NYC Lead Paint Compliance (Local Law 1): Annual Turnover Inspections, XRF Tests, and Records

11 min read · Updated 2026-08-13

NYC Local Law 1 lead paint compliance where children under six reside: inspection triggers, the LL31 XRF deadline, remediation standards, and record-keeping.

NYC Lead Paint Compliance Requirements

What does NYC Local Law 1 require of landlords?

Local Law 1 of 2004 (the Childhood Lead Poisoning Prevention Act) requires landlords of pre-1960 buildings (and buildings built 1960-1978 where lead paint is known to be present) to annually inspect occupied apartments where a child under six resides. The inspection looks for peeling or deteriorating lead paint and any lead paint on friction surfaces (doors, windows) or impact surfaces. Any such conditions must be remediated before they cause exposure.

When are the annual lead inspections required?

Annual inspections must be conducted in apartments where a child under 6 resides. The landlord must attempt to determine whether a child under 6 lives in each apartment — typically through annual occupancy surveys. If a child under 6 is present, the inspection must be conducted at least annually. Inspections are also required at each apartment turnover (between tenants) for covered buildings.

What is an XRF test and when is it used?

XRF (X-ray fluorescence) testing is a non-destructive method for testing painted surfaces for lead content. A certified lead inspector or risk assessor uses an XRF analyzer that fires X-rays at the surface and measures the characteristic energy of lead fluorescence. Results are measured in mg/cm² — NYC lowered the action level to 0.5 mg/cm² under Local Law 66 of 2019. XRF testing is used to determine whether specific surfaces are lead-bearing and can guide remediation decisions. Only certified inspectors can perform XRF testing for compliance purposes.

What is the Local Law 31 XRF testing deadline?

Local Law 31 of 2020 required owners of covered pre-1960 buildings (and 1960-1978 buildings with known lead) to XRF-test every dwelling unit for lead paint by August 9, 2025 — the five-year deadline has now passed, so owners who did not complete unit testing are out of compliance and exposed to HPD enforcement. Local Law 111 of 2023 extended the same XRF testing duty to common areas, also due by August 9, 2025. Once a surface is tested and cleared as lead-free, it generally does not need retesting, so completing this testing removes a recurring inspection burden.

What remediation is required when lead paint is found?

When lead paint in deteriorating condition is found or when lead paint is found on friction or impact surfaces (regardless of condition), it must be remediated. Remediation may include: encapsulation (covering with a durable material), enclosure (building a physical barrier), or abatement (complete removal). Local Law 123 of 2023 goes further, requiring abatement of lead paint on friction surfaces such as doors and windows in units where a child under six lives, phased in by set deadlines (including turnover-triggered abatement). Post-remediation dust clearance testing must pass before re-occupancy, and NYC tightened the dust-lead thresholds to 5 µg/ft² for floors, 40 µg/ft² for window sills, and 100 µg/ft² for window troughs.

What is required at apartment turnover for lead paint compliance?

Before re-renting a covered apartment (built pre-1960, or 1960-1978 with known lead), the landlord must: (1) Inspect all painted surfaces for deterioration; (2) Remediate any deteriorating paint using lead-safe methods; (3) Test friction surfaces for lead if not previously cleared; (4) Perform a dust clearance test; (5) File the required HPD certification. This turnover inspection is mandatory regardless of whether the incoming tenant has children under six.

What records must I keep for lead paint compliance?

Keep all inspection reports, XRF test results, remediation records (contractor certifications, work orders), clearance test results, and any HPD certifications of compliance. Records should be maintained for at least 10 years and must be available for HPD inspection. When selling the building, these records must be transferred to the new owner. Many property managers scan and store these in a digital building file alongside other compliance documentation.

What are the penalties for lead paint violations in NYC?

HPD can issue Class C (immediately hazardous) violations for lead paint hazards when a child under six is present. Class C violations require remediation within 24 hours. Failure to remediate can result in HPD emergency repairs billed to the owner, civil penalties, and potential criminal liability in cases of child lead poisoning. Lead violations are among the most serious HPD enforces, and penalties are correspondingly severe. There have been multimillion-dollar jury awards in cases of childhood lead poisoning.

Who is considered a "certified" lead inspector or contractor?

New York State certifies lead inspectors, risk assessors, and abatement supervisors and workers. The EPA also runs a Lead Renovation, Repair, and Painting (RRP) certification program. For NYC LL1 compliance, inspections must be done by NYS-certified lead inspectors or risk assessors. Remediation work must be performed by certified workers using lead-safe work practices. You can verify certifications through the NYS Department of Health's online database.

Does Local Law 1 apply to pre-1960 owner-occupied units?

The mandatory inspection obligations under LL1 apply to rental units in multiple dwellings (buildings with 3+ units). Owner-occupied buildings with 1-2 units are not subject to the same mandatory inspection requirements (though lead hazard reduction is still a best practice). However, if an owner-occupied building is converted to rental, the LL1 obligations apply.