Windsor Environmental · Updated November 2026
What the law requires
Local Law 31 of 2020 required XRF lead paint testing at the 0.5 mg/cm² action level of all rental units and common areas in pre-1960 buildings, plus 1960–1978 buildings where the owner knows of lead paint and rental units in 1–2 family homes, by August 9, 2025.
Who can test
An EPA-certified lead inspector or risk assessor, independent of the owner and of any company hired to do remediation.
Exemptions
- Lead-free: all lead paint above 0.5 mg/cm² permanently removed. No annual notices or investigations needed.
- Lead-safe: lead paint encapsulated or enclosed. Periodic inspections still required.
Owner-occupied co-op and condo units are not required to be tested while the owner lives there.
Penalties
Non-compliance can bring a Class C immediately hazardous violation, with civil penalties of $1,500 per unit or common area.
If you’re behind
- Schedule XRF testing for all covered units and common areas.
- Keep the reports. HPD can ask for them.
- Address positive components: maintain them lead-safe, or abate to work toward an exemption.
Questions
Is a 1.0 mg/cm² report still valid?
Older 1.0 reports may still count for compliance in some cases, but new exemptions require testing at 0.5 mg/cm².
This guide is general information, not legal advice. Rules change. We’ll confirm what applies to your property when you call.
