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
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Status2021-OE-0011b-01OpenClosedPriorityPriority
We believe these open recommendations, if implemented, will have the greatest impact on helping HUD achieve its mission to create strong, sustainable, inclusive communities and quality affordable homes for all.
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 November 22, 2024, the Office of Lead Hazard Control and Healthy Homes (OLHCHH) informed HUD OIG that the final Federal Register Notice was published for its request for information from Lead Safe Housing Rule stakeholders and the general public on its proposal to adopt the CDC's BLRV of 3.5 µg/dL as its EBLL under the rule. The public comment period ended on October 11, 2024, and as of October 15, 2024, all 25 comments submitted have been posted to https://www.regulations.gov/docket/HUD-2024-0069/comments. OLHCHH is reviewing the public comments in preparing to decide whether to change the rule's current level, and if so, to what level.
The estimated completion date is June 30, 2025.
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
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Status2021-OE-0011b-02OpenClosedClosed 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.
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Status2021-OE-0011b-03OpenClosedClosed 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.
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Status2021-OE-0011b-04OpenClosedClosed 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.
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Status2021-OE-0011b-05OpenClosedClosed 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.
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Status2021-OE-0011b-06OpenClosedPriorityPriority
We believe these open recommendations, if implemented, will have the greatest impact on helping HUD achieve its mission to create strong, sustainable, inclusive communities and quality affordable homes for all.
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
As of November 13, 2024, the PIH Office of Field Operations (OFO) had completed its outreach data collection and identified 9 public housing authorities that had not completed the required EBLL reporting actions and that OFO informed the field office directors overseeing the appropriate PHAs that they had until November 6, 2024, to upload the proper information to the trackers. OFO had not received confirmation that the data had been uploaded.
The estimated completion date is February 28, 2025.
Analysis
To fully address this recommendation, OFO must provide evidence that it coordinated with other HUD offices and identified the causes of the variances in the number of EBLL cases among states on the EBLL tracker. OFO must also demonstrate that it fully remedied the causes of the variances.
Alternatively, OFO must provide an explanation sufficient to support a claim that it could not identify the causes of the variances or develop and implement solutions for problems it identified in its research.
Implementation of this recommendation will result in improved HUD data of EBLL cases of children living in public housing across the country. Accurate reporting of EBLL cases to HUD is essential so that HUD can ensure PHAs take effective environmental interventions that help prevent additional lead exposure.
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Status2021-OE-0011b-07OpenClosedClosed on February 28, 2023
Create a plan and timeline that outlines OFO’s proposal to move the LBPR tracker to a different platform.
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Status2021-OE-0011b-08OpenClosedClosed 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.