Lead Paint Inspection Deadlines under 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

• 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.

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.

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.

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

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.

• 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.

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.

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

• $10,000 fine per unit

• License revocations

• Tenant lawsuits / rent withholdings

• Property value loss

• Increased city inspections

• Apply for a lead exemption through HPD

• Keep all testing records

• Exempt buildings avoid many annual monitoring requirements

•  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

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

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.