Local Law 31 Lead Paint: NYC Compliance Guide 2025

How to avoid work stoppages and fines during renovations in older NYC buildings

Robert Chen owns a six-unit building in Astoria built in 1958. Last fall, he hired a contractor to renovate two vacant apartments — new kitchens, fresh paint, refinished floors. Three days into demolition, an HPD inspector arrived on-site and issued a work stop order. Robert hadn't conducted the required lead paint testing under Local Law 31.

The remodel sat idle for two weeks while he scrambled to hire a certified inspector, remediate hazards, and obtain clearance. The delay cost him over $8,000 in lost rent and contractor rescheduling fees.

According to NYC's Department of Buildings, over 12,000 renovation permits were flagged for potential Local Law 31 non-compliance in 2024 alone.

If you're planning construction, renovation, or even minor repairs in an older building, Local Law 31 compliance is mandatory — and failure can halt your project. This guide explains what the law requires, when it applies, how it compares to Local Law 1, and how to keep your renovation on track.

What Is Local Law 31?

Local Law 31 of 2020 is NYC’s regulation requiring lead-based paint testing before beginning renovation or construction work in applicable buildings. It ensures safe work practices when disturbing painted surfaces that may contain lead.

For landlords and contractors, that means testing before any demolition or surface disturbance — not during, not after.

UNYSE offers certified XRF lead inspections tailored for Local Law 31 compliance.
Learn more about lead paint XRF testing

Purpose of Local Law 31

While Local Law 1 focuses on lead hazards impacting tenants, Local Law 31 focuses on lead hazards created by renovation. Demolition, sanding, or scraping can release lead dust into the air and onto surfaces, endangering workers, tenants, and future occupants.

Local Law 31 closes that regulatory gap by requiring testing before work begins and enforcing strict safety practices.

How Local Law 31 Differs from Local Law 1

Both laws address lead paint, but their triggers and requirements are different. Understanding the distinction helps avoid major compliance failures.

Side-by-Side Comparison

Factor	Local Law 31	Local Law 1
Primary Trigger	Renovation/construction work	Child under 6 years old resides in unit
Building Age	Pre-1960 or 1960–1978 with known lead	Pre-1960 or 1960–1977 with known lead
Testing Timing	Before work begins	Annually (if child present)
Work Threshold	2 sq ft per room / 10% of surface area	N/A (inspection-based, not work-based)
Certified Professional	DOH-certified lead inspector	DOH-certified lead inspector
Penalties	Work stop order; up to $5,000 per violation	Up to $1,500 per unit (Class C)
Clearance Testing	Required after lead remediation	Required after remediation

Which Law Applies to You?

Local Law 1 applies when a child under six lives in or regularly visits your building, requiring annual inspections.
Local Law 31 applies when you're planning construction or renovation work that disturbs painted surfaces, regardless of occupancy.

Many landlords in pre-1960 buildings must comply with both. For example, if you manage a pre-1960 building with families and plan a kitchen renovation, you need both Local Law 1 annual inspections and Local Law 31 pre-work testing.

When Is Local Law 31 Compliance Required?

Local Law 31 is triggered by renovation activities involving painted surfaces, including:

Disturbing 2 square feet or more of painted surface per room
Affecting 10% or more of a wall or surface
Replacing windows, doors, or floors
Sanding floors near painted baseboards
Scraping deteriorated or peeling paint before repainting

Common Examples

Kitchen or bathroom gut renovations
Window replacement or frame repair
Wall demolition
Floor refinishing near painted trim

Local Law 31 also applies to work in common areas in pre-1960 buildings (hallways, stairwells, lobbies, basements), even if no children live in individual units.

Local Law 31 Inspection Requirements

XRF Testing: The Standard for LL31

Most landlords rely on XRF (X-ray fluorescence) testing to satisfy Local Law 31 requirements:

Fast: On-site results in a few hours
Non-destructive: No scraping required for most surfaces
Accurate: Confirms lead content in mg/cm²
Accepted: Recognized by NYC DOH for Local Law 31 compliance

Schedule Local Law 31 testing with UNYSE:
UNYSE Lead Paint XRF Services

Certified Inspectors Only

Local Law 31 requires inspections by a DOH-certified lead inspector or licensed industrial hygienist using calibrated equipment. UNYSE’s inspectors have over 20 years of NYC compliance experience.

Documentation and Certificates

After XRF inspection, you will receive:

A complete lead test report
Photos and diagrams of the work area
Identification of lead-based paint and hazard locations
Recommendations for safe work practices or abatement

Once hazards are addressed and clearance testing is passed, you receive a Certificate of Compliance that can be presented to HPD and DOB inspectors.

Landlord Responsibilities Under Local Law 31

Before Work Begins

Confirm your building falls under Local Law 31 (pre-1960 or known lead).
Hire a DOH-certified lead inspector to test all painted surfaces in the planned work area.
Review the inspection report and identify lead hazards.
Share those findings with your contractor so they can plan lead-safe work.

Starting work without testing is an immediate violation and can trigger a stop-work order.

Safe Work Practices During Renovation

If lead is present, contractors must:

Contain the work area with plastic sheeting and barriers
Use wet methods for scraping and sanding
Wear appropriate protective equipment
Use HEPA vacuums for cleanup
Dispose of lead-contaminated waste according to NYC rules

These practices are required by both Local Law 31 and the EPA’s Renovation, Repair, and Painting (RRP) Rule.

Post-Remediation Clearance

After remediation or encapsulation, clearance testing is required to confirm that dust levels are below regulatory thresholds:

Floors: ≤10 µg/ft²
Window sills: ≤50 µg/ft²
Window troughs: ≤100 µg/ft²

UNYSE coordinates dust wipe sampling and lab analysis and typically delivers clearance results within 3–5 business days.

Local Law 31 Violations and Fines

Penalty Structure

HPD can impose:

Work stop orders until testing and remediation are completed
Fines up to $5,000 per violation, with each untested work area potentially counted separately
Class C violations at $1,500 per unit if lead dust contaminates occupied areas or children are endangered

Repeat or willful non-compliance may trigger escalated enforcement or referral.

HPD Enforcement and Work Stop Orders

Enforcement can result from:

Routine site inspections tied to permits
Tenant complaints about dust or unsafe work
Anonymous tips from neighbors, workers, or other observers

Inspectors can arrive unannounced, review permits, and demand proof of lead testing and clearance. If you cannot produce valid documentation, you should expect a stop-work order and fines.

UNYSE helps landlords prevent this scenario with fast pre-work inspections and compliance reporting.
Call (888) 436-8338 to schedule Local Law 31 testing before your contractor mobilizes.

How to Achieve Local Law 31 Compliance

Compliance is straightforward when you follow a defined process.

Step-by-Step Inspection Checklist

Confirm your building age and lead status (pre-1960 or known lead).
Define the scope of renovation and the painted surfaces that will be disturbed.
Hire a certified lead inspector such as UNYSE before permits and demolition.
Conduct XRF testing of all painted surfaces in the work area.
Review the inspection report and identify any lead hazards.
Implement lead-safe work practices or hire a licensed abatement contractor.
Complete remediation (removal, encapsulation, or component replacement).
Conduct post-remediation clearance testing (dust wipes).
Obtain a Certificate of Compliance and provide it to HPD or DOB if requested.
Maintain all records (reports, certificates, invoices) for at least 10 years.

Timeline and Scheduling Best Practices

Schedule testing 7–10 days before your planned start date.
Allow 3–5 days for clearance testing and lab processing if abatement is required.
Coordinate inspection and clearance with your contractor’s schedule to avoid downtime.

UNYSE offers expedited testing packages and can often mobilize within 24–48 hours when schedules are tight.

Why Choose UNYSE for Local Law 31 Testing

UNYSE has been New York’s environmental compliance partner since 1991. We understand the urgency of renovation timelines and the complexity of NYC lead regulations.

Fast XRF Testing Turnaround

On-site inspections typically scheduled within 48 hours
Comprehensive compliance reports delivered in 2–3 business days
Non-destructive XRF testing accepted by NYC DOH and HPD

Whether you are renovating a single unit or an entire building, UNYSE can scale services to match your project.

Learn more:
UNYSE Environmental Services

Complete Compliance Reporting

Every UNYSE Local Law 31 package includes:

Detailed XRF readings for each tested surface
Photos and diagrams of the work area
Lead hazard identification and recommended next steps
Certificate of Compliance (when applicable)
Coordination of clearance testing after remediation

UNYSE has supported more than 1,500 NYC renovation projects with Local Law 31 compliance. One Queens property owner received XRF testing and clearance in 72 hours, keeping a $50,000 kitchen renovation on schedule.

Visit unyse.net or call (888) 436-8338 to schedule your pre-work inspection.

Frequently Asked Questions About Local Law 31

Do I need Local Law 31 testing if I am only repainting?
If existing paint is fully intact and you are not scraping or sanding, testing may not be required. However, if the paint is peeling or you are disturbing more than 2 square feet per room, Local Law 31 testing is mandatory.

Can I use a home lead test kit?
No. NYC requires testing by a DOH-certified lead inspector using XRF or lab-analyzed paint chip samples. DIY kits are not legally sufficient.

How much does Local Law 31 testing cost?
Costs vary based on the number of rooms and surfaces tested. UNYSE typically charges $300–$600 for a single-unit XRF inspection. Contact UNYSE for a project-specific quote.

What if my contractor says they are EPA-certified?
EPA RRP certification is required for contractors but does not replace Local Law 31 testing. You must still hire a certified lead inspector to test the work area before starting.

How long is a Certificate of Compliance valid?
A Certificate of Compliance remains valid as long as the tested painted surfaces are not disturbed again. If you undertake new renovation work in the future, you will need new testing.

Do Not Let Lead Testing Delay Your Renovation

Local Law 31 compliance is non-negotiable, but it does not have to slow your project. With UNYSE’s fast XRF testing, experienced inspectors, and turnkey documentation, you can start work on time and avoid costly violations.

Whether you are planning a single apartment refresh or a building-wide renovation, UNYSE delivers the Local Law 31 compliance support NYC landlords rely on.

Call (888) 436-8338 or visit unyse.net to schedule your Local Law 31 inspection today. Compliance starts here.