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OFFICE OF THE NEW YORK STATE COMPTROLLER

D IVISION OF LOCAL GOVERNMENT


& SCHOOL ACCOUNTABILITY

Enforcement of
Elevator and Related
Equipment Inspections

2010-MS-6

Thomas P. DiNapoli
Table of Contents

Page

AUTHORITY LETTER 2

EXECUTIVE SUMMARY 3

INTRODUCTION 5
Background 5
Objective 6
Scope and Methodology 6
Comments of Local Officials 6

ENFORCEMENT OF ELEVATOR INSPECTIONS 7


Recommendations 11

APPENDIX A Response From City Officials 12


APPENDIX B Audit Methodology and Standards 13
APPENDIX C How to Obtain Additional Copies of the Report 15
APPENDIX D Local Regional Office Listing 16

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 1


State of New York
Office of the State Comptroller

Division of Local Government


and School Accountability

September 2010

Dear City Officials:

A top priority of the Office of the State Comptroller is to help local government officials manage
government resources efficiently and effectively and, by so doing, provide accountability for tax
dollars spent to support government operations. The Comptroller oversees the fiscal affairs of
local governments statewide, as well as compliance with relevant statutes and observance of good
business practices. This fiscal oversight is accomplished, in part, through our audits, which
identify opportunities for improving operations and City Council governance. Audits also can
identify strategies to reduce costs and to strengthen controls intended to safeguard local government
assets.

Following is a report of our audit titled Enforcement of Elevator and Related Equipment
Inspections. This audit was conducted pursuant to Article V, Section 1 of the State Constitution
and the State Comptroller’s authority as set forth in Article 3 of the General Municipal Law.

This audit’s results and recommendations are resources for local government officials to use in
effectively managing operations and in meeting the expectations of their constituents. If you have
questions about this report, please feel free to contact the local regional office for your county, as
listed at the end of this report.

Respectfully submitted,

Office of the State Comptroller


Division of Local Government
and School Accountability

2 OFFICE OF THE NEW YORK STATE COMPTROLLER


State of New York
Office of the State Comptroller
EXECUTIVE SUMMARY

There are an estimated 700,000 elevators and 35,000 escalators in the United States.1 Incidents
involving elevators and escalators kill about 30 and seriously injure about 17,000 people each year
in the United States.2 Many of the deaths could have been prevented if adequate maintenance and
inspection procedures had been in place in the involved buildings.

New York State Property Maintenance Code Section 606.1 (Code) requires that all elevators,
dumbwaiters and escalators be maintained to safely carry all imposed loads, that they operate
properly, and that they be free from physical and fire hazards. The Code specifies that elevator
inspections be performed every six months by a qualified elevator inspector (QEI).3 In addition,
Article 18 of the New York State Uniform Fire Prevention and Building Code Act (Article 18)
requires local governments to enforce the Code and ensure that property owners meet schedules
for inspections and tests set forth in the Code.

Scope and Objective

The objective of our audit was to determine whether local governments are ensuring that all
elevators and related equipment are being properly inspected and tested in accordance with
Code requirements for the period January 1, 2009 through April 6, 2010. Our audit addressed the
following related question:

• Are local governments ensuring that public elevators and escalators are being inspected
and tested by certified QEIs as scheduled in the Code?

Audit Results

Five of the six cities audited are not ensuring that public elevators and related equipment are
inspected as required by the Code. Only Buffalo has a tracking system in place that enables it
to successfully enforce compliance with the Code. While not in compliance, Elmira verifies that
building owners provide for annual on-site inspections (the Code requires inspections every six
months). However, we found that Binghamton, Troy, Poughkeepsie and Utica do not ensure that
property owners have their elevators and related equipment properly inspected and/or tested
in accordance with Code. These cities had no systems to inventory and track elevators and
related equipment4 subject to inspection requirements, and to monitor compliance with Code
1
According to the Elevator Escalator Safety Foundation at http://eesf.org
2
According to the U.S. Bureau of Labor Statistics and the Consumer Product Safety Commission
3
A QEI meets the qualification requirements of the American Society of Mechanical Engineers.
4
Escalators, dumbwaiters and lifts are considered related equipment.

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 3


requirements. Consequently, these municipal officials do not know if the elevators and related
equipment in their cities are safe to use. Officials in these cities told us that they were not aware of
the Code’s specific requirements or that they lacked the resources to implement them.

Since municipal officials often do not enforce the Code, we conducted tests to determine if
building owners complied with the Code’s provisions on their own. Our tests of 476 elevators in
192 properties (148 private properties and 44 city-owned buildings) found that, while inspection
compliance rates were excellent in Buffalo (100 percent) and Elmira (97 percent), compliance
rates ranged from 0 percent to 50 percent in the other four cities. In these four cities, only 63
of 213 (30 percent) of the elevators tested were QEI-inspected; further, none of the elevators in
these cities’ municipal buildings were inspected. Many building owners whose elevators were not
inspected as required told us that they did not know they were not following the Code, or that their
elevator maintenance companies informed them that the city did not require compliance with the
Code. The failure to enforce required elevator inspections in all buildings – including city-owned
buildings – puts public safety at risk.

Comments of Local Officials

The results of our audit and recommendations have been discussed with city officials and their
comments have been considered in preparing this report.

4 OFFICE OF THE NEW YORK STATE COMPTROLLER


Introduction

Background There are an estimated 700,000 elevators and 35,000 escalators


in the United States.5 Each year in the United States, incidents
involving elevators and escalators kill about 30 people and
seriously injure about 17,000 people.6 Many of the deaths and
injuries could have been prevented if adequate maintenance and
inspection procedures had been in place in the involved buildings.
New York State Property Maintenance Code Section 606.1
(Code) requires that all elevators, dumbwaiters and escalators be
maintained to safely carry all imposed loads, that they operate
properly, and that they be free from physical and fire hazards.
The Code specifies that elevator inspections be performed every
six months by a qualified elevator inspector (QEI).7 In addition,
Article 18 of the New York State Uniform Fire Prevention and
Building Code Act (Article 18) requires local governments to
enforce the Code and ensure that property owners meet schedules
for inspections and tests set forth in the Code.

Our audit examined six cities (the Cities of Binghamton,


Buffalo, Elmira, Poughkeepsie, Troy and Utica) across the State
to review the monitoring and enforcement of required inspections
of elevators, escalators and related lift devices. The following
table provides background information on each city.

5
According to the Elevator Escalator Safety Foundation at http://eesf.org
6
According to the U.S. Bureau of Labor Statistics and the Consumer Product
Safety Commission
7
A QEI meets the qualification requirements of the American Society of
Mechanical Engineers.

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 5


BACKGROUND FOR EACH CITY AUDITED
2009 Budgeted Number of
Responsible
City County Population Expenditures Commercial
for Monitoring
in millions Buildings*
Binghamton Broome 47,400 $89.1 Fire Marshall** 2,021
Supervisor
of Elevator
Buffalo Erie 292,000 $494 Inspections 7,484
Elmira Chemung 29,500 $28.7 Fire Marshall 981
Building
Poughkeepsie Dutchess 30,500 $70.7 Department 1,137
Code
Troy Rensselaer 47,200 $75.5 Enforcement 1,603
Fire
Utica Oneida 60,600 $62.4 Department** 2,279
* Information from the New York State Office of Real Property Services
** After fieldwork began, the City made the Fire Marshall responsible for Code enforcement.

Objective The objective of our audit was to determine whether local


governments are ensuring that all elevators and related equipment
are being properly inspected and tested and qualified elevator
inspectors perform the inspections in accordance with the Code.
Our audit addressed the following related questions:

• Are local governments ensuring that public elevators and


escalators are being inspected and tested by a certified
QEI as scheduled in the Code?

Scope and Methodology For the period January 1, 2009 through April 6, 2010, we
interviewed municipal officials and examined records related
to the enforcement of elevator and escalator inspections, as
scheduled in the Code, in six cities.

We conducted our audit in accordance with generally accepted


government auditing (GAGAS). More information on such
standards and the methodology used in performing this audit is
included in Appendix B of this report.

Comments of Local The results of our audit and recommendations have been
Officials discussed with city officials and their comments have been
considered in preparing this report.

6 OFFICE OF THE NEW YORK STATE COMPTROLLER


Enforcement of Elevator Inspections

One of the primary functions of municipal governments is to


provide for public safety. Municipal officials’ responsibility for
public safety includes providing the oversight needed to ensure
that elevators and related equipment in both public and privately-
owned buildings are inspected and tested by a QEI in accordance
with the Code.

We found that Buffalo has a tracking system in place and


successfully enforces compliance with the Code. While not in
compliance, Elmira verifies that building owners provide for
annual on-site inspections (the Code requires inspections every
six months). However, we found that the remaining four cities
(Binghamton, Poughkeepsie, Troy and Utica) are not ensuring
that property owners have their elevators and related equipment
properly inspected and/or tested in accordance with Code. In
these four cities, only 63 of 213 (30 percent) of the elevators
tested were QEI-inspected; none of the elevators in these cities’
municipal buildings were inspected. We attribute this significant
rate of non-compliance to the fact that these cities do not have
systems in place to inventory and track all elevators and related
equipment8 subject to inspection, and to monitor compliance with
the Code’s testing requirements. Consequently, these municipal
officials do not know if the majority of the elevators and related
equipment in their cities are safe to use.

City Monitoring Efforts – Article 18 requires local governments


to enforce and ensure that property owners meet Code
requirements. The Code specifies schedules for inspections
and tests, and requires that QEIs perform the inspections. The
Code also requires that a copy of the most current certificate of
inspection be provided to the municipality. The certificate must
contain enough inspection information to enable the municipality
to determine whether the inspection and/or tests performed are in
compliance with the Code. To enforce the inspection requirements,
city officials must first establish an effective monitoring system
that provides for:

• Identifying and tracking elevators and related equipment


in the city

8
Escalators, dumbwaiters and lifts are considered related equipment.

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 7


• Employing or authorizing QEIs whom building owners
can contact to perform inspections

• Establishing procedures to monitor compliance with


inspection requirements

• Informing the building owners about the Code and their


responsibility to comply with it

• Establishing methods of recourse for enforcing


compliance with the Code and penalizing Code violations.

We found that Buffalo has established a monitoring system


that includes the above components. Buffalo officials use this
system to monitor and enforce compliance with the Code within
the required timeframes. Buffalo has established procedures
governing the Code, and has made this information available to
the public. Buffalo has also created a separate function within the
Department of Economic Development, Permit and Inspection
Services for monitoring compliance with the Code, which is
performed by a Supervisor, who is a QEI. The Supervisor sends
out semi-annual letters to notify property owners 60 days before
inspections are due, maintains a list of licensed independent
QEIs available to perform inspections, and electronically
tracks the inspections and tests that are performed in the City.
The Supervisor receives inspection reports from the QEIs, and
issues annual certificates of operation to property owners after
any listed violations are corrected. Property owners can also
select an elevator maintenance contractor from a City-approved
list of licensed contractors. In 2009, the City collected about
$80,000 in elevator inspection-related revenues, including fees
from the issuance of elevator operating certificates and elevator
maintenance contractor licenses and code violation payments.

We also found that, while Elmira has an elevator inspection


monitoring system in place, the system lacks certain components
needed to provide adequate assurance of compliance with Code
requirements. Elmira’s monitoring system verifies that property
owners in the City inspect and/or test their elevators and related
equipment on an annual basis. The Fire Department’s Division of
Inspection Services verifies that inspections/tests have been done
when they perform annual fire safety inspections in buildings.9
However, the Code requires that such inspections be performed
every six months, not every year. Further, the City has not hired
9
Elmira local law allows the Fire Department to inspect commercial property
at least once a year.

8 OFFICE OF THE NEW YORK STATE COMPTROLLER


QEIs, and does not maintain a list of authorized independent
QEIs whom building owners can hire to do inspections. In
addition, the City does not use the inspection reports it receives to
identify non-compliance. Elmira officials told us they do not have
sufficient resources or personnel to execute all aspects of their
responsibilities under the Code, namely maintaining continuous
monitoring and doing inspections every six months.

Binghamton, Poughkeepsie, Troy, and Utica have not established


procedures to monitor and enforce the inspection of elevators
and related equipment, and they do not track and follow up on
inspections and tests that are independently performed. Only
Binghamton had identified elevators and related equipment in
the city, although the list was incomplete. These cities have not
employed QEIs or authorized QEIs to perform inspections of
elevators and related equipment in their jurisdiction. Because
they have no means of verifying that required inspections are
performed, officials in these cities do not know if building
owners are aware of or in compliance with the Code. Further, in
light of the lack of monitoring, these cities also have no system in
place to assess penalties for non-compliance. As a result, these
local officials do not know whether the elevators and related
equipment in their cities are safe to use.

City officials in three of the four noncompliant cities told


us they were not aware of the detailed requirements of the
Code; only Utica officials reported that they were aware of the
requirements. Officials in all four cities gave various reasons
for noncompliance, including a lack of funding and a limited
number of personnel. These officials said they were focusing
instead on implementing other requirements of Article 18
relating to elevators in new construction/renovations and elevator
complaints because they lacked the resources to implement the
required oversight program for all city elevators.

We recognize that Buffalo’s ability to sustain full-scale


monitoring efforts, including having a QEI supervise the elevator
inspection function, is due in part to the fact that an elevator
inspection function in a larger municipality creates enough
revenue to cover the cost of running the function. However, it
is essential that officials in all cities create and maintain an
inventory of elevators in their city, employ or authorize QEIs
who can do inspections, and develop a practicable method
of monitoring for compliance with the Code’s inspection
requirements. Otherwise, public safety could be at risk.

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 9


Compliance with Inspection Requirements – The Code requires
that all elevators, dumbwaiters and escalators be inspected
every six months to help ensure they are properly maintained
to operate safely. Since municipal officials often do not monitor
the enforcement of the Code, we conducted tests to determine
if building owners complied with the Code’s provisions on
their own. We judgmentally selected a sample of 476 elevators
in 192 properties to test for compliance with Code inspection
requirements. The 192 buildings10 we tested, which included
148 private properties and 44 city-owned buildings, comprised
a representative sample of multi-level commercial (e.g., banks,
retail stores) and municipal (e.g., city agency offices, city housing
units) buildings in each city. While inspection compliance rates
were excellent in Buffalo (100 percent) and Elmira (97 percent),
compliance rates ranged from 0 percent to 50 percent in the other
four cities, as shown in the following table.

Buildings Percent
City Elevators QEI-inspected
Tested Compliance
Binghamton 27 62 17 27%
Buffalo 56 197 197 100%
Elmira 29 66 64 97%
Poughkeepsie 21 30 0 0%
Troy 20 59 30 50%
Utica 39 62 16 25%
Total 192 476 324

In the four cities that did not monitor for inspections and enforce
compliance with the Code, we found that only 63 of 213 (30
percent) of elevators tested were QEI-inspected, as required by
Code. Even worse, none of the 28 elevators located in 19 city-
owned buildings in these four cities were QEI-inspected.

Many building owners whose elevators were not inspected as


required told us that they did not know they were not following
the Code, or that their elevator maintenance companies informed
them that the city did not require compliance with the Code.
These property owners had no proof that inspections were
performed. Other non-compliant property owners had very
limited evidence of inspections that was inadequate to show that
inspections were performed according to Code. For example:

10
The buildings were owned by a total of 72 property owners/managers,
comprising 12 owners (including the municipality) in each city.

10 OFFICE OF THE NEW YORK STATE COMPTROLLER


• While reviewing property owners’ documentation,
most were only able to produce bills, service reports or
maintenance logs that did not provide information about
whether any inspections were performed.

• Other property owners produced records of service calls


that were unclear regarding the testing that was done.

• Some of the records identified the technicians providing


service, but the technicians were not independent
inspectors or QEIs.

• At some properties, neither the owners nor their


representatives (for example, a maintenance supervisor or
a building manager) were present for maintenance visits
to ensure that the work was performed.

The failure to monitor and enforce required elevator inspections


in all buildings – including city-owned buildings – and the
failure to inform the public about Code requirements contributes
significantly to the incidence of non-compliance with elevator
inspections. Such non-compliance jeopardizes public safety due
to potentially unsafe elevators and related equipment.

Recommendations 1. City officials should ensure that all elevators and related
equipment in city buildings are being inspected and tested in
compliance with Code.

2. City officials should develop procedures to enable


the effective monitoring of the Code pertaining to the
enforcement of elevator inspections.

3. City officials should create and periodically update the


inventory of elevators and related equipment in their cities.

4. City officials should employ or authorize QEIs that building


owners can use to perform inspections of elevators and
related equipment.

5. City officials must inform the building owners about the


Code and their responsibility to comply with it, as well as
establish recourse for non-compliance with the Code.

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 11


APPENDIX A

RESPONSES FROM CITY OFFICIALS

We provided a draft copy of this global report to officials in each of the six cities we audited and
requested responses. We received response letters from the Cities of Binghamton, Buffalo, Elmira
and Utica. We provided the Cities of Troy and Poughkeepsie with an opportunity to respond, but
they chose not to respond to the draft global report within the designated timeframe.

Officials in the four cities agreed with our audit conclusions and recommendations, as indicated in
the following excerpts from their response letters.

City of Binghamton officials: “It is our intention to implement all five recommendations as soon
as possible after we receive the final report.”

City of Buffalo officials: “…we are delighted with the findings of the auditors and therefore have
no issues with the report.”

City of Elmira officials: “…we are very happy with our final outcome and the items pointed out to us
during this audit were helpful and have given us direction to hopefully improve our performance.”

City of Utica officials: “…policies and procedures consistent with these recommendations will be
established with the goal of attaining 100% compliance.” However, Utica officials also stated that
the comment we included from building owners, specifically that “elevator maintenance companies
informed them the city did not require compliance with the code” (page 10, paragraph 3), was hearsay.

OSC’s Comment

We visited buildings in each city to verify compliance with code requirements and to report the
building owners’ reasons for non-compliance. The reasons, as told to us by the building owners,
are properly attributed to the owners in our report.

12 OFFICE OF THE NEW YORK STATE COMPTROLLER


APPENDIX B

AUDIT METHODOLOGY AND STANDARDS

We interviewed officials in the six cities to gain an understanding of the internal controls over the
monitoring and enforcement of the inspection of elevators in the cities. We reviewed relevant laws
and the building Code to familiarize ourselves with the statutes that impact the authorities having
jurisdiction over the enforcement of the inspections of elevators. We reviewed City records for
evidence of inspection and performed on-site visits to selected building owners/managers in the
Cities’ jurisdiction to review applicable records and determine if the elevators were being tested
and inspected in accordance with the Code.

In gaining understanding of internal controls we determined:

• Responsibility for monitoring and enforcing the Code

• Familiarity with the Code and the prescribed review schedule pertaining to elevators,
escalators and associated equipment

• Responsible for maintaining an inventory of all elevators and associated equipment in the
City

• If there are local laws and/or policies and procedures in place for the oversight, review, and
monitoring of elevators and related equipment in the City

• Whether or not the City employs QEI inspectors.

In reviewing city records to ascertain monitoring efforts over public elevators and escalators being
inspected and tested in accordance with the Code, we:

• Determined whether elevators and related equipment within the City that are housed
in zoned commercial property and would be subject to compliance with code had been
identified

• Chose 12 building owners from each City, from the inventory list (if one existed) and from
known area buildings with elevators such as hospitals/medical facilities, nursing homes,
private colleges, high-rise office buildings, apartments, and hotels through research

• Reviewed the elevators and related equipment information to determine compliance with
Code schedules. The on-site information from the locations were then compared with
available records at the City. Specific questions included:

o If elevators and escalators were inspected by someone with a QEI certification


every 6 months, as required

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 13


o If elevators and escalators were tested by the Owner’s maintenance company and
witnessed by a QEI every 12 months, as required

o If the inspector was employed by or authorized by the City (the AHJ Authority
having jurisdiction)

o If the information that is required to be on an inspection report, including the name


and QEI identification number of the inspector, was on the report,

o If the “certificate” of inspection which is required to be on the device, in a location


approved by the City, or in the building manager’s office, was available

o If a copy of the inspection report (or certificate), prepared by the QEI, was on file
with the City.

We conducted our performance audit in accordance with generally accepted government auditing
standards (GAGAS). Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions
based on our audit objective. We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objective.

14 OFFICE OF THE NEW YORK STATE COMPTROLLER


APPENDIX C

HOW TO OBTAIN ADDITIONAL COPIES OF THE REPORT

To obtain copies of this report, write or visit our web page:

Office of the State Comptroller


Public Information Office
110 State Street, 15th Floor
Albany, New York 12236
(518) 474-4015
http://www.osc.state.ny.us/localgov/

DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY 15


APPENDIX D
OFFICE OF THE STATE COMPTROLLER
DIVISION OF LOCAL GOVERNMENT
AND SCHOOL ACCOUNTABILITY
Steven J. Hancox, Deputy Comptroller
John C. Traylor, Assistant Comptroller

LOCAL REGIONAL OFFICE LISTING

ALBANY REGIONAL OFFICE HAUPPAUGE REGIONAL OFFICE


Kenneth Madej, Chief Examiner Ira McCracken, Chief Examiner
Office of the State Comptroller Office of the State Comptroller
22 Computer Drive West NYS Office Building, Room 3A10
Albany, New York 12205-1695 Veterans Memorial Highway
(518) 438-0093 Fax (518) 438-0367 Hauppauge, New York 11788-5533
Email: Muni-Albany@osc.state.ny.us (631) 952-6534 Fax (631) 952-6530
Email: Muni-Hauppauge@osc.state.ny.us
Serving: Albany, Columbia, Dutchess, Greene,
Schenectady, Ulster counties Serving: Nassau, Suffolk counties

BINGHAMTON REGIONAL OFFICE NEWBURGH REGIONAL OFFICE


Patrick Carbone, Chief Examiner Christopher Ellis, Chief Examiner
Office of the State Comptroller Office of the State Comptroller
State Office Building, Room 1702 33 Airport Center Drive, Suite 103
44 Hawley Street New Windsor, New York 12553-4725
Binghamton, New York 13901-4417 (845) 567-0858 Fax (845) 567-0080
(607) 721-8306 Fax (607) 721-8313 Email: Muni-Newburgh@osc.state.ny.us
Email: Muni-Binghamton@osc.state.ny.us
Serving: Orange, Putnam, Rockland, Westchester
Serving: Broome, Chenango, Cortland, Delaware, counties
Otsego, Schoharie, Sullivan, Tioga, Tompkins counties

ROCHESTER REGIONAL OFFICE


BUFFALO REGIONAL OFFICE Edward V. Grant, Jr., Chief Examiner
Robert Meller, Chief Examiner Office of the State Comptroller
Office of the State Comptroller The Powers Building
295 Main Street, Room 1050 16 West Main Street – Suite 522
Buffalo, New York 14203-2510 Rochester, New York 14614-1608
(716) 847-3647 Fax (716) 847-3643 (585) 454-2460 Fax (585) 454-3545
Email: Muni-Buffalo@osc.state.ny.us Email: Muni-Rochester@osc.state.ny.us

Serving: Allegany, Cattaraugus, Chautauqua, Erie, Serving: Cayuga, Chemung, Livingston, Monroe,
Genesee, Niagara, Orleans, Wyoming counties Ontario, Schuyler, Seneca, Steuben, Wayne, Yates counties

GLENS FALLS REGIONAL OFFICE SYRACUSE REGIONAL OFFICE


Karl Smoczynski, Chief Examiner Rebecca Wilcox, Chief Examiner
Office of the State Comptroller Office of the State Comptroller
One Broad Street Plaza State Office Building, Room 409
Glens Falls, New York 12801-4396 333 E. Washington Street
(518) 793-0057 Fax (518) 793-5797 Syracuse, New York 13202-1428
Email: Muni-GlensFalls@osc.state.ny.us (315) 428-4192 Fax (315) 426-2119
Email: Muni-Syracuse@osc.state.ny.us
Serving: Clinton, Essex, Franklin, Fulton, Hamilton,
Montgomery, Rensselaer, Saratoga, Warren, Washington Serving: Herkimer, Jefferson, Lewis, Madison,
counties Oneida, Onondaga, Oswego, St. Lawrence counties

16 OFFICE OF THE NEW YORK STATE COMPTROLLER

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