As the August 9, 2025 Local Law 31 deadline approaches, the NYC Department of Housing Preservation and Development (HPD) is ramping up enforcement across thousands of residential buildings. Local Law 31 requires landlords of pre-1960 properties to conduct XRF lead-based paint inspections in every dwelling unit—regardless of tenant turnover.
With HPD actively preparing for citywide compliance checks, property owners need to understand exactly what inspectors will be looking for in 2025. Here’s a clear breakdown of HPD’s enforcement strategy and how to stay ahead of violations.
1. Proof of Completed XRF Lead Inspections
In 2025, HPD’s primary focus will be verifying that every required unit has undergone certified XRF testing. Owners must present:
- A full XRF inspection report
- Completed by an EPA-certified inspector or risk assessor
- Results documented for each room and each surface tested
- Proper signatures and certification information
Missing or incomplete XRF reports are expected to trigger immediate violations after the deadline.
2. Tenant Notification Records
Under Local Law 31, owners must provide tenants with a copy of the inspection results within 21 days.
HPD will look for:
- Proof of tenant notification
- Dated delivery receipts (email, paper notices, or acknowledgment forms)
- Copies of all communications provided to residents
Failure to notify tenants can result in separate violations—even if the inspection was completed.
3. Lead Hazard Remediation Documentation
If any XRF tests reveal lead-based paint at or above 1.0 mg/cm², HPD will expect:
- Evidence that repairs or abatement were performed
- Use of EPA-certified contractors
- Lead-safe work practices documentation
- Clearance test results (if required)
Owners who performed repairs without proper certification or documentation may face serious penalties.
4. Recordkeeping for the Past 10 Years
Local Law 31 falls under Local Law 1’s broader lead safety rules, which require owners to keep records for at least 10 years.
In 2025, HPD may request:
- Annual lead inspection records
- Turnover records
- Proof of tenant child occupancy surveys
- Lead notices and disclosures
- Previous violation clearances
HPD often issues violations simply because documents cannot be produced during an audit.
5. Child Under 6 Compliance (Ongoing)
Even after XRF inspections are complete, HPD will continue checking for:
- Annual inspections in units with children under 6
- Prompt correction of peeling paint
- Lead-safe work practices during any repair
- Accurate tenant occupancy surveys
Failure to comply can result in Class C (“immediately hazardous”) violations.
6. Spot Checks and Field Inspections
In 2025, HPD inspectors are expected to conduct:
- Random audits
- Complaint-driven inspections
- Proactive building sweeps, especially in high-risk neighborhoods
If peeling paint is observed in any unit, HPD may demand proof of recent XRF testing and remediation.
7. Penalties Owners Can Expect in 2025
Non-compliance with Local Law 31 can lead to:
- HPD violations
- Daily civil penalties
- Emergency repair charges
- Increased litigation risk
- Delays in refinancing or selling the property
After August 9, 2025, enforcement will become more aggressive, especially for buildings with children.
Need Assistance?
Contact Environmental Safeguard Solutions today to schedule your Parapet wall inspection:
📞 (929-305-1232 | 🌐 www.ess-nyc.com
