NYC Lead Paint Compliance: Common Area XRF Testing Deadline Passed
Dear Property Manager, this is an urgent compliance reminder regarding New York City’s lead-based paint inspection laws. Under Local Law 31 (2020), owners and agents must complete certified X-ray fluorescence (XRF) testing for lead-based paint in all dwelling units. Local Law 111 (2023) extends this requirement to common areas — hallways, stairwells, lobbies, and elevators.
Who Must Comply
Even when co-op or condo apartments are owner-occupied and exempt from in-unit testing under Local Law 31, the common areas of these buildings must still be inspected by an EPA-certified professional.
Deadline and Penalties
All testing was required by August 9, 2025. Properties without documentation are out of compliance and may face HPD Class C “immediately hazardous” violations and penalties.
Immediate Actions
- Review every pre-1978 property for proof of XRF testing in units and common areas.
- Schedule testing immediately with an EPA-certified lead inspector or risk assessor.
- Retain all inspection and remediation records for HPD review.
- Notify boards under NYC Admin Code § 27-2056.4(a-1) and § 27-2056.6.1.
EnviroCore Services LLC provides certified inspections, documentation packages, and compliance tracking to help co-ops, condos, and property managers achieve full compliance quickly and efficiently.