| Date: | October 28, 2026 |
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In 2025, NYS created a new lead rental registration program. The state is requiring municipalities to inspect properties that are the most at-risk of containing lead hazards and to require landlords to remove lead safety hazards. This is a major step toward improving our housing stock here in Buffalo and protecting children from lead poisoning!
Unfortunately, the NYS Dept of Health recently put out its guidelines for running this program, and the details are highly concerning. Among other issues, NYS is telling Erie County not to require inspections until 2029—three years from now! Kids in WNY can’t wait that long! In the City of Buffalo alone, it’s expected that roughly 800 children will be lead poisoned between now and 2029. We’re urging the NYS Dept of Health to require inspections immediately, and to make other changes to their guidelines that will make the program more functional.
Below is a letter that PPG, along with 29 partner organizations sent to the Commissioner of the NYS Department of Health urging him to improve the rental registry guidelines:
October 28, 2026
Commissioner James V McDonald
New York State Department of Health
Corning Tower
Empire State Plaza
Albany, NY 12237
Dear Commissioner McDonald,
We represent 30 community organizations across Western New York. It is with great urgency that we demand changes to the New York State Department of Health (NYS DOH) rental registry guidelines. The current guidelines remove the Erie County Department of Health’s ability to enforce compliance and will result in a catastrophic continuation of the Buffalo and Erie County lead poisoning crisis. We implore you to make the following changes to the guidelines to ensure that we can address the lead poisoning crisis swiftly and safely:
Currently, the DOH requires that municipalities wait until 2029 to begin enforcement. We implore the DOH to begin enforcement immediately. Between now and 2029, an estimated 800 children will be poisoned in the City of Buffalo alone. This is unacceptable. Many landlords will need the County’s enforcement to comply with lead-safe practices. Without the County’s ability to write citations, charge fines, or deny rent collection, there are no protective measures for occupants of these homes. It is imperative that municipalities begin rental registry and inspection enforcement immediately.
The NYSDOH guidelines slow down rental inspections and delay critical public health interventions in homes. These regulations mandate that municipalities communicate and schedule inspections solely with the landlord, rather than with the tenant or landlord as is necessary. While some landlords will schedule inspections voluntarily, it’s highly unlikely that the worst landlords–those who neglect their properties and risk causing childhood lead poisoning–will schedule an inspection in a timely manner. On the other hand, if tenants understand the purpose and benefit of an inspection, they’re more likely to allow inspectors in. It is both imperative and effective for inspectors to gain access to housing units through communication with both tenant and landlord, as tenants have stakes in the matter and can coordinate these inspections themselves.
Right now, the state does not require standardized training for inspectors. A lack of consistent training or list of requirements create holes in the system for insufficient inspections, compromising the integrity and safety of rental units. Every municipality in NYS must enforce a high standard of risk assessment training for each inspector. To do this, the NYSDOH should establish a standard for inspector training that all municipalities must follow. An improper inspection is not only neglectful to public health, but also a waste of time and resources.
The state’s new regulations fail to fully address and inspect for lead hazards in soil. This is a dangerous oversight as children are vulnerable to poisoning through interactions outside with soil or lead dust. Lead from industry or paint chips can accumulate in the soil, which acts as a sink for lead pollution. In Erie County, inspectors conduct a visual assessment to identify uncovered, exposed soil that may act as a lead hazard. If snow prevents this visual assessment, County inspectors immediately schedule an inspection for the spring. New York State’s current guidelines are negligent as they do not require the follow-up soil inspection in spring, falling short of public health laws. The DOH should require municipalities to reschedule soil inspections if they are unable to perform them due to weather.
The effects of lead poisoning are permanent and life altering. Prevention starts in the home, and hundreds of children are going unprotected. The current NYS DOH guidelines are highly concerning, and–if they go unchanged–will be the cause for hundreds of irreversible cases of childhood lead poisoning. Strengthening the regulations, as recommended in this letter, is absolutely essential in preventing this harm.
We strongly urge the NYSDOH to undertake an immediate and substantive revision of the guidelines to ensure that this program is implemented in a sound, evidence‑based public health manner. Without meaningful changes, the current approach fails to safeguard the children and families of New York State from the lifelong and irreversible consequences of lead poisoning.
Thank you,
Brown Kids with Disabilities
Buffalo Center for Health Equity
Buffalo Prenatal Perinatal Network
Campaign for New York Health (WNY Hub)
Center for Elder Law and Justice
Citizen Science Community Resources, Inc.
Clean + Healthy
Cooperation Buffalo
Environmental Education Associates
Every Bottom Covered, Inc.
Health Foundation for Western & Central New York
Heart of the City Neighborhoods
Housing Opportunities Made Equal
Jericho Road Community Health Center
Jewish Family Services
Lead Free Kids New York
Liftoff WNY
Massachusetts Avenue Project
Mediation Offices of Eric A. Deutsch
My Place Home for the Homeless
Open Buffalo
Our City Action Buffalo
Our City Buffalo
Partnership for the Public Good
Right to Counsel NYC Coalition
The Tool Library
Urban Roots Cooperative Garden Market
WNY Women's Foundation
Zero Emission Vehicle Committee