What Local Law 31 requires
Local Law 31 of 2020 amended the city's lead law, Local Law 1 of 2004. It requires owners to have every dwelling unit and common area tested for lead-based paint by an EPA-certified inspector or risk assessor using an XRF (X-ray fluorescence) analyzer.
- Buildings covered: residential buildings built before 1960, and buildings built between 1960 and 1978 where the owner knows lead-based paint is present.
- The deadline: HPD set August 9, 2025 as the deadline to complete testing. Testing was required sooner in units where a child under six lives.
- Who must do it: the testing must be performed by an inspector who is independent of the owner and the owner's management company.
Missed the deadline? Test now
If your building has not been tested, the requirement did not go away. Testing now lets you identify which surfaces are lead-free, apply for exemptions and plan any abatement work before a violation or a child-under-six notice forces a rushed schedule. HPD can issue violations and penalties to owners who cannot show the required records.
How an XRF inspection works
The inspector holds a handheld XRF analyzer against painted surfaces for a few seconds per reading: walls, doors, door frames, windows, sills, baseboards, radiators and other components. No paint is scraped or removed, and no dust is created. A typical apartment takes about 30 to 60 minutes, and tenants can stay home.
The result is a report that lists each surface tested and whether it contains lead-based paint at or above the city's standard.
Exemptions after testing
Surfaces that test negative, or that have been abated, can support an exemption through HPD's Lead Exemption Online Portal. HPD accepts XRF results for exemptions only when the device's Performance Characteristic Sheet supports the city's 0.5 mg/cm² action level, so the right equipment matters.
What comes next: Local Law 123 of 2023
Testing is the first step. Under Local Law 123 of 2023, owners of pre-1960 multiple dwellings must abate lead-based paint on the surfaces the law specifies, such as friction surfaces of doors and windows, at the earliest of:
- the next turnover of the apartment;
- July 1, 2027, for units where a child under six lived as of January 1, 2025;
- within three years after a child under six begins living in a unit, if that happens after January 1, 2025.
A lease renewal is not a turnover. Owners must also deliver the annual child-under-six notice between January 1 and January 16 and keep lead records for at least 10 years.
How we help
We test every unit, deliver organized reports for your records, and turn the results into a unit-by-unit abatement plan and schedule that works around your tenants. When abatement is done, we perform clearance dust wipe testing and give you the paperwork for HPD.