We audited the Philadelphia Housing Authority’s (Authority) management of lead‐based paint in its public housing program based on our assessment of the risks of lead‐based paint in public housing agencies’ (PHA) housing developments. The risk factors included the age of buildings, the number of units, household demographics, reported cases of childhood lead poisoning, and reports of missing lead‐based paint inspections in HUD’s data. The audit objective was to determine whether the Authority adequately managed lead‐based paint and lead‐based paint hazards in its public housing units.
The Authority did not adequately manage lead‐based paint and lead‐based paint hazards in its public housing units. Specifically, it did not always perform lead‐based paint visual assessments within the required timeframe and mitigate lead‐based paint hazards in a timely manner. Further, the Authority needs to improve its processes for maintaining lead‐based paint documentation and providing accurate lead‐based paint disclosures to tenants. The Authority also did not ensure that its contractors provided lead‐based paint inspection and risk assessment reports that met HUD’s requirements. These weaknesses occurred because the Authority lacked adequate procedures and controls to appropriately manage its housing units that contained lead‐based paint. As a result, households that participated in the Authority’s program were at an increased risk of being exposed to lead‐based paint hazards, particularly families with children under 6 years of age.
We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to (1) establish procedures and controls to ensure that lead‐based paint visual assessments are performed within the required timeframe; (2) implement procedures and controls to ensure that lead‐based paint hazard reduction work is performed within the required timeframe and that all identified hazards are abated or treated with interim controls; (3) maintain lead‐based paint documentation for its properties in a manner that it is readily available for review by HUD and the Authority’s tenants if requested; (4) perform a search for historical lead‐based paint documentation; and (5) implement adequate procedures and controls to ensure that accurate lead disclosures are provided to current and prospective tenants and that contracted inspectors’ deliverables comply with applicable requirements. We also recommend that the Director of the Philadelphia Office of Public Housing work in conjunction with HUD’s Office of Lead Hazard Control and Healthy Homes to (1) provide training to the Authority’s staff involved with managing lead‐based paint and technical assistance to the Authority in developing and implementing new procedures and controls and (2) assess the quality of lead‐based paint inspections and risk assessments performed by the Authority’s contractors.
Recommendations
Public and Indian Housing
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Status2023-CH-1001-001-AOpenClosedClosed on May 29, 2024
We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to establish and implement procedures and controls to ensure that lead-based paint visual assessments are performed within the required timeframe.
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Status2023-CH-1001-001-BOpenClosedClosed on May 29, 2024
We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to implement adequate procedures and controls to ensure that lead-based paint hazard reduction work is performed within the required timeframe and that all identified hazards are abated or treated with interim controls.
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Status2023-CH-1001-001-COpenClosedClosed on May 29, 2024
We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to maintain lead-based paint documentation for its properties in a manner that it is readily available for review by HUD and the Authority’s tenants if requested.
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Status2023-CH-1001-001-DOpenClosedClosed on May 29, 2024
We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to perform a search for historical lead based paint documentation and if any documents are found, compare the results from the historical documents with the results of the recent testing to identify any potential issues or inconsistencies and maintain all lead-based paint documentation related to the Authority’s properties according to HUD’s requirements.
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Status2023-CH-1001-001-EOpenClosedClosed on May 29, 2024
We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to Implement adequate procedures and controls to ensure that accurate lead disclosures are provided to current and prospective tenants.
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Status2023-CH-1001-001-FOpenClosedClosed on May 29, 2024
We recommend that the Director of the Philadelphia Office of Public Housing require the Authority to implement adequate controls to ensure that contracted inspectors’ deliverables comply with HUD’s and EPA’s requirements.
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Status2023-CH-1001-001-GOpenClosedClosed on November 07, 2023
We also recommend that the Director of the Philadelphia Office of Public Housing work in conjunction with HUD’s Office of Lead Hazard Control and Healthy Homes to provide training to the Authority’s staff involved with managing lead-based paint and technical assistance in developing and implementing new procedures and controls.
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Status2023-CH-1001-001-HOpenClosedClosed on August 01, 2024
We also recommend that the Director of the Philadelphia Office of Public Housing work in conjunction with HUD’s Office of Lead Hazard Control and Healthy Homes to assess the quality of the lead-based paint inspections and risk assessments performed by the Authority’s contractors to determine whether they are sufficient to fulfill HUD’s requirements.