NYC HPD · Lead Paint · Annual

Local Law 1 compliance for NYC owners.

If your pre-1960 NYC building has a child under six in residence, Local Law 1 of 2004 requires an annual lead-paint investigation, prompt remediation of any peeling lead paint, and a defensible written record. Envirex runs the whole annual cycle — investigation, friction-surface treatment, dust-wipe clearance, HPD filing — under one engagement.

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What Local Law 1 actually requires.

Local Law 1 of 2004 — the Childhood Lead Poisoning Prevention Act — applies to every NYC multiple dwelling built before 1960 (and to 1960–1978 buildings where the owner has actual knowledge of lead paint). The owner must:

  • Investigate annually for lead-based paint hazards in any dwelling unit where a child under six resides;
  • Remediate identified hazards (peeling lead paint, deteriorated friction surfaces, chewable surfaces accessible to children) using lead-safe work practices;
  • Provide an annual lead notice to every tenant family;
  • Maintain records for at least 10 years; and
  • Perform a lead-based paint inspection at unit turnover before re-renting.

Failure to investigate, remediate or document is treated as a Class C immediately hazardous violation — the most serious HPD violation tier, with 21-day correction deadlines and per-day civil penalties that accrue until closure.

What an Envirex Local Law 1 engagement covers.

Most LL1 owners engage us for a full annual program. Scope of work typically includes:

  • Tenant notice management. Annual lead notice template, distribution log, and response tracking — the documentation HPD will ask for first.
  • Annual visual investigation. Apartment-by-apartment visual inspection of all painted surfaces, with a focus on friction surfaces (window stools, troughs, sashes, doors), chewable surfaces, and any deteriorated paint.
  • XRF testing when triggered. Where the visual investigation identifies a hazard or where tenant turnover triggers it, an EPA-certified inspector performs a calibrated XRF inspection with results in 24–48 hours.
  • Friction-surface treatment scoping. Where lead paint is identified on friction surfaces, we scope the remediation — sometimes replacement, sometimes encapsulation, sometimes full abatement — depending on the surface, the budget and the child-occupancy context.
  • Dust-wipe clearance. After remediation, an Envirex assessor (independent of the contractor) performs dust-wipe clearance sampling and lab analysis to current EPA standards.
  • HPD documentation package. Annual investigation log, photographs, XRF data, remediation records and clearance results compiled into a single owner-of-record file — ready for HPD inspection or audit.

Class C lead violations — the 21-day clock.

If HPD inspects and finds an LL1-related lead hazard, you'll typically receive a Class C immediately hazardous violation. The clock is 21 days from issue to certify correction. In practice that's tight: the building must complete remediation, clearance testing, and the certification filing inside that window. Envirex routinely closes Class C lead violations in 14–21 days when the call comes in early. We handle the certification of correction filing end-to-end with HPD.

Common Local Law 1 scenarios.

  • New child under six in the unit. Owner notification triggers an investigation requirement within the annual cycle.
  • Tenant turnover in a pre-1960 unit. Turnover triggers an obligation to identify and remediate lead paint hazards before re-renting — see Turnover Lead Inspection.
  • Open HPD violation. See HPD Lead Violation Closure for the rapid-response workflow.
  • Renovation or repair triggering disturbed paint. EPA RRP rules apply alongside LL1; remediation should be performed by an EPA Lead-Safe Certified Firm.

Deliverable.

A single annual file per dwelling unit covering: tenant notice and response, visual investigation findings, any XRF readings, any remediation scope and clearance results, and a signed owner-of-record certification. Format is built to satisfy HPD audit and to be defensible if a future violation issue arises.

FAQ

Local Law 1 — common questions.

Does Local Law 1 apply if no child under six lives in the building?
The annual investigation requirement is triggered when a child under six is in residence in a specific dwelling unit. The owner's general obligations under LL1 (tenant notice, recordkeeping, turnover inspection in pre-1960 units) apply regardless of child residency.
What's the deadline for the annual investigation?
The annual investigation must be completed within a 12-month cycle from the prior year's investigation, or within the cycle starting when a child under six first takes up residence. Most owners run a consolidated annual cycle in the spring or fall.
Can the owner perform the investigation themselves?
The annual visual investigation may be conducted by trained owner staff. Where lead paint is identified or suspected, the testing and clearance work must be performed by an EPA Lead-Safe Certified Firm. Envirex handles both ends — investigation and the regulated testing/clearance.
How does Local Law 1 differ from Local Law 31?
LL1 (2004) is the annual investigation and remediation framework. LL31 (2020) required a one-time XRF inspection of every pre-1960 dwelling unit by the August 2025 deadline. The LL31 inspection record now feeds into the LL1 cycle.
What happens if I miss an annual investigation?
Missed investigations are typically discovered when HPD inspects in response to a complaint. The result is one or more Class C lead violations, each carrying a 21-day correction deadline and civil penalties that accrue until certification of correction is filed.
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