide walks the TPP section by section: what triggers it, what each piece must contain, how the governing code anchors each requirement, and what the common filing mistakes look like.

When a TPP is required

NYC Administrative Code §28-104.8.4 requires a TPP when an applicant applies for a permit to alter a building that is occupied in whole or in part. The trigger is occupancy during the alteration, not building type.

In practice, TPPs apply to:

• Multifamily residential alterations where tenants remain in occupancy during the work
• Hotel renovations where guests or staff occupy portions of the building
• Office building modernizations with tenants in adjacent or upper floors
• Healthcare facility alterations where patients, staff, or visitors occupy proximate areas
• Any alteration that will affect shared building systems (egress, standpipes, gas, electrical risers) while occupied portions of the building remain in use

Smaller alterations entirely within a vacant tenant space that don't touch shared systems often don't require a TPP. When the scope is ambiguous, the DOB filing resolves it. A licensed safety firm can confirm in a 30-minute review of the job application.

What's in a TPP

A TPP filing must describe, in specific enough detail for a DOB plan reviewer to evaluate it, how each of the following will be managed during the alteration:

• Egress and life safety during construction phases
• Fire safety system continuity including impairment management
• Dust, debris, noise, and vibration controls
• Utility service continuity (water, gas, electrical, HVAC, plumbing)
• Air quality protections, with ICRA classification in healthcare settings
• Tenant notification procedures, timing, and contact information
• Housing relocation plans if any occupant must be temporarily displaced
• Construction schedule as it relates to occupied portions

Each section has detail expectations. DOB reviewers look for specifics tied to each construction phase, not general assurances. "Egress will be maintained" is a finding, not a plan.

Egress and life safety

The egress section is the most scrutinized part of any TPP. The governing frame is NYC Building Code Chapter 10, which establishes egress requirements for occupied buildings, and those requirements don't pause because construction is happening.

The TPP must show, phase by phase:

• That tenants always have access to the minimum required number of egress paths under BC Chapter 10
• That egress corridors, stairs, and exits are clear, lit to the required footcandle level, and signed
• That construction barriers don't reduce egress width below the BC Chapter 10 minimum
• That construction doesn't block the FDNY access path to standpipes and FDCs
• That fire alarm and voice communication systems remain operable along every egress path
• That emergency lighting remains on emergency power circuits not affected by the construction scope

Phased alteration is where egress problems concentrate. If demolition eliminates a stair on floors 5 through 8, the TPP must show how those floor occupants reach grade via an alternate egress path with documented BC Chapter 10 compliance. Phase-specific egress drawings are the standard for doing this.

Fire safety provisions

The fire safety section of a TPP is where the SSM and the FDNY F-89 Fire Safety Manager coordinate most directly. BC §3303 requires that fire protection systems be maintained operable during construction and alteration. When they can't be, impairment management kicks in.

Required elements:

• Sprinkler and standpipe operability schedule: which systems, which zones, which floors, when taken offline, and for how long
• Fire watch coverage (FDNY F-58 personnel) during every impairment window, as required
• Hot-work permitting structure, including the tighter controls that apply in an occupied building versus a vacant construction site
• Smoke and fire detection continuity: if detectors in the work area are taken offline, the plan must describe the compensating measures
• Voice communication and fire alarm continuity for occupied floors
• FDNY notification procedures and advance notice periods for planned impairments
• NFPA 241 principles govern the construction fire safety program; the TPP's fire section must be consistent with the project's NFPA 241-based safety plan

Operating hotels and operating hospitals are the most fire-safety-intensive occupied alterations. DOB objections to TPP fire sections are most common on these project types.

Dust, debris, noise, and vibration

Tenants experience these directly and daily. The TPP must be specific about how each is controlled.

Dust. The standard controls for occupied-building alteration include physical containment barriers (typically gypsum board or poly sheeting from floor to deck), negative-pressure HEPA filtration units exhausting outside the occupied zone, and daily visual inspection of the barrier condition by the site safety manager. For projects involving silica-generating work (concrete cutting, masonry demolition), the applicable federal standard is 29 CFR 1926.1153 (OSHA Respirable Crystalline Silica in Construction), which sets permissible exposure limits and requires either a written exposure control plan or the use of specified engineering controls.

Debris. Debris removal routes through the occupied building must be specified: timing (off-hours or with covered chutes), containment (sealed trash bags or enclosed debris chutes), and cleaning of common areas after each removal.

Noise. NYC's Noise Code (NYC Administrative Code Title 24, Chapter 2) governs construction noise. The TPP must identify permitted work hours for each noise-generating activity and address any nighttime or weekend work, which requires separate DOB or community-board approval for most occupied residential buildings.

Vibration. For demolition, heavy structural work, or foundation work near occupied portions, the TPP specifies vibration monitoring equipment, threshold levels, and response protocols. Thresholds are typically set by the structural engineer of record or the project's geotechnical engineer.

Healthcare alterations. For any alteration in an occupied healthcare facility, the dust section becomes a formal ICRA (Infection Control Risk Assessment). The ICRA classifies the construction activity by type (Type A through D under FGI Guidelines for Design and Construction of Hospitals) and classifies the adjacent patient care areas by risk group. The combination of activity type and risk group drives containment class (Class I through IV), with Class IV requiring an anteroom, negative pressure, and HEPA exhaust. The NYC Department of Health and Mental Hygiene publishes infection control guidelines for healthcare construction that align with the FGI ICRA framework.

Utility service continuity

Occupied tenants need uninterrupted utilities. The TPP must address each service:

• Water. Any planned interruption requires advance tenant notice (typically 24–48 hours) and a defined restoration window. Domestic hot water interruptions in residential buildings have additional NYC HPD implications for multiple dwelling units.
• Gas. Any gas service interruption must be coordinated with Con Edison (or National Grid) and requires advance notice to tenants. Occupied building gas work is governed by the NYC gas code and DOB rules; no assumptions about timeline should appear in the TPP.
• Electrical. Planned panel work, riser modifications, or temporary service interruptions require advance notice to tenants. The TPP specifies the scope of each planned interruption and the restoration window.
• HVAC. Heating interruptions in winter months in occupied residential buildings trigger NYC HPD's heat season requirements (heat must be provided when outdoor temperatures drop below specified thresholds). The TPP must address how heat will be maintained or substituted during HVAC work.
• Plumbing. Domestic hot water, drain stacks, and fixture connections are each addressed.

Each utility section should include: what may be interrupted, the advance notice procedure, the planned interruption window, the emergency contact for tenants, and the contingency if restoration takes longer than planned.

Tenant notification

NYC Administrative Code §28-104.8.4 requires that the TPP include a tenant notification procedure. Plan reviewers will reject a TPP that describes notification in vague terms.

A compliant notification section specifies:

• What is communicated: work scope, schedule by phase, expected noise levels, planned utility interruptions, dust control measures, and emergency contact information
• When notice is given: typically a minimum of 24 hours for service interruptions and 72 hours to one week for significant work phase changes
• How notice is delivered: lobby posting is the minimum. Many projects also use door-to-door distribution, email, building-app notifications, and a project hotline.
• Who the tenant contact is: a named individual (project superintendent or property manager) with a phone number and email
• Frequency of ongoing updates: weekly or bi-weekly progress notices are common on long-duration projects

For residential buildings with low-income or non-English-speaking tenants, notice in translated form may be appropriate and is required in some cases under HPD rules.

Filing path

TPPs are filed through DOB NOW as part of the permit application for an alteration of an occupied building, per NYC Administrative Code §28-104.8.4. The filing professional is typically the project's Registered Architect or Professional Engineer. Licensed safety firms also file TPPs directly in some cases.

DOB review timelines run parallel to SSP review: 2–6 weeks standard, expedited options available, objections are routine. Common TPP objections parallel the common mistakes below. Each round of objections and resubmittal adds 1–2 weeks.

When both an SSP (§3304) and a TPP (§28-104.8.4) are required, both are typically filed together and cross-referenced. Coordinating them under one firm reduces the risk of internal conflicts.

Common TPP mistakes

The mistakes that produce DOB objections and stop work orders:

1. Assumed-not-required. The project team decides the alteration is minor enough not to need a TPP. DOB disagrees at inspection. Stop work order issued pending TPP filing.
2. Generic egress narrative. "Egress will be maintained throughout construction" without phase-specific drawings fails review. The TPP needs phase-by-phase egress plans showing BC Chapter 10 compliance at each stage.
3. Missing impairment plans. Sprinkler and standpipe systems will be impaired at some point on every significant alteration. A TPP that doesn't address the impairment schedule, fire watch coverage, and FDNY notification is incomplete.
4. Vague notification language. "Tenants will be notified as required" doesn't satisfy §28-104.8.4. The form of notice, the timing, and the responsible party are all required.
5. No ICRA section in healthcare alterations. A healthcare TPP that addresses dust with generic construction language and not FGI ICRA classification will be rejected by DOB and, depending on the project, by the facility's infection control officer.
6. Missing NYC Noise Code address. The TPP must reference permitted construction hours and the procedure for any off-hours work. Many teams forget this.
7. Not revised when scope changes. A TPP filed for the foundation phase but never updated for the façade or fit-out phase doesn't cover the later work. Phase revisions file through DOB NOW and require DOB approval before implementation.

Bottom line

The TPP requirement comes from NYC Administrative Code §28-104.8.4. It applies whenever an occupied building is being altered. Each section of the TPP anchors to a governing code: egress to BC Chapter 10, fire safety to BC §3303 and NFPA 241 principles, dust in healthcare to ICRA under the FGI Guidelines, notification to §28-104.8.4 itself. The filing goes through DOB NOW alongside the permit application. Generic language fails review. Phase-specific drawings and named contacts are what pass.

Skilled Safety Management prepares and files TPPs as part of our Site Safety Plan service. For projects with both occupied-alteration and new-construction scope, both filings are prepared under one accountable team.

Frequently asked questions

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