Lead Paint Rules for Pre-1978 Housing in Onondaga County: A Landlord Guide

Here’s a fact that every Syracuse landlord needs to sit with: the vast majority of the city’s housing stock was built before 1978. That means lead paint is not a hypothetical concern. It’s a near certainty in most rental units across Onondaga County. If you own pre-1978 housing, you have specific legal obligations under federal, state, and county regulations. Ignoring them doesn’t just put tenants at risk. It puts your entire investment at risk. Fines, lawsuits, and even criminal liability are all on the table.

Let’s break down what you actually need to know and do.

When Lead Testing Gets Triggered

Lead inspections in Onondaga County don’t happen randomly. They’re triggered by specific events, and you should know every single one of them.

A Child Under 6 Tests Positive for Elevated Blood Lead Levels

This is the most common trigger. When a child’s blood lead level comes back elevated (the CDC reference value is currently 3.5 micrograms per deciliter), the Onondaga County Health Department gets notified automatically. They will then investigate the child’s primary residence, and if that’s your rental unit, you’re going to hear from an inspector. This is not optional. You cannot decline the inspection.

Visible Peeling, Chipping, or Deteriorating Paint

Code enforcement officers can flag deteriorating paint conditions during routine inspections or complaint-driven visits. In Syracuse, where the housing stock is old and winters are hard on exterior surfaces, peeling paint is extremely common. A code officer who spots it in a pre-1978 building has grounds to require lead testing.

Tenant Complaints

Any tenant can file a complaint with the county health department about suspected lead paint hazards. Once that complaint is filed, the health department is required to follow up. Landlords who retaliate against tenants for filing lead complaints face serious legal consequences under New York State law.

The bottom line: if you own pre-1978 rental property in Onondaga County, assume that lead testing will eventually happen. It’s better to get ahead of it than to be caught off guard.

Onondaga County Health Department Inspection Process

When the Onondaga County Health Department initiates a lead inspection, here’s what typically happens:

• Initial notification. You’ll receive a letter or phone call informing you that an inspection has been ordered. In cases involving a child with elevated blood lead levels, this can happen quickly.
• XRF testing. An inspector will use a portable X-ray fluorescence (XRF) analyzer to test painted surfaces throughout the unit. This is non-destructive and gives immediate results. They’ll test window frames, door frames, trim, walls, and any other painted surface.
• Risk assessment. If lead is found at levels above 1.0 mg/cm2, the inspector will issue a risk assessment report identifying which surfaces are hazardous and what remediation is required.
• Order to remediate. You’ll receive a formal order with a timeline to complete lead hazard remediation. Timelines vary depending on the severity of the hazard, but 30 to 90 days is typical for non-emergency situations.
• Clearance testing. After remediation is complete, the health department will conduct clearance testing to verify the hazards have been properly addressed. You cannot pass clearance without documented proof of proper remediation methods.

Failure to comply with a health department order can result in fines starting at $1,000 per day, and in severe cases, the county can pursue legal action to force compliance.

Renovation Best Practices: The RRP Rule

If you’re doing any renovation, repair, or painting work in a pre-1978 rental property, you need to understand the EPA’s Renovation, Repair, and Painting (RRP) Rule. This applies to any work that disturbs more than 6 square feet of interior painted surface or 20 square feet of exterior painted surface.

What the RRP Rule Requires

• The work must be performed by an EPA-certified renovator working for an EPA-certified firm.
• Specific lead-safe work practices must be followed, including containment, HEPA vacuuming, and wet methods to minimize dust.
• A post-work cleaning verification must be completed and documented.
• Tenants must receive the EPA pamphlet “Renovate Right” before work begins.

This isn’t just a suggestion. The fines for violating the RRP Rule can reach $37,500 per day per violation under federal law. Even if nobody gets sick, the violation itself is enough to trigger enforcement. The EPA has been active in Upstate New York, and contractors who skip RRP compliance put both themselves and the property owner at risk.

Turnover Renovations: The High-Risk Moment

Unit turnovers are the most common time landlords run into RRP issues. You’ve got a tenant moving out, maybe some walls to patch and repaint, possibly new windows or trim work. If the building is pre-1978 and the work exceeds the square footage thresholds, RRP applies. Period.

A lot of landlords use handymen or small contractors who are not RRP-certified. This is a gamble that can go very wrong. Get it right from the start: use certified contractors for any work that disturbs paint in pre-1978 units. The cost difference is usually modest, and the liability protection is enormous.

Documentation You Must Retain

Lead paint compliance is a documentation game. If you don’t have the paperwork, you might as well not have done the work. Here’s what you need to keep on file for every pre-1978 rental unit:

• Lead paint disclosure form. Federal law requires you to provide every tenant with an EPA-approved lead paint disclosure form before they sign a lease. The tenant must sign it acknowledging receipt. Keep a copy in the tenant file. This is non-negotiable, and it applies to every lease and every renewal.
• Lead test results. If any lead testing has been performed on the property, whether by you, a previous owner, or the health department, you must disclose the results to tenants and keep copies on file.
• Remediation records. If lead hazard work has been done, keep all documentation: the scope of work, the contractor’s EPA certification, work area photos, and the clearance test results.
• RRP compliance records. For any renovation work under the RRP Rule, retain the certified renovator’s documentation, including the signed acknowledgment from the tenant that they received the “Renovate Right” pamphlet.

Keep these records for at least three years after the tenancy ends. Some attorneys recommend keeping them indefinitely, since lead exposure claims can surface many years after the fact, especially when children are involved.

What Does Lead-Safe Compliance Actually Cost in CNY?

The cost range is wide because it depends entirely on the scope of the hazard and the remediation method. Here are realistic numbers for the Syracuse market:

• Lead inspection and risk assessment: $300 to $600 per unit.
• Minor stabilization work (scraping, priming, and repainting deteriorated surfaces): $1,500 to $3,000 per unit.
• Window replacement (a common remediation strategy since windows are often the biggest lead hazard): $300 to $800 per window installed. A typical Syracuse double with 15 to 20 windows per unit can run $6,000 to $12,000.
• Full lead abatement (complete removal of all lead paint hazards): $8,000 to $15,000 or more per unit, depending on size and complexity.
• Clearance testing after remediation: $200 to $400 per unit.

For most landlords in Onondaga County, the practical approach is interim controls rather than full abatement. Interim controls (stabilizing surfaces, improving conditions to prevent paint deterioration) cost significantly less and satisfy health department requirements in most cases. Full abatement is usually only required in extreme situations or when a property owner chooses it proactively.

NYS Lead Law Updates Worth Knowing

New York State has been tightening lead regulations in recent years. A few key points for CNY landlords:

• The state’s blood lead reference level now aligns with the CDC’s lower threshold, which means more children will be flagged and more inspections will be triggered.
• New York requires visual assessments for lead paint hazards at unit turnover in certain municipalities. Syracuse is included.
• There’s ongoing legislative discussion about requiring proactive lead testing in all pre-1978 rentals, regardless of whether a child has been exposed. If that passes, the inspection volume in a city like Syracuse will increase dramatically.

Staying ahead of these changes is much cheaper than reacting to them after a violation. Budget for lead compliance as a standard operating cost, not an emergency expense.

Protect Your Tenants and Your Investment

Lead paint compliance in Central New York isn’t something you can afford to ignore or defer. The regulations are real, the enforcement is active, and the stakes are high. A single lead exposure claim involving a child can result in six-figure liability. The good news is that compliance is manageable if you plan for it and work with people who understand the process.

RenPro Property Management helps landlords across Onondaga County navigate lead paint compliance, from disclosure documentation to contractor coordination to health department communication. If you own pre-1978 rental property and want to make sure you’re covered, get in touch with our team. We’ll help you build a compliance plan that protects your tenants and your bottom line.