2025 Deadline Alert: NYC's Expanded Lead Paint Testing Requirements for Buildings
This week we wanted to supplement our October 31, 2023, Title Tuesday which discussed NYC Local Law 31 of 2020 (“LL 31”) which went into effect on August 9, 2020 (the “Effective Date”) and requires certain property owners to complete at least one (1) investigation for the presence of lead-based paint utilizing an X-Ray Fluorescence (XRF) analyzer by no later than August 9, 2025 (the “Effective Date”).
A link to the October 31, 2023, Title Tuesday email is set forth below.
https://www.homeabstractcorp.
While it is commonly known that LL 31 requires all Residential Apartments in covered properties to be tested for lead utilizing an X-Ray Fluorescence (XRF) analyzer before the Effective Date (unless an Apartment qualifies for a specific Exemption), what many are not aware of is that NYC Local Law 111 of 2023 (“LL 111”) now supplements LL-31 and requires that all Common Areas of covered buildings be tested in similar fashion. The deadline to complete the XRF testing for all Common Areas and report results is due by August 9, 2025, as well.
A link to LL 111 is set forth below.
https://intro.nyc/local-laws/
Please note that HPD will require submission of documented evidence of XRF lead testing in accordance with LL 31 and LL 111 as part of any attempt to clear Lead Paint Violations issued after August 9, 2025.
Below is a link to HPD’s website with additional important information regarding the current state of NYC’s Lead Paint testing requirements.
https://www.nyc.gov/site/hpd/
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