XRF inspection
For covered properties, an independent EPA-certified inspector or risk assessor uses XRF to test painted surfaces in units and common areas.
Explore XRF inspectionsNYC HPD · LOCAL LAW 31
Lead paint rules,
answered clearly.
Landlords ask where XRF inspections, dust wipes, and equipment rental fit. Here are direct answers, grounded in current NYC HPD guidance.
THREE DIFFERENT NEEDS
Which service
fits your project?
Local Law 31 is about documenting lead in painted surfaces. Follow-on work can bring separate lead dust and clearance requirements.
Dust-wipe testing
Dust wipes measure lead in settled dust, often for clearance after regulated paint work. A dust-wipe result does not replace the Local Law 31 XRF inspection.
Explore dust-wipe testingXRF rental
Qualified professionals can request the SciAps X-550 Pb. Renting the instrument alone does not satisfy inspector certification, independence, testing, or record requirements.
Explore XRF rental01 / WHO NEEDS TESTING
Start with the
property.
Building age, rental use, and existing lead paint knowledge determine the scope. A young child can trigger an earlier inspection deadline.
What is NYC Local Law 31?
It requires XRF lead-based paint testing in covered dwelling units and common areas by an independent EPA-certified lead inspector or risk assessor. The citywide deadline was August 9, 2025. See HPD’s testing guidance ↗
Does this apply to my pre-1960 building if no child lives there?
Yes, the XRF testing requirement for covered pre-1960 rental housing is not limited to units with young children. HPD also identifies rental units in one- and two-family homes and common areas in covered buildings. A child of applicable age can make the inspection due sooner.
My building was built between 1960 and 1978. Do I need testing?
HPD says the requirement also applies to rental buildings from 1960 through 1978 when the owner has actual knowledge of lead-based paint. Share the building year and any prior lead records when requesting a scope review.
Do co-ops and condos have to be tested?
HPD says rented or otherwise non-owner-occupied co-op and condo units must be tested when the building is covered. A unit that remains occupied by its owner or the owner’s family is not required to be tested under this rule; public and common areas still require testing.
Are vacant or newly rented apartments included?
Yes. HPD says covered units must be tested even when vacant or temporarily unavailable for rent. A lease change does not erase a prior valid XRF inspection; keep the report and review any separate turnover obligations.
The August 9, 2025 deadline passed. What should I do?
Arrange the required XRF inspection as soon as possible and retain the completed records. HPD says failure to complete testing may result in a Class C violation and civil penalties. Do not assume a pending appointment counts as completed testing.
Is XRF testing required every year?
No. HPD describes the Local Law 31 XRF inspection as a one-time requirement. Separate annual notices and, in some cases, annual lead-hazard investigations remain part of NYC lead paint rules.
02 / THE INSPECTION
What happens
on site?
The inspector and the test method matter as much as the instrument.
Can my superintendent, property manager, or owner do the XRF inspection?
Not for this requirement. HPD requires an EPA-certified lead inspector or risk assessor who is independent of the owner, the owner’s agent, and any firm hired for lead paint remediation. Owning or renting an XRF analyzer does not create that qualification.
Can I use a visual inspection, swabs, paint chips, or dust wipes instead?
No. HPD specifies XRF testing for the Local Law 31 inspection. Visual checks, paint-chip analysis, and dust wipes may have other roles, but they do not replace the required XRF survey.
Will the inspector enter every room and test doors, windows, and closets?
The inspection covers painted components throughout each covered unit and applicable common areas. Plan access to every room and closet, including windows, doors, trim, walls, and other painted components. The inspector determines the readings required by the applicable protocol.
Are hallways and staircases included in my apartment price?
No. HPD includes covered common areas in the testing requirement, and we price them separately at $99 per above-ground story. Tell us about multiple staircases, basement or roof spaces, and unusual layouts so we can review the final quote.
What if a tenant will not give access?
Document notices, contact attempts, offered appointment options, and the reason access failed. HPD provides a sample no-access affidavit and says it will review the owner’s access records when assessing compliance. An untested unit is not the same as a completed inspection.
03 / RESULTS AND RECORDS
After the
readings.
A report identifies where lead-based paint is present. Any repair, clearance, or exemption is a separate step.
What if XRF finds lead paint? Must I remove all of it?
A positive reading does not automatically require removal of every painted surface. The next steps depend on paint condition, a child’s presence, violations, and whether friction or impact components are involved. HPD describes monitoring intact paint and specific remediation duties for peeling paint and turnover. Review HPD’s scenarios ↗
Can I just paint or encapsulate a chipped lead-painted door?
Do not assume ordinary repainting resolves a lead paint hazard. HPD’s requirements depend on the surface, its condition, child occupancy, and any violation. Required abatement or safe work must use appropriately certified firms, and some work needs independent dust clearance. Ask a qualified lead professional to review the specific condition.
Does a negative XRF report automatically give me a lead-free exemption?
No. HPD encourages owners with negative results to apply for a Lead-Free Exemption, but HPD must grant it. Its exemption process requires supporting forms and testing at the applicable 0.5 mg/cm² standard with an approved XRF Performance Characteristic Sheet.
I have an older XRF report at 1.0 mg/cm². Must I retest?
HPD says a prior XRF report at 1.0 mg/cm² can satisfy the testing requirement if you retain the report. To apply for an exemption, HPD requires testing at the newer 0.5 mg/cm² standard. Have the earlier report reviewed before ordering repeat testing.
Do I file the XRF report with HPD after the inspection?
HPD says owners must keep testing records and provide them when requested; routine submission of every inspection report is not described as the completion step. An exemption application is a separate filing. Keep the XRF report, inspector and firm certifications, and applicable affidavits.
How long should I keep the records, and what happens if I sell?
Keep testing records, certifications, and affidavits for at least 10 years and provide them to HPD on request. HPD says lead paint records must be transferred to a new owner when the property changes hands.
04 / DUST WIPES AND RENTAL
The next
right service.
An XRF inspection, a dust clearance, and equipment rental answer different needs.
When do I need dust-wipe testing?
Dust-wipe clearance may be required after regulated work that disturbs lead-based or presumed lead-based paint. HPD’s safe-work guidance calls for independent sampling and laboratory results in applicable cases. Tell us what work occurred, who performed it, and whether an HPD or DOHMH violation is involved so we can review the scope. See HPD safe-work guidance ↗
Will a passed dust wipe satisfy Local Law 31?
No. Dust wipes measure lead in dust; Local Law 31 requires an XRF survey of painted surfaces. A clearance result can document cleanup after covered work, but it does not replace the XRF inspection report.
If I rent your SciAps X-550 Pb, can I inspect my own building?
The rental supplies the instrument only. HPD requires the Local Law 31 inspection to be performed by an independent EPA-certified inspector or risk assessor. An owner, owner’s agent, or remediation contractor cannot meet that independence rule by renting equipment.
Does the rental include a certified inspector or an HPD-ready report?
No. It is an equipment rental for qualified professionals. The renter is responsible for their own credentials, test protocol, report, records, and applicable destination rules. If you need a complete NYC inspection service, request our XRF inspection instead.
OFFICIAL GUIDANCE
Check the
source.
These answers reflect HPD guidance reviewed October 2026. Property facts and any violations can change the required work.
READY TO PLAN THE WORK?
Send the property
details.
Tell us the building year, unit count, common areas, and what you need documented. We will review the scope before scheduling.
Request an XRF inspection