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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
    Prioridad

    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 March 4, 2024, the Office of Lead Hazards Control and Healthy Homes (OLHCHH) informed us that it has drafted the Federal Register notice of its request for information from Lead Safe Housing Rule stakeholders and the general public on its proposal to adopt the Centers for Disease Control and Prevention's (CDC) blood lead reference value (BLRV) of 3.5 µg/dL as its elevated blood lead level (EBLL) under the rule. The current EBLL is 5 µg/dL. OLHCHH will be obtaining clearance of the notice, publishing the cleared version, and reviewing public comments in preparing to decide whether to change the rule's current level, and if so, to what level. OLHCHH plans on publishing the Federal Register notice by June 30, 2024, with a 60-day comment period.


    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 Noviembre 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 Agosto 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 Diciembre 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 Diciembre 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
    Prioridad

    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 February 23, 2024, the Office of Field Operations (OFO) provided the following update based on a reported exchange with OLHCHH:

    Because health care providers typically test children and adults who are at a high risk for lead exposure, the individuals tested are not representative of the entire U.S. population. Moreover, state requirements for blood lead testing and reporting vary based on local conditions, making these data incomparable across different locations or generalizable at the national, state, or local level. Another significant issue is the use of the term “screening.” Many health care providers do not test the blood unless a verbal screening indicates that a child is at risk. This means that in some areas of the country, blood testing is not performed because parents have not identified conditions that would prompt a physician to test the child through capillary or venous.

    Therefore, implementing the recommendation falls outside the purview of OFO and OFO requested closure of this recommendation.


    Analysis

    We do not agree with the recommendation closure request. On February 23, 2024, we responded to OFO that to close this recommendation, we would need the evidence and information that OIG and OFO had previously agreed upon. We had previously agreed that to close this recommendation, OFO would need to provide evidence of meetings held and summaries of the research it conducted. Our request to OFO was as follows:

    For example, what was the exchange with OLHCHH, did OFO coordinate with any other offices, and what research was conducted? The evidence should ensure that our recommendation for finding EBLL Cases Were Primarily Located in Only Two States (see report pages 15-16) is fully addressed. In an August 2022 meeting with us, HUD officials suggested several potential causes for the disproportionate number of EBLL cases on the EBLL tracker. This recommendation asks OFO to research those potential causes (and any other causes identified) for the variances and then determine what HUD could do to address it.

    On March 7, 2024, we offered to meet with OFO to discuss the recommendation. On March 8, 2024, OFO responded that it would continue to provide monthly updates on the recommendation. Therefore, we will continue to follow up with OFO monthly on this recommendation.

  •   2021-OE-0011b-07

    Closed on Febrero 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 Marzo 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.