Local Law 31 XRF lead testing for NYC buildings.
Local Law 31 of 2020 requires owners of pre-1960 NYC buildings to have every rental unit and common area tested for lead-based paint with an XRF analyzer, by an EPA-certified inspector who is independent of the owner and of any abatement firm. The deadline was August 9, 2025, so a building that hasn't been tested is overdue. We test the units and common areas, then hand you the report and signed affidavit HPD asks to see.
Testing, affidavit and records
- XRF testing of every rental unit and common area, including vacant units
- All surface types tested, including chewable, friction and impact surfaces
- Results by room and surface, at the 0.5 mg/cm² action level
- Signed affidavit from the certified inspector who did the testing
- A record of each access attempt for units a tenant won't open, for your no-access affidavit
- Independent dust-wipe clearance after your abatement contractor finishes
Typically used by
Owners and managing agents of pre-1960 multifamily buildings, co-op and condo boards with rented units and common areas, and buyers who need to know what the records show before closing.
If your building hasn't been tested yet.
HPD says a building that misses the requirement can receive a Class C immediately hazardous violation, with civil penalties of $1,500 per unit or common area. HPD's FAQ also states there are no exceptions to the testing requirement.
When we test a building that's behind, we start with the units that carry the most exposure: any unit where a child under six lives or spends 10 or more hours a week, and any unit with an open lead violation. Common areas and the remaining units follow on the same schedule.
If you tested years ago, find the report first. A past XRF report at 1.0 mg/cm² still counts for Local Law 31, and we can tell you whether what you have holds up before you pay for new testing.
How a building gets tested.
1. Send us the building. The address, the number of units, which are occupied, and any open HPD lead violations. We quote a flat price before we come out.
2. Tenant notice and access. HPD recommends written notice 48 to 72 hours ahead. We schedule around tenants; occupied units and evening or weekend access are routine for us.
3. XRF testing. A certified inspector tests each room and common area surface by surface.
4. Report and affidavit. You get results by unit, room and surface, plus the signed affidavit and our EPA certifications, which together make up the testing records HPD can ask for during an audit. Typical turnaround is 48 hours.
Local Law 31 questions, answered.
Which buildings does Local Law 31 cover?
Rental units and common areas in buildings built before 1960, and in buildings built between 1960 and 1978 where the owner knows lead-based paint is present. Rental units in one- and two-family homes are covered too. In co-ops and condos, units that are rented out and all common areas must be tested; units the owner or the owner's family lives in are not.
Do I have to XRF test every year?
No. Local Law 31 requires one XRF investigation per unit and common area. Keep the records for at least ten years, provide them to HPD when asked, and pass them to the new owner if you sell.
Do vacant units need testing?
Yes. HPD requires every unit to be tested, including units that are vacant or off the market for repairs.
We tested at 1.0 mg/cm² years ago. Do we need to retest?
Not for Local Law 31 compliance, as long as you have the XRF report. If you want to apply to HPD for a lead-free exemption, the unit has to be tested at the current 0.5 mg/cm² action level.
What happens if a surface tests positive?
It depends on the paint's condition and who lives there. Intact lead paint has to be monitored and kept in your annual records, and positive door and window friction surfaces must be abated at turnover. Peeling lead paint in a unit where a child under six resides needs immediate correction by an EPA-certified abatement firm, followed by dust clearance testing by a firm independent of the one that did the work.
Can the company that tests also do the abatement?
No. The law requires the XRF inspector to be independent of the owner, the owner's agent and any contractor hired to remediate lead-based paint. The same independence applies to dust clearance after abatement. Raza does not perform lead abatement or remediation, so we can test, and clear your contractor's work, independently.
Requirements summarized from HPD's Paint Testing Requirement and Exemptions page and Local Law 31 XRF Testing FAQ.
Already tested and dealing with a violation or a turnover?
We also handle turnover inspections, dust-wipe clearance and HPD lead violation support. See services for property owners.
Send us the building list.
Tell us the address and how many units. We'll tell you exactly what's required, what it costs, and when we can be there.