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Lead paint XRF testing, explained.

If your rental building has three or more apartments and was built before 1960 (or you don't know the year, which the law treats the same way), Local Law 31 required an XRF lead-paint test of every apartment and common area by an EPA-certified inspector. The filing deadline has passed, which means buildings that haven't tested are now out of compliance, and enforcement is active.

What it costs to skip: lead paint violations are class C immediately hazardous, carry civil penalties, and — the expensive part — an untested pre-1960 building is presumed to contain lead paint in any dispute. If a child is poisoned, that presumption plus missing records is how judgments get large.
Applies toPre-1960 buildings with 3+ apartments and any tenants (unknown year built counts as pre-1960)
The testXRF (x-ray fluorescence) survey of every unit and common area
Who testsAn EPA-certified lead inspector or risk assessor
RecordsKeep results and all lead paperwork 10 years; they transfer on sale
AgencyHPD
The lawNYC Admin. Code § 27-2056.4 et seq. (Local Laws 1/2004, 31/2020, 111/2023)

What XRF testing is

A technician points an x-ray fluorescence gun at painted surfaces; it reads lead content on the spot without disturbing paint. A full survey of a small building takes hours, not days. If surfaces test at or above the threshold, those surfaces carry ongoing duties: no unsafe disturbance, remediation at turnover, and abatement where required.

The annual companions to the one-time test

Pre-1960 rental owners also send the annual lead notice each January (asking whether a child under 6 lives in each unit), investigate when the answer is yes, and remediate at unit turnover. The XRF results tell you which surfaces those duties attach to.

If you haven't tested yet

Book an EPA-certified inspector now: being late is bad, but being late without records while HPD or a tenant's lawyer asks questions is much worse. Testing also frees you: surfaces that test negative come off the lead-duty list permanently.

See every rule that applies to your building

Sources: HPD, Lead-Based Paint · Admin. Code § 27-2056.4 et seq.. Reviewed July 4, 2026. This guide organizes public requirements in plain English; it is not legal advice, and No Fines is not affiliated with the City of New York. Confirm specifics with the agency before your deadline.