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Lead the Way: Are You Ready for NYC’s August 2025 Local Law 31 Deadline for Lead Inspections?
- Staff Writer
- Jun 9
- 4 min read
Updated: 21 hours ago
Time flies, and so does the deadline for complying with New York City's Local Law 31 of 2020.
By August 9, 2025, property owners must ensure their buildings are inspected for lead-based paint hazards. This law mandates that all residential buildings constructed before 1960, and those built between 1960 and 1978 with known lead-based paint, undergo certified lead-based paint inspections. These inspections must be performed by EPA-certified Inspectors or Risk Assessors using X-ray fluorescence (XRF) analyzers to determine if lead-based paint is present .
What Property Owners Need to Do:
Understand the Scope
The law applies to all landlords and building owners of any one of the following:
Multiple Dwellings (residential buildings with 3 or more apartments) that:
Were built prior to 1960, regardless of whether children reside in the units.
Were built between 1960 and 1978, and the owner knows that lead-based paint is present.
Privately-owned residential units where a child under 6 resides, and the building meets the above construction year criteria (and must also comply with Local Law 1 of 2004 — which works hand-in-hand with Local Law 31).
Condominiums and Cooperatives, but only:
· When individual units are not owner-occupied (e.g., they are rented out).
· The building still meets the age and construction year criteria.
Common Areas within buildings meeting the above criteria - Local Law 111 of 2023 amended Local Law 31 to include XRF testing of common areas in residential buildings, such as stairwells and hallways.
Schedule XRF Inspections
Hire an independent/third-party EPA-certified Lead Inspector or Risk Assessor to conduct XRF testing in all tenant-occupied apartments and common areas of your building. The XRF Testing must also comply with Local Law 66 of 2019 which lowered the threshold (Action Level) for defining Lead-based Paint to 0.5 mg/cm².
Keep Records
Maintain documentation of all inspections and any necessary remediation to demonstrate compliance.
Notify the Tenants
Provide written notice to tenants of the XRF inspection results, as well as any remediation work that will take place. Under Local Law 1 of 2004, you must also provide Annual Notices and maintain signed copies from tenants.
Remediate/Abate the Hazards
If the XRF inspection identifies Lead-based Paint greater than or equal to 0.5 mg/cm² , and that paint is peeling, flaking, chipping, cracking or otherwise deteriorated and a child under 6 years old lives or spends at least 10 hours a week in the apartment - you must remediate the lead hazards immediately in compliance with Local Law 1 of 2004 and HUD/EPA guidelines; and use EPA-certified firms and workers for any lead paint disturbance, repair, or remediation work. This also applies to common areas where deteriorated Lead-based Paint has been identified and a child under 6 years old lives in or spends at least 10 hours a week in the apartment building.
When you don't need to immediately remediate or abate:
If Lead-based Paint has been identified but is intact (whether a child lives in the unit or not) - a Lead-based Paint Hazard is not present and you are not required to remediate the hazard immediately. The Owner may choose to monitor the Lead Paint Condition to prevent it from becoming a hazard (peeling, flaking, chipping, etc.), or choose to permanently remove (abate) the Lead Paint; however, for units where a child under 6 resides - Owners must perform inspections/reevaluations at least annually, provide Annual Notices, and immediately remediate any lead hazards that arise.
If a Lead Hazard has been identified (Lead Paint that is peeling, flaking, chipping, etc.) but a child under 6 years old does not live or spend at least 10 hours a week in the apartment - the Owner is not required to make any repairs or remediate if the apartment is occupied; however, once the apartment becomes vacant - the Owner must comply with the Requirements Upon Turnover of an Apartment and remediate all peeling Lead Paint/underlying defects, remove Lead Paint on chewable and friction surfaces, and make all bare floors, window sills and window wells in the apartment smooth and cleanable.
Important Note:
Under Local Law 123 of 2023, if a child under 6 years old lives in a dwelling unit built prior to 1960 (or comes to live in said unit) where Presumed Lead-based Paint exists, the owner must abate the lead-based paint on door and window friction surfaces, and remediate lead paint hazards including making all floors smooth and cleanable, by July 2027.
Lead Training Programs:
Navigating and preparing for these lead regulations can be complex, but we're here to help. CNS offers comprehensive training programs for those seeking to become certified:
And our courses are designed to provide you with the knowledge and skills needed to conduct thorough inspections and ensure compliance with NYC laws.
Why Lead Based Paint Training with CNS?
Expert Instructors: Learn from industry professionals with years of real-life experience in lead inspection, risk assessment and abatement.
Hands-On Experience: Gain practical skills through real-world scenarios and case studies.
Certification Preparation: Our programs prepare you for your EPA certification exam to achieve full EPA certification.
Now is the golden opportunity to get certified. Book your training at CNSenviro.com and take the first step toward becoming a certified Lead Paint professional.
Not looking to train and just need the inspection?
Yes, we train the experts — but we also are the experts. If you're a landlord, co-op board, or property manager trying to make sense of your obligations under Local Law 31, contact our environmental consulting team who is ready to help. We make the complex stuff simple — and we’ll keep you on track with all local and federal requirements.
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