Local Law 31

What Is Local Law 31?

Local Law 31 is a 2020 NYC law that requires building owners to test for lead paint using XRF technology. If your building was built before 1960, this applies to you. It also applies to buildings from 1960-1978 if lead paint has been found before.

The law requires you to test every painted surface in every apartment and all common areas — hallways, stairwells, lobbies, the works. Any surface that reads at or above 0.5 mg/cm² (the threshold set by Local Law 66) counts as lead-based paint.

You can't do this yourself. The city requires an EPA-certified inspector with an XRF analyzer — visual inspections and home test kits don't count.

The deadline to get this done is August 9, 2025. If you haven't completed testing by then, you're looking at violations and fines from HPD.

Who Needs to Get Tested?

Not sure if your building is covered? Here's a quick breakdown. If you own or manage any of these property types, you need to schedule LL31 testing:

Pre-1960 Apartment Buildings

Every apartment and common area needs testing — no exceptions. It doesn't matter if you've never had a lead complaint or if no children live in the building.

Buildings Built 1960-1978

If lead paint was previously found or assumed in your building, you're covered too. This catches a lot of owners off guard — check your records.

1-2 Family Rentals

Own a brownstone or two-family and rent it out? You need testing. The only exception is if you live there and don't rent any units at all.

Co-ops & Condos With Renters

Even if just one unit in the building is rented, that unit and all common areas need to be tested. This is a big one for co-op and condo boards.

All Common Areas

Hallways, stairwells, lobbies, laundry rooms, basements — if tenants use it, it needs to be tested. This is separate from individual apartments.

What Happens If You Miss the Deadline?

HPD isn't treating this lightly. If your building isn't tested by August 9, 2025, here's what you're looking at:

Class C Violations — This is HPD's most serious violation category ("immediately hazardous"). It goes on your building's public record and can cause problems with lenders, insurers, and buyers.

Fines Up to $1,500 Per Violation — And if you don't correct the issue quickly, daily penalties can stack up on top of that.

HPD Enforcement Actions — HPD can order mandatory inspections, require lead paint remediation, and take legal action if you continue to ignore the requirement.

These violations also show up on HPD Online — meaning tenants, buyers, and lenders can see them. Don't let a missed deadline follow your building around.

The good news? Getting compliant is simple. Book your XRF inspection now, get it done, and move on. Call us at (929) 305-1232 to get on the schedule.

Get a Lead-Free Exemption for Your Building

Here's the upside of LL31 testing: if every surface in your building comes back clean (below 0.5 mg/cm²), you can file for a lead-free exemption with HPD. This is a big deal for landlords.

Once you have it, you no longer have to assume lead paint exists in your building. That means less paperwork, no more lead-safe work practice requirements during routine maintenance, and no automatic remediation obligations at tenant turnover. It simplifies your life as an owner.

We handle the entire filing process for you — from compiling the XRF reports to submitting everything HPD requires.

Pro tip: Even if you expect some surfaces to test positive, getting the exemption on the rest of the building still reduces your overall compliance burden. Every clean surface counts.

What ESS Does for You

We take LL31 off your plate — from the initial inspection through filing your exemption. Here's how the process works:

Step 1: We Test Every Surface With XRF

Our EPA-certified inspectors come to your building and test every painted surface in every unit and common area using an XRF analyzer. You'll have results the same day — no waiting around.

Step 2: We Handle All the Documentation

You'll get a full inspection report ready for HPD. We keep records on file for 10 years, so when an auditor, tenant, or buyer asks for proof of compliance, you've got it.

Step 3: If Lead Is Found, We Coordinate the Fix

Lead-positive results don't have to be a crisis. We manage the whole remediation process — scoping the work, coordinating contractors, and running clearance testing to confirm the job is done right.

Step 4: We Keep You Compliant Year After Year

If your building has lead paint, the city requires annual visual inspections of all painted surfaces. We set up a recurring schedule so you never miss one and stay in good standing with HPD.

Step 5: We File Your Lead-Free Exemption

If your building tests clean, we prepare and submit everything HPD needs to grant your exemption. Once approved, you're free from the lead paint presumption — which means less work and fewer headaches for you going forward.

Why Building Owners Choose ESS

We work with building owners, property managers, and co-op boards across all five boroughs. Here's why they keep coming back:

Same-Day Results — No waiting for lab work. XRF gives instant readings on site.

EPA Certified — Every inspector holds current EPA certification and uses calibrated equipment.

Full Documentation — HPD-ready reports delivered to you. Records stored for the required 10 years.

End-to-End Service — From testing to remediation to exemption filing — one team handles it all.

Related NYC Lead Paint Laws

LL31 isn't the only lead paint law on the books. Here are the other ones that affect you as a building owner — and what each one means in plain English:

Local Law 66 — The 0.5 mg/cm² Threshold

This is the law that lowered the bar for what counts as lead paint. The old standard was 1.0 mg/cm² — now it's 0.5. That means more surfaces in your building may test positive than you'd expect. This threshold applies to all LL31 testing.

Local Law 111 — Common Area Maintenance

Requires annual inspections of hallways, stairwells, and other shared spaces. If paint is peeling or deteriorating in common areas, you need to fix it — whether or not lead has been confirmed.

Local Laws 122 & 123 — Windows, Doors & Units With Young Children

These laws target friction surfaces like windows and doors in apartments where a child under 6 lives. You'll need XRF testing and remediation on those surfaces by July 2027. If you're already doing LL31 testing, it's smart to address these at the same time.

Local Law 31 FAQ

When is the Local Law 31 deadline?

August 9, 2025. Your building needs to have XRF testing completed and documented by that date. If you haven't started yet, now is the time to get on the schedule — slots fill up fast as the deadline gets closer.

Does my building need to be tested?

If your building was built before 1960 and has rental units, yes. This includes apartment buildings, 1-2 family rentals, and co-ops or condos with any rented units. Buildings from 1960-1978 are also covered if lead paint has been found before. Both apartments and common areas need testing.

Can I use a home lead test kit instead?

No. The city requires an EPA-certified inspector using a professional XRF analyzer. Home test kits and visual inspections don't satisfy the requirement. All of our inspectors are EPA-certified and use industry-standard XRF equipment.

What happens if I don't get tested in time?

HPD will issue Class C violations — that's their most serious category. You'll face fines up to $1,500 per violation, and the violations go on your building's public record. That can create problems with lenders, insurance companies, and potential buyers.

My building was tested for lead years ago. Does that count?

It depends. If your old test used the previous 1.0 mg/cm² threshold, it won't meet the current 0.5 mg/cm² standard. And if testing didn't cover every surface in every unit and common area, you'll need additional testing. Give us a call — we can review your existing records and tell you exactly what's still needed.

How do I get a lead-free exemption?

If every surface in your building tests below 0.5 mg/cm², you qualify. We'll compile your XRF results and submit the application to HPD for you. Once it's approved, you no longer have to presume lead paint exists — which means significantly less compliance work and cost going forward.

How long does testing take? Will it disrupt my tenants?

A typical apartment takes about 30-60 minutes. We work around tenant schedules and can handle multi-unit buildings efficiently. You'll have results the same day — no long waits for lab work.

Ready to Get Your Building Tested?

We serve all five boroughs and offer same-day results. The sooner you book, the sooner you can check LL31 off your list. Call us at (929) 305-1232 or schedule your inspection online.