NYC HPD · Lead Paint · One-time XRF

Local Law 31 — the one-time XRF inspection program.

Local Law 31 of 2020 required every pre-1960 NYC dwelling unit to receive a one-time XRF lead inspection by August 9, 2025. Owners who missed the deadline face open HPD violations, accruing penalties, and an inspection backlog. Envirex performs LL31 inspections at scale, including the post-deadline catch-up work.

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What Local Law 31 requires.

Local Law 31 of 2020 amended NYC's Childhood Lead Poisoning Prevention Act to require that every dwelling unit in a multiple dwelling erected before 1960 receive a one-time XRF lead-based paint inspection. The original deadline was August 9, 2025, with HPD-issued extensions in limited circumstances. The inspection must:

  • Be performed by an EPA-certified lead-based paint inspector or risk assessor;
  • Use an XRF instrument operated to the relevant ASTM and HUD standards;
  • Cover every painted component in the dwelling unit and the building's common areas serving that unit;
  • Generate a written inspection report that the owner must retain for the life of the building's compliance record.

The report becomes the baseline lead-paint inventory for the unit, feeding into the annual Local Law 1 investigation cycle and into turnover compliance.

What Envirex does for LL31 inspections.

Scope of work for an LL31 engagement:

  • Building inventory. A walk of the building to confirm the unit count, common-area scope, and any units already inspected under prior owners or programs.
  • Calibrated XRF survey. Every painted component in every in-scope unit and common area is read individually with a NIST-traceable, calibrated XRF instrument. Daily calibration logs are appended to the report.
  • Inconclusive resolution. Any inconclusive reading triggers paint-chip sampling for AIHA-LAP confirmation. See Paint Chip Sampling.
  • Friction and impact surface flagging. Window stools, troughs, sashes, doors and other friction surfaces with lead are flagged for inclusion in the building's annual maintenance and turnover protocols.
  • Sealed inspection report. Signed and sealed by the EPA-certified inspector, with photographs, sample maps and calibration data. Delivered to the owner in 24–48 hours.
  • Compliance file. The LL31 report is filed into the building's compliance record alongside the annual LL1 investigation log.

If you missed the August 9, 2025 deadline.

HPD has been working through inspection backlogs since the deadline. Owners with uninspected pre-1960 units face one of three scenarios:

  • Active HPD violation. A Class B or Class C lead violation has been issued citing the missing LL31 inspection. The clock is running on civil penalties. Envirex's HPD Lead Violation Closure workflow handles these end-to-end.
  • Pre-violation, owner-initiated catch-up. No violation has been issued yet but the owner needs to complete the inspection before HPD notices. We schedule rapid LL31 surveys for owners in this position.
  • Portfolio-wide gap. Larger owners with multiple unrelated pre-1960 buildings often need a coordinated multi-building catch-up. We scope these as portfolio engagements with consolidated reporting.

Common LL31 questions.

The LL31 inspection sits inside a larger compliance ecosystem — RRP, turnover, abatement clearance, HUD Section 35. We brief owners on how the LL31 record interacts with each so the same inspection isn't paid for twice in adjacent programs.

FAQ

Local Law 31 — common questions.

Does LL31 apply to owner-occupied 1-2 family homes?
LL31 applies to multiple dwellings (three or more dwelling units). Owner-occupied 1- or 2-family homes are not subject to the LL31 inspection requirement, though they may still fall under federal Disclosure Rule, EPA RRP, and HUD-funded program rules.
How long does an LL31 inspection take per unit?
Typical occupied unit: 60–120 minutes of in-unit inspector time, depending on layout and painted-component count. Common-area inspection time is bundled into the per-building visit. Report delivery is 24–48 hours.
If we already have an XRF report from before LL31, does it satisfy the requirement?
A prior XRF inspection performed by an EPA-certified inspector covering every painted component generally satisfies LL31, provided the report is on file and accessible. We review prior reports on intake to confirm scope and identify any gaps requiring supplemental inspection.
What's the penalty for failing to complete an LL31 inspection?
Civil penalties accrue per dwelling unit until the inspection is performed and documented. Compounded across a portfolio, penalties can become significant quickly. Catch-up engagements should be scheduled as soon as the gap is identified.
Will the LL31 inspector identify lead in common areas too?
Yes. Common-area painted components on the path of travel serving the dwelling unit are included in the inspection scope.
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