Lead Paint Inspection Deadlines under Local Law 31

lead paint inspection

If you own a building in New York City—especially one built before 1960—you have a big responsibility when it comes to lead-based paint compliance. In 2025, Local Law 31 makes that responsibility even clearer.

Here’s the deal: lead poisoning in children is serious. NYC has been stepping up enforcement, and this year the city is imposing tough deadlines. By August 9, 2025, all apartments and common areas must undergo lead paint testing.

Don’t stress, we’ll walk you through everything you need to know about lead inspection in NYC in this blog.

What Is Local Law 31?

Local Law 31 (enacted in 2020) requires the use of XRF technology for lead inspections in NYC rental buildings:

  • Pre-1960 buildings – mandatory inspections

  • 1960–1978 buildings – required if lead-based paint is present or suspected

Key deadline: August 9, 2025

Failure to comply can result in:

  • Class “C” violations

  • Up to $1,500 per violation in civil penalties

  • Mandatory abatement orders by HPD

Key Requirements

  • Full XRF lead testing in all dwelling units by August 2025

  • Immediate compliance for buildings with children under 6

  • Must be done by EPA-approved firms

Local Law 31 is all about detecting hazards before they become a health threat.

Who Needs to Take Action?

If you own or manage a building built before 1960 (or 1960–1978 with lead), you must act now:

  • Landlords

  • Property managers

  • Schools & daycare facilities

  • Developers & rehab contractors

  • Housing agencies & authorities

The closer we get to August 2025, the harder it will be to book inspections.

2025 Deadlines to Know

August 2025 – All XRF inspections for pre-1960 buildings must be completed.
Ongoing – Annual notice and monitoring rules under Local Law 33 apply.
Immediately – Lead inspection is required for any residence with children under 6.

Other Local Laws You Should Know

Local Law 122 (2023)

  • Requires annual notice and investigation records

  • Adds stricter requirements for violation dismissals

Local Law 111 (2023)

  • Requires common area XRF testing by August 2025

  • HPD inspections must include paint condition checks in common areas

Local Law 127 (2023)

  • Adds turnover compliance violations as audit triggers

How to Get Your Building Tested

You cannot use store-bought lead test kits. NYC requires XRF (X-ray fluorescence) testing by an EPA-certified inspector.

Step-by-Step Process:

  1. Find a certified contractor

    • Visit EPA.gov and search “lead certified contractors.”

  2. Inspect all units & common areas

    • Every room, hallway, stairwell, and surface must be scanned.

  3. Get official documentation

    • Results above 0.5 mg/cm² are considered positive.

  4. Store records for 10 years

    • HPD can request them at any time.

Recordkeeping

  • Keep all testing, remediation, and monitoring records for 10 years.

  • Failure to produce records = violation, even if the work was done.

  • Starting August 2025, HPD can request your records immediately during inspections.

Why XRF Inspections Are Mandatory

XRF benefits:

  • Fast – Full-unit testing in under an hour

  • Non-destructive – No paint removal needed

  • Accurate & compliant – Meets EPA, HUD, and NYC standards

Manhattan Lead uses state-of-the-art XRF technology to scan walls, windows, doors, trim, and more.

What If Lead Is Found?

If a child under 6 lives in the unit:

  • Peeling paint – Immediate remediation required

  • Intact paint – Monitor and maintain

If no child under 6:

  • No immediate abatement required unless a child moves in.

Deadlines:

  • If child present on Jan 1, 2025 → remediation by July 2027

  • If child moves in later → 3 years from move-in date

Penalties for Non-Compliance

  • $10,000 fine per unit

  • License revocations

  • Tenant lawsuits / rent withholdings

  • Property value loss

  • Increased city inspections

If Your Building Tests Negative

  • Apply for a lead exemption through HPD

  • Keep all testing records

  • Exempt buildings avoid many annual monitoring requirements

Compliance Checklist

  •  Hire an EPA-certified XRF inspector
  • Test all painted surfaces in units and common areas
  • Keep results for 10 years
  • Monitor lead-painted units with children under 6
  • Apply for exemption if all results are negative
  • Follow annual notice & turnover rules

Why Choose Manhattan Lead

We offer:

  • EPA-licensed inspectors

  • Fully compliant XRF tests

  • Clear documentation for LL31 & LL33

  • Follow-up monitoring & clearance testing

  • Deadline reminders & compliance support

Enforcement Made Easy:

  1. Schedule your XRF inspection

  2. Get full, room-by-room testing

  3. Receive electronic compliance reports

  4. We handle reminders & deadlines for you

Final Word: The 2025 Deadline Is Near

The August 9, 2025 deadline is final—no extensions. If you own or manage pre-1960 property, schedule your inspection now to avoid penalties.

Manhattan Lead ensures your property is safe, compliant, and ready for the future.

FAQS

Q: Can I do a visual inspection instead of XRF?
No—visual inspections are not compliant. NYC requires XRF testing.

Q: Which buildings must comply?
All built before 1960, or 1960–1978 with lead paint.

Q: I already remediated—do I still need to test?
Yes—testing and recordkeeping are still required.

Q: Can I test it myself?
No—only EPA-certified inspectors can perform compliant testing.