We audited the Puerto Rico Public Housing Administration’s management of lead‐based paint in its public housing program based on our assessment of the risks of lead‐based paint in public housing.  The risk factors assessed included the age of buildings, the number of units, and reported cases of childhood lead poisoning.  The Puerto Rico Public Housing Administration (Authority) is the second largest public housing agency (PHA) in the country with about 53,700 public housing units, the majority of which were constructed before 1978, the oldest having been constructed in 1941.

We found that Puerto Rico Public Housing Administration has not adequately managed lead-based paint in its public housing.  It did not (1) conduct lead-based paint inspections or risk assessments, (2) maintain adequate records, (3) integrate interim controls, including ongoing maintenance and visual assessments, in its normal operations, or (4) properly disclose the presence of lead-based paint to its public housing residents.  These deficiencies are the result of weak governance and inadequate oversight by the Authority.  Leadership failed to allocate the necessary resources, implement effective risk management practices, and maintain up-to-date policies consistent with Federal regulations.  Poor information management and communication further contributed to gaps in tracking lead-based paint hazards and informing affected families.  Additionally, the lack of monitoring prevented the timely identification and correction of deficiencies, ultimately compromising the safety of public housing residents, particularly young children.  As a result, individuals and families living in the Authority’s public housing units, including those with children under 6 years of age, are at an increased risk of exposure to lead-based paint hazards shown to result in adverse health effects, a risk compounded by the absence of complete and reliable information necessary for the Authority and HUD to implement adequate mitigation measures.  While the Authority implemented procedures in HUD’s LSHR to manage elevated blood lead levels (EBLL) cases for children under 6 years of age, improvements are needed.  Specifically, the Authority (1) did not notify families of the results of its environmental investigations, (2) did not notify HUD in a timely manner of the results of environmental investigations, and (3) did not perform hazard reduction in one case.  The Authority’s policies for managing EBLL cases were outdated and contained operational and communication deficiencies, indicating the need for continued efforts to strengthen monitoring and ensure the protection of residents, particularly young children.  While the Authority took steps to complete environmental investigations for EBLL cases, individuals and families, especially those with children under 6 years old, were not adequately informed of lead-based paint hazards, increasing the risk of prolonged exposure and delayed medical intervention.

We recommend that the Director of the Caribbean Office of Public Housing require the Authority to (1) conduct risk assessments in public housing without adequate lead-based paint inspection documentation to ascertain the existence of lead-based paint hazards, (2) conduct lead-based paint inspections at public housing where removal methods had been applied but  an abatement report is unavailable, (3) abate or implement interim control measures to reduce the risk of exposure to lead-based paint hazards identified through risk assessments, (4) implement an ongoing maintenance program for lead-based paint to ensure units remain hazard free, (5) develop and implement adequate policies and procedures regarding the management of lead-based paint in public housing, including adequate record-keeping practices, completing interim controls, and conducting ongoing maintenance for lead-based paint and (6) ensuring   appropriate and accurate disclosures to prospective and current tenants.  We also recommend that the Director of the Caribbean Office of Public Housing require the Authority to (1) revise and update the Authority’s policies to ensure that environmental investigations are completed for all EBLL cases, and ensure that HUD and residents are notified of the results of environmental investigations in a timely manner, (2) coordinate with HUD to train the Authority’s staff on managing EBLL cases, and to provide technical assistance such as developing written procedures, improving internal controls, or contracting with subject matter experts on procedures and controls to address the issues cited in this report, and (3) provide evidence that it abated lead-based paint hazards in one EBLL case where the Authority did not abate the hazards identified in an environmental investigation.