What Local Law 31 requires
Local Law 31 made XRF testing a key requirement for many NYC residential buildings. The practical purpose is simple: owners need documented knowledge of whether painted components contain lead. For local help, our team can help you sort out the next step.
The main point
Owners should not rely only on the age of the building or past assumptions. A proper XRF inspection creates a written record that can be used for compliance, repairs, turnover work, and future planning.
Owners should review
- Which buildings and units were tested.
- Whether common areas were included.
- Whether any units were missed because access was not available.
- Whether the report is complete enough for HPD, counsel, or a buyer to review.
Why the deadline still matters
Even if a main deadline has passed, the recordkeeping issue does not go away. Owners may still need the report during an audit, sale, refinancing, renovation, management change, or tenant dispute.
Common problems after testing
- Reports are missing unit numbers or room names.
- The owner cannot show which units were inaccessible.
- Prior management kept reports in different folders.
- The report does not clearly identify the instrument or inspector.
- Only a summary was saved, not the full inspection record.
These problems are easier to fix before an agency or transaction reviewer asks for the file. A related guide on this site covers Local Law 1 Lead Paint Inspections in NYC. Another useful page explains HPD Lead Requirements for NYC Property Owners.
How to plan XRF testing across a portfolio
NYC properties often involve many units, tenants, supers, managing agents, and access windows. The inspection plan should match that reality. City guidance is available through HPD Local Law 31 FAQ.
A practical access plan includes
- A unit list with occupied, vacant, and no-access status.
- Tenant notice and superintendent coordination.
- A route for the inspector by floor, line, or building.
- A process for documenting missed units.
- A plan for report delivery and file naming.
Good reports reduce confusion
The final report should identify each building, unit, room, component, substrate, reading, result, inspection date, inspector, and instrument information. City guidance is available through HPD lead-based paint rules.
What owners should do when records are incomplete
If prior Local Law 31 records are incomplete, do not wait until the issue becomes urgent. Start with a document review, identify gaps, and decide whether supplemental inspection is needed.
Questions to ask
- Do we have the full report or only a summary?
- Does the report cover all required units?
- Are inaccessible units clearly listed?
- Are common areas addressed if they were in scope?
- Can we connect each result to a specific component?