Effective September 1, 2024, owners will have to provide annual notice and investigation records whenever lead-based paint hazard or turnover violations are issued. Owners will also have to provide XRF testing records for the same violations, starting in August 2025 (to coincide with the final due date for XRF tests in all units).
Another law – Local Law 122 of 2023 – would allow HPD to dismiss record-keeping violations as corrected if the owner submits one of the following:
- An appropriate request form for such violation with the required 10 consecutive years of records, including records for the year in which the dismissal request is submitted; OR
- The appropriate request form with documentation demonstrating that the owner has kept the required records for a period of at least 3 consecutive years, including such records for the year in which the owner is submitting the dismissal request
- …and upon notification from HPD that the above is sufficient, a payment of $1,000 for each of the 10 years that the owner does not submit documentation
SiteCompli and InCheck users can automate mailings, response tracking, and action items, providing an end-to-end solution for mailings-related records. Reach out to support@sitecompli.com or your Customer Success Manager with more questions.
FRICTION SURFACES
In addition to record production requirements, Local Law 132 also covers requirements regarding friction surfaces (doors, doorframes, windows) effective September 2024:
- If a child under 6 resides in a unit with presumed lead-based paint (property built prior to 1960) on January 1, 2025, the owner must abate the lead-based paint on door and window friction surfaces, and remediate lead paint hazards, including making all floors smooth and cleanable, by July 2027; OR
- If a child under six comes to reside in a unit with presumed lead-based paint after January 1, 2025, the property owner must abate the lead-based paint on door and window friction surfaces, and remediate lead paint hazards, including making all floors smooth and cleanable within 3 years of the date that the child comes to reside there.
Remember, the definition of reside was updated to “lives, or routinely spends 10 or more hours per week in a unit.” That’s really important for understanding the first date from when the clock starts for three years, or even earlier if it’s before 1/1/25.