In New York City, property owners must comply with strict lead paint regulations to ensure tenant safety, particularly in buildings constructed before 1960. The NYC Department of Housing Preservation and Development (HPD) issues violations when lead hazards are identified. Understanding the different HPD order numbers associated with lead violations is crucial for landlords, property managers, and tenants. Below, we break down these order numbers and explain how they can be resolved.
Common HPD Lead Violation Order Numbers
HPD assigns specific order numbers to categorize the type and severity of lead violations. Here are some of the most frequently encountered order numbers:
- Order #616 – Correct the lead-based paint hazard, the presumed lead paint that is peeling or on a deteriorated surface using safe work practices. This is a Lead-Based Paint (LBP) Hazard Violation issued when peeling or deteriorated lead-based paint is found in a dwelling where a child under six resides. It requires prompt remediation and clearance testing. Any abatement performed must include post-abatement dust wipe testing.
- Order #617 – Correct the lead-based paint hazard that has been tested positive for lead content and is peeling or on a deteriorated surface using safe work practices. This violation is issued when the owner fails to submit required lead-related documentation, such as the Annual Notice or Lead-Based Paint Investigation Report. Failure to comply can lead to escalated enforcement actions. Any abatement performed must include post-abatement dust wipe testing.
- Order #618 – This order number is assigned when HPD determines that previous lead hazard violations have not been corrected within the required timeframe, triggering further penalties and potential emergency repair work by the city.
- Order #619 – A violation issued due to failure to provide proper turnover compliance, which mandates lead-based paint testing and remediation during tenant turnovers per Local Law 1 of 2004.
- Order #620 – Issued when lead dust hazards are found during an inspection, particularly on surfaces such as floors, windowsills, and wells. Property owners must perform dust wipe clearance tests to resolve the issue.
- Order #624 – Correct the lead-based paint hazard that is XRF machine tested inconclusive for lead content at 0.5MG/CM2 and is presumed lead paint, and that is peeling or on a deteriorated subsurface. Any abatement performed must include post-abatement dust wipe testing.
How to Resolve HPD Lead Violations
If you receive an HPD lead violation, it’s essential to take immediate action to avoid fines and legal repercussions. Here’s how you can resolve each type of violation:
- Address Lead Paint Hazards Promptly – For Order #616 violations, property owners must hire an EPA-certified lead abatement firm to remediate peeling paint and perform clearance testing to confirm compliance.
- Submit Required Documentation – Order #617 violations can be resolved by providing HPD with missing paperwork, such as lead inspection reports and annual notices sent to tenants.
- Ensure Timely Compliance – Order #618 and #619 require property owners to correct violations within a specified timeframe. If a deadline is missed, penalties escalate, and HPD may conduct emergency repairs at the owner’s expense.
- Conduct Lead Dust Clearance Testing – For Order #620, a licensed risk assessor or lead inspector must conduct dust wipe sampling and submit results demonstrating that lead levels are below federal and city thresholds. For any order that requires abatement, post-abatement dust wipe clearance testing is mandatory to confirm compliance.
Avoiding Future HPD Lead Violations
Prevention is key to avoiding costly lead violations. Here are some proactive steps property owners can take:
- Perform Routine Inspections – Regularly check for peeling paint and deteriorating surfaces, especially in pre-1960 buildings.
- Maintain Proper Documentation – Keep thorough records of annual notices, lead inspections, and tenant responses.
- Ensure Compliance During Tenant Turnovers – Conduct lead paint testing and remediation before re-renting units to remain compliant with Local Law 1.
- Hire Licensed Professionals – Work with an EPA-certified lead inspector or risk assessor to identify hazards and ensure compliance with all regulations.
Need Assistance with Lead Violations?
Navigating HPD lead violations can be complex, but Environmental Safeguard Solutions is here to help. Our team specializes in HPD violations, lead inspections, risk assessments, and abatement services to ensure your property meets all regulatory requirements. Contact us today for expert guidance and compliance solutions.
By understanding HPD lead violation order numbers and taking the necessary steps to address them, property owners can maintain safe, compliant buildings while avoiding hefty fines and legal issues.
