New York City property owners are subject to strict lead paint regulations to protect tenants from hazardous exposure — especially young children. One violation you may encounter is Order #623, a Class B violation issued by the NYC Department of Housing Preservation and Development (HPD).
If you’re a landlord or owner of a residential building in NYC, here’s what you need to know about this violation — and how to avoid or resolve it.

What Is HPD Order #623?

Order #623 is issued when a property owner fails to provide lead paint turnover documentation upon request. Specifically, this violation applies when:

• A tenant moved into the unit within the last 10 years, and
• The owner cannot produce required lead documentation during an HPD inspection.
• This violation is issued per unit, meaning multiple fines can be applied across a building.

When Does It Happen?

During field audits tied to:

• A COTA (Certification of Turnover Activities) inspection
• The HPD Lead Index Audit

When an occupant confirms they moved in within the last 10 years
The owner fails to submit records following an HPD Record Production Order

How to Resolve a 623 Violation

There are two main ways to deal with a 623 violation:

Option 1: Provide Proper Turnover Documents

You can clear the violation by submitting:

• Documentation of lead-based paint compliance at turnover,
• Proof that proper inspections, risk assessments, or abatement were completed before the current tenant moved in.

Option 2: Submit Negative XRF Test Results

Alternatively, you may submit:

• Negative XRF test results (showing no lead paint) for all door and window friction surfaces in the unit.

What If Lead Is Found?

If any door or window tests positive or is untested, you must:

• Abate those surfaces using EPA-certified abatement contractors
• Hire a third-party EPA-certified firm to conduct dust wipe clearance tests
• Submit all required documentation to certify compliance with the violation

What Are the Penalties?

Failure to comply with a 623 violation comes with a $1,500 fine per violation.
Additionally:

• Owners can request a postponement of the correction date, but must follow the instructions included in the Notice of Violation.
• Delays or inaction may lead to further enforcement actions by HPD.

Final Takeaway

Order #623 is serious — but manageable. If you’re a property owner in NYC, keep your turnover records organized and stay proactive with  lead paint test compliance. Whether you’re managing a single-family home or a multi-unit building, staying ahead of inspections and documentation can save you thousands in fines — and protect your tenants.
Need help understanding NYC lead paint rules or getting compliant? Feel free to reach out or consult HPD’s official lead paint page.