September 28, 2021

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Lead Paint in Housing: HUD Has Not Identified High-Risk Project-Based Rental Assistance Properties

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<div>During fiscal years 2018 and 2019, the Department of Housing and Urban Development (HUD) obligated about $421 million through two grant programs to state and local governments to help identify and control lead paint hazards in housing for low-income households. HUD also issued guidelines for evaluating and controlling lead paint hazards, generally encouraging abatement (such as replacing building components containing lead) as the preferred long-term solution. HUD has supported research on lead paint hazard control and provided education and outreach to public housing agencies, property owners, and the public through publications and training events. HUD monitors lead paint-related risks in its Project-Based Rental Assistance Program, one of HUD's three largest rental assistance programs, through management reviews and periodic physical inspections, but has not conducted a comprehensive risk assessment to identify properties posing the greatest risk to children under the age of 6. HUD's management reviews include assessing property owners' compliance with lead paint regulations—such as by reviewing lead disclosure forms, records of lead inspections, and plans to address lead paint hazards. Inspectors from HUD's Real Estate Assessment Center also assess the physical condition of properties, including identifying damaged paint that could indicate lead paint risks. According to HUD officials, they have not conducted risk assessments in project-based rental assistance housing because they believe the program has relatively few older and potentially riskier properties. However, GAO's analysis of HUD data found that 21 percent of project-based rental assistance properties have at least one building constructed before 1978 (when lead paint was banned in homes) and house over 138,000 children under the age of 6. If HUD used available program data to inform periodic risk assessments, HUD could identify which of the properties pose the greatest risk of exposure to lead paint hazards for children under the age of 6. Unless HUD develops a strategy for managing the risks associated with lead paint and lead paint hazards in project-based rental assistance housing, it may miss the opportunity to prevent children under the age of 6 from being inadvertently exposed to lead paint in those properties. Project-Based Rental Assistance Properties with at Least One Building Built before 1978 and That House Children under Age 6, as of December 31, 2019 Note: Children under the age of 6 are at the greatest risk of lead exposure because they have frequent hand-to-mouth contact, often crawl on the floor, and ingest nonfood items. Lead paint exposure in children under the age of 6 can cause brain damage, slowed development, and learning and behavioral problems. Exposure to lead paint hazards can cause serious harm to children under 6 years old. HUD is required by law to reduce the risk of lead paint hazards in HUD-assisted rental housing—including project-based rental assistance (subsidies to make privately owned multifamily properties affordable to low-income households). The 2019 Consolidated Appropriations Act Joint Explanatory Statement includes a provision for GAO to review, among other things, HUD's oversight of lead paint and related hazards in affordable rental housing. This report (1) describes how HUD programs and guidance address lead paint hazards in HUD-assisted and other low-income rental housing, and (2) examines HUD's oversight procedures for assessing risk for lead paint hazards in project-based rental assistance housing. GAO reviewed HUD and Environmental Protection Agency (EPA) lead paint regulations and documents on lead programs and methods for addressing lead paint hazards. GAO reviewed HUD oversight policies and procedures and analyzed HUD data on building and tenant age. GAO interviewed staff at HUD, EPA, and organizations that advocate for safe affordable housing. GAO recommends that HUD (1) conduct periodic risk assessments for the Project-Based Rental Assistance Program and (2) develop and implement plans to proactively manage identified lead paint risks. HUD agreed to conduct periodic risk assessments and develop and implement a plan to proactively manage risks. For more information, contact John H. Pendleton at (202) 512-8678 or pendletonj@gao.gov.</div>

What GAO Found

During fiscal years 2018 and 2019, the Department of Housing and Urban Development (HUD) obligated about $421 million through two grant programs to state and local governments to help identify and control lead paint hazards in housing for low-income households. HUD also issued guidelines for evaluating and controlling lead paint hazards, generally encouraging abatement (such as replacing building components containing lead) as the preferred long-term solution. HUD has supported research on lead paint hazard control and provided education and outreach to public housing agencies, property owners, and the public through publications and training events.

HUD monitors lead paint-related risks in its Project-Based Rental Assistance Program, one of HUD’s three largest rental assistance programs, through management reviews and periodic physical inspections, but has not conducted a comprehensive risk assessment to identify properties posing the greatest risk to children under the age of 6. HUD’s management reviews include assessing property owners’ compliance with lead paint regulations—such as by reviewing lead disclosure forms, records of lead inspections, and plans to address lead paint hazards. Inspectors from HUD’s Real Estate Assessment Center also assess the physical condition of properties, including identifying damaged paint that could indicate lead paint risks. According to HUD officials, they have not conducted risk assessments in project-based rental assistance housing because they believe the program has relatively few older and potentially riskier properties. However, GAO’s analysis of HUD data found that 21 percent of project-based rental assistance properties have at least one building constructed before 1978 (when lead paint was banned in homes) and house over 138,000 children under the age of 6. If HUD used available program data to inform periodic risk assessments, HUD could identify which of the properties pose the greatest risk of exposure to lead paint hazards for children under the age of 6. Unless HUD develops a strategy for managing the risks associated with lead paint and lead paint hazards in project-based rental assistance housing, it may miss the opportunity to prevent children under the age of 6 from being inadvertently exposed to lead paint in those properties.

Project-Based Rental Assistance Properties with at Least One Building Built before 1978 and That House Children under Age 6, as of December 31, 2019

Note: Children under the age of 6 are at the greatest risk of lead exposure because they have frequent hand-to-mouth contact, often crawl on the floor, and ingest nonfood items. Lead paint exposure in children under the age of 6 can cause brain damage, slowed development, and learning and behavioral problems.

Why GAO Did This Study

Exposure to lead paint hazards can cause serious harm to children under 6 years old. HUD is required by law to reduce the risk of lead paint hazards in HUD-assisted rental housing—including project-based rental assistance (subsidies to make privately owned multifamily properties affordable to low-income households).

The 2019 Consolidated Appropriations Act Joint Explanatory Statement includes a provision for GAO to review, among other things, HUD’s oversight of lead paint and related hazards in affordable rental housing. This report (1) describes how HUD programs and guidance address lead paint hazards in HUD-assisted and other low-income rental housing, and (2) examines HUD’s oversight procedures for assessing risk for lead paint hazards in project-based rental assistance housing.

GAO reviewed HUD and Environmental Protection Agency (EPA) lead paint regulations and documents on lead programs and methods for addressing lead paint hazards. GAO reviewed HUD oversight policies and procedures and analyzed HUD data on building and tenant age. GAO interviewed staff at HUD, EPA, and organizations that advocate for safe affordable housing.

What GAO Recommends

GAO recommends that HUD (1) conduct periodic risk assessments for the Project-Based Rental Assistance Program and (2) develop and implement plans to proactively manage identified lead paint risks. HUD agreed to conduct periodic risk assessments and develop and implement a plan to proactively manage risks.

For more information, contact John H. Pendleton at (202) 512-8678 or pendletonj@gao.gov.

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