The Housing Authority of the City of Los Angeles Did Not Adequately Manage Lead-Based Paint in Its Public Housing Units

We audited the Housing Authority of the City of Los Angeles’ management of lead-based paint and lead-based paint hazards in its public housing units. We selected the Authority based on our assessment of the risks of lead‐based paint in public housing agencies’ (PHA) housing developments, including the age of buildings, the number of units, household demographics, and reported cases of childhood lead poisoning. The audit objectives were to determine whether the Authority (1) complied with HUD’s requirements for children with elevated blood lead levels (EBLL) and (2) adequately managed lead‐based paint and lead‐based paint hazards in its public housing units. The Authority appropriately managed a case of a child with an EBLL. It also maintained lead-based paint inspection reports for the 69 units reviewed. However, the Authority did not adequately manage lead-based paint and lead-based paint hazards in its public housing units. Specifically, for all 69 units reviewed, the Authority did not complete visual assessments in a timely manner. The Authority also did not conduct risk assessments and reevaluations for lead-based paint stabilization projects at 5 of the 10 developments reviewed, which included work at approximately 200 buildings. These issues occurred because the Authority (1) misapplied HUD’s waiver of the requirement for physical inspections during the coronavirus 2019 pandemic to visual assessments and (2) misinterpreted HUD’s requirements for visual assessments. The Authority also used standard treatments for remediating lead-based paint hazards; however, that method for remediating lead-based paint hazards does not apply to public housing, and it incorrectly believed that work performed was for lead maintenance in preparation for exterior painting rather than hazard reduction. Further, the Authority lacked adequate policies, procedures, and controls to ensure that it appropriately managed its housing units that contained lead-based paint. As a result, households that participated in the Authority’s program were at an increased risk of exposure to lead-based paint hazards, particularly families with children under 6 years of age. We recommend that the Director of the Los Angeles Office of Public Housing require the Authority to (1) implement adequate procedures and controls to ensure that visual assessments for lead-based paint are completed at least every 12 months; (2) implement adequate procedures and controls to ensure that risk assessments and reevaluations are conducted in accordance with HUD’s requirements; (3) obtain lead-based paint risk assessments and applicable reevaluations for its developments as applicable; and (4) coordinate with HUD’s Office of Lead Hazard Control and Healthy Homes to obtain training for the Authority’s employees on the management of lead-based paint, including the requirements for visual assessments, risk assessments, reevaluations, and hazard reduction.