Lead Paint in Housing: HUD Has Not Identified High-Risk Project-Based Rental Assistance Properties
Fast Facts
The law requires the Department of Housing and Urban Development to reduce the risk of lead paint hazards in HUD-assisted housing. Exposure to lead paint can cause brain damage and slow development in children under 6 years.
HUD monitors lead paint-related risks in its Project-Based Rental Assistance program that provides subsidies to make privately owned multifamily properties affordable to low-income households. Although HUD periodically does physical inspections, it hasn't done a comprehensive risk assessment to identify the properties posing the greatest risk to young children. We recommended it assess and manage such risks.
Highlights
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.
Recommendations
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.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Housing and Urban Development | The Deputy Assistant Secretary for the Office of Multifamily Housing Programs, in collaboration with the Director of HUD's Office of Lead Hazard Control and Healthy Homes, should periodically conduct a risk assessment for the PBRA program to identify which properties have the greatest risk of exposing children under the age of 6 to lead paint hazards. (Recommendation 1) |
As of January 2021, HUD's Deputy Assistant Secretary for Multifamily Housing Programs, in collaboration with the Director of HUD's Office of Lead Hazard Control and Healthy Homes, planned to periodically conduct a risk assessment for the PBRA program based on resources available to identify which properties have the greatest risk of exposing children under the age of 6 to lead paint hazards. As of February 2024, HUD was still in the process of building a "data repository." HUD officials told us that this repository would include data on properties built prior to 1978 as well as occupancy data to identify households with children under 6. HUD officials stated that once the data repository was built, they would be able to identify properties with the greatest risk of exposing children under the age of 6 to lead paint hazards. As of January 2025, HUD has made great progress on building the data repository, but because it is a living document, they will continue working to update the data fields, particularly to identify the construction date of properties and other elements of risk. In addition, they had developed ideas for how to use the data repository by targeting the oldest properties based on the date of construction. HUD is developing a written plan for conducting the risk assessments using data in the data repository and other sources. This recommendation will remain open until HUD provides the written plan and conducts risk assessments.
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| Department of Housing and Urban Development | The Deputy Assistant Secretary for the Office of Multifamily Housing Programs, in collaboration with the Director of HUD's Office of Lead Hazard Control and Healthy Homes, should develop and implement plans to proactively manage the risks associated with lead paint hazards in PBRA properties identified in the periodic risk assessments. (Recommendation 2) |
As of January 2021, HUD's Deputy Assistant Secretary for Multifamily Housing Programs, in collaboration with the Director of HUD's Office of Lead Hazard Control and Healthy Homes, planned to develop and implement plans to proactively manage the risks associated with lead paint hazards in PBRA properties identified in programmatic risk assessments. As of February 2024, HUD was in the process of building a database which would enable them to identify risky properties. As of January 2025, HUD had made great progress on building the data repository, but because it is a living document, they will continue working to update the data fields, particularly to identify the construction date of properties and other elements of risk. Using the data, HUD has developed several ideas for how to use the data repository to target risky properties. For example, they will identify the oldest properties based on the date of construction, provide a list to the health department to see if lead problems have been reported in any of them, and specifically target those with a yes from the health department. HUD also plans to target properties that have peeling paint as identified in REAC inspections and review Management and Occupancy Reviews to identify the oldest and riskiest units. HUD is working to develop a written plan for how they will conduct these risk assessments. This recommendation will remain open until HUD provides a written plan identifying their steps to proactively manage the risks associated with lead paint hazards identified in these periodic assessments.
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