Navigating Local Law 31: A Guide for Building Owners and Property Managers
Lead paint poses serious health risks, especially to young children. Building owners and property managers need to think about taking action in order to ensure compliance with Local Law 31, which requires building owners to test for lead-based paint in residential buildings (built prior to 1960), before the August 2025 deadline. Testing, remediation, and compliance take time. Delaying can lead to rushed decisions, increased costs, and even penalties. Here’s how you can stay ahead and protect both your tenants and your property.
Take Immediate Action for Units with Children Under Six
If your property houses children under six, follow these steps to be in compliance:
- Inspect the Units Annually, especially those within the first year of the child’s residency.
- Test Additional Spaces: in pre-1960 buildings where children under six spend more than 10 hours weekly, even if they don’t live there.
Acting quickly ensures you meet these requirements and avoid unnecessary complications as deadlines approach.
Meet Key Deadlines and Requirements
Complete XRF Testing by August 2025
By August 2025, you must:
- Conduct X-ray Fluorescence (XRF) testing in all pre-1960 buildings, including both dwelling units and common areas. Use only EPA-certified lead inspectors to perform this testing.
- Keep detailed records of all testing and provide them to the Department of Housing Preservation and Development (HPD) upon request.
Getting started now makes it easier to secure certified inspectors and avoid the rush as the deadline gets closer.
Comply with New Lead Paint Standards
As of December 1, 2021, the lead-based paint threshold dropped from 1.0 mg/cm² to 0.5 mg/cm². This stricter standard means more surfaces now qualify as hazardous, so there is increased urgency to test and remediate.
Apply for Exemptions Early
If your property tests negative for lead paint or you’ve already abated all lead surfaces, apply for an exemption with HPD. Submitting early will help simplify future compliance requirements.
Fulfill Future Responsibilities
Abate Lead Hazards for Units with Children Under Six
- By July 2027: Abate door and window friction surfaces and ensure floors are smooth and cleanable.
- For New Tenants After 2025: Meet abatement and remediation standards within three years for any unit occupied by children under six after January 1, 2025.
Getting started on these projects early prevents unnecessary delays and helps ensure that you meet deadlines.
Engage Tenants to Stay Compliant
Effective communication with tenants will help you comply with Local Law 31:
- Distribute Annual Notices: Provide tenants with lead hazard notices between January 1 and 16 each year in English and Spanish. Follow up with investigations between February 16 and March if tenants don’t respond by February 15.
- Certify During Leasing: Ask about children under six during leasing or renewal time, confirm lead-related work is complete, and deliver notices about lead hazards.
Actively engaging tenants strengthens trust while ensuring compliance.
Act Now to Avoid Last-Minute Panic
The August 2025 deadline may seem far away, but testing and documentation take time. Acting early allows you to plan for inspections, address lead hazards, and maintain compliance without the pressure of a last-minute rush. As the deadline nears, demand for certified inspectors will surge, increasing the risk of delays and higher costs.
Begin Today; Protect Your Property
Don’t wait until it’s too late. Local Law 31 requires immediate attention to create safer living environments for your tenants and help you avoid costly penalties. Schedule testing now, begin abatement early, and stay proactive to ensure full compliance.
Contact RTK Environmental to schedule your lead testing and get ahead of the process.
