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According to the Centers for Disease Control and Prevention (CDC), lead-based paint and lead-contaminated dust are some of the most widespread and hazardous sources of lead exposure for young children in the United States.  There is no safe blood lead level in children, and there is no cure for lead poisoning.  Therefore, it is important to prevent exposure to lead, especially among children.

U.S. Department of Housing and Urban Development (HUD) officials reported that policies and guidance related to lead-based paint hazards and elevated blood lead levels (EBLL) were clear and well written.  However, HUD did not align its EBLL value to CDC’s blood lead reference value (BLRV) for children under the age of 6.  As of August 2022, HUD was using the EBLL value of 5 micrograms of lead per deciliter of blood (µg/dL), despite CDC lowering the BLRV to 3.5 µg/dL in October 2021.  By aligning EBLL processes with CDC’s BLRV, HUD can help to ensure that cases of children with EBLLs between 3.5 µg/dL and 4.9 µg/dL are reported and monitored.

HUD uses its EBLL tracker to monitor cases of children with identified EBLLs residing in public housing.  However, the EBLL tracker’s data fields needed improvement.  For example, the EBLL tracker did not enable field staff to reference historical EBLL cases; indicate how many children living in a housing unit had an EBLL; or specify whether the unit, building, or development previously had an EBLL case.  Additionally, the EBLL tracker contained instances of unreliable data, which reduced its usefulness to HUD officials and hindered HUD’s ability to monitor EBLL cases and ensure that children residing in public housing with confirmed EBLLs were living in lead-safe units.  Lastly, we compared the percentage of public housing development buildings constructed before 1978 to a snapshot of the EBLL tracker.  We found it notable that New York and Pennsylvania together accounted for virtually all (94.1 percent) of EBLL tracker cases of children living in public housing with an EBLL resulting from a confirmed lead-based paint hazard.  This result was despite other States’ having the same amount or more public housing development buildings built before 1978, when lead-based paint was banned.

HUD uses its lead-based paint response (LBPR) tracker to monitor and resolve cases in which public housing agencies had missing or incomplete lead-related documentation.  However, the COVID-19 pandemic halted HUD’s Real Estate Assessment Center inspection process, which determines whether HUD needs to create an LBPR tracker case for the inspected property.  Additionally, there are no timeliness standards for the LBPR tracker, and we identified several cases in which there was no evidence of HUD action for long periods.  Developing timeliness standards for the LBPR tracker would help HUD avoid delays in closing LBPR tracker cases.

By improving its EBLL tracker and LBPR tracker, HUD could better ensure that it has accurate, complete, and useful data regarding where EBLLs and lead-based paint hazards are prevalent.

Recommendations

Lead Hazard Control

  •   2021-OE-0011b-01
    Priority

    Update HUD regulations, policies, and procedures following the regulatory process required by the amended Lead Safe Housing Rule, in consideration of CDC’s lowered BLRV of 3.5 ug/dL.


    Status

    On June 12, 2024, the Office of Lead Hazard Control and Healthy Homes informed HUD OIG that the draft Federal Register notice of its request for information from Lead Safe Housing Rule stakeholders and the general public on its proposal to adopt CDC's BLRV of 3.5 µg/dL as its EBLL under the rule has been circulated for OGC and preclearance review, which will be followed by Departmental clearance. OLHCHH plans on publishing the Federal Register notice by June 30, 2024, with a 60-day comment period. OLHCHH will provide the link and the link and the notice once it is published. OLHCHH will then review public comments in preparing to decide whether to change the rule's current level, and if so, to what level.

    The Office of Lead Hazard Control and Healthy Homes estimated this will be completed by June 30, 2024.


    Analysis

    To fully address this recommendation, OLHCHH must provide evidence that it has updated its regulations, policies, and procedures so that they are consistent with CDC’s lowered BLRV of 3.5 ug/dL.

    Alternatively, OLHCHH must establish that its research led it to determine that environmental interventions in cases of children with EBLLs between 3.5 and 4.9 µg/dL were ineffective in reducing the children’s blood lead levels and that lowering HUD’s EBLL regulation to 3.5 µg/dL is unnecessary.

    Implementation of this recommendation will help ensure children living in public housing with EBLLs receive effective environmental interventions.

Public and Indian Housing

  •   2021-OE-0011b-02

    Closed on November 13, 2023

    Create a plan and timeline that outlines OFO’s proposal to make necessary improvements to the EBLL tracker, such as moving it to a different platform.

  •   2021-OE-0011b-03

    Closed on August 25, 2023

    Provide field office staff access to historical data in the EBLL tracker to be readily available as needed, with adequate protection of PII.

  •   2021-OE-0011b-04

    Closed on December 08, 2023

    Update the EBLL tracker to show whether one or multiple children have an EBLL and whether the unit, building, or development previously had an EBLL reported.

  •   2021-OE-0011b-05

    Closed on December 08, 2023

    Update the EBLL tracker by including which data fields are required, establishing what type of information can be entered into each data field, and disallowing case closure if required information is missing.

  •   2021-OE-0011b-06
    Priority

    PIH in coordination with other HUD offices as necessary, research and address potential causes of the variance in the number of EBLL cases among States on the EBLL tracker and identify solutions that are within HUD's control.


    Status

    On May 7, 2024, the Office of Field Operations (OFO) stated that it met with the Real Estate Assessment Center (REAC) and Office of Lead Hazard Control and Healthy Homes (OLHCHH) on March 4 and April 23 and agreed that OFO and OLHCHH will review CDC data on counties with the highest prevalence of EBLLs in children for counties whose states that have reported their BLL data to CDC. OFO will review its EBLL tracker to determine reporting rates by the largest public housing authorities in those counties. OLHCHH will assign an analyst to summarize the most recently available prevalence rates based on selected states. Subsequently, OFO will scrutinize public housing authorities within those states to ascertain the reported cases.

    The revised estimated completion date is February 28, 2025.


    Analysis

    To fully address this recommendation, OFO must provide evidence of meetings held and summaries of the research conducted. For example, what was the exchange with OLHCHH, did OFO coordinate with any other offices, and what research was conducted? OFO needs to research potential causes for the variances and determine what HUD could do to address them.

    Alternatively, OFO must establish that there are no solutions within HUD’s control to address any identified causes.

    Implementation of this recommendation will help ensure that EBLL cases are reported and recorded appropriately in the EBLL tracker.

  •   2021-OE-0011b-07

    Closed on February 28, 2023

    Create a plan and timeline that outlines OFO’s proposal to move the LBPR tracker to a different platform.

  •   2021-OE-0011b-08

    Closed on March 07, 2024

    Develop a timeliness standard in the LBPR tracker to establish expectations for how often field office staff must reach out to PHAs on the LBPR tracker to discuss measures that will resolve cases in a timely manner.