Under the Lead Safe Housing Rule (LSHR), owners of multifamily properties receiving assistance from the U.S. Department of Housing and Urban Development (HUD) must comply with specific requirements following reports that a child under the age of 6 residing in an assisted unit has a confirmed elevated blood lead level (EBLL).  Some of these requirements are (1) ensuring that an environmental investigation is conducted to determine the source of the lead poisoning, (2) timely remediating or abating the source of the lead poisoning, if applicable, and (3) notifying both the Office of Multifamily Housing Programs (Multifamily) and the Office of Lead Hazard Control and Healthy Homes (OLHCHH) throughout the process.  HUD requires owners to report EBLL response information to both HUD Field Offices and OLHCHH because such information must be received timely to ensure efficient and effective program administration and to monitor whether the owner has taken timely and appropriate steps to protect children who live in HUD-assisted multifamily housing.

We found that Multifamily lacks policies and processes to effectively ensure that property owners are managing reported EBLLs and are taking appropriate and timely steps to investigate and mitigate lead hazards.  First, Multifamily has no internal policy specifying how staff should oversee property owners’ compliance with LSHR requirements following a potential or confirmed EBLL.  Additionally, Multifamily’s property management information system, the Integrated Real Estate Management System (iREMS), is used to document digital files and interactions with property owners but was not designed to track reported EBLLs or property owners’ actions to mitigate lead hazards.  HUD has received only two reports of EBLLs from multifamily property owners during fiscal years 2019 to 2024, and information on those reports in iREMS was either nonexistent or limited in nature.

To improve its oversight of owners’ responsibilities under the LSHR, Multifamily should (1) develop and implement a policy that clearly defines its staff’s roles and responsibilities for EBLL-related requirements and (2) establish a process to track reported EBLLs as well as actions required of property owners to mitigate lead hazards.  Without implementing these measures, HUD will not have assurance that property owners who have children with EBLLs residing in their properties are taking timely and appropriate steps to protect residents from continued exposure to lead hazards.

We provided HUD with two recommendations to ensure HUD’s compliance with the LSHR’s specific requirements following reports that a child under the age of 6 residing in an assisted unit has a confirmed EBLL.