7/6/2016
NCHH's Chief Scientist David Jacobs, Director of Research Jonathan Wilson, and Director of Policy Julie Kruse submitted a comment to HUD's proposed rule FR–5928–N–01, Notice of Demonstration to Test Proposed New Method of Assessing the Physical Conditions of Voucher-Assisted Housing. The comment is viewable on Regulation.gov as of this afternoon.
While it supports the development of UPCS-V as "an important step forward" toward the alignment of HUD inspection protocols into a uniform one that will protect both public health and the taxpayer investment for federally assisted properties, NCHH noted some specific deficiencies in the draft UPCS-V Dictionary of Definitions. NCHH compared the draft dictionary against the to the National Healthy Housing Standard, a comprehensive tool created in 2014 by NCHH and the American Public Health Association (APHA) to help improve codes, and noted 30 improvements that were absent from the draft dictionary. Additionally, NCHH made six additional recommendations to items that were in the draft dictionary.
"In particular," wrote NCHH, "we would like to highlight what we believe is a key deficiency in the draft documents you have posted at the HUD UPCS-V webpage regarding lead-based paint. Specifically, the draft UPCS-V Dictionary of Definitions at [link] does not require the standard HUD/EPA lead-based paint risk assessment protocol. Instead, on p. 216, the draft document persists in the use of only a visual assessment for deteriorated paint. This ignores the main pathway of exposure for most children today, which is contaminated house and soil dust lead and the deteriorated lead-based paint from which it comes."
Read the full comment here.