While conducting an ongoing audit of the Philadelphia Housing Authority’s (Authority) management of lead-based paint hazards in its public housing units, we identified a significant gap in HUD’s program requirements related to safe work practices, which we believe requires immediate action by HUD. We identified that the Authority determined a substantial percentage of maintenance and hazard reduction work performed on surfaces with lead-based paint in its public housing units was “de minimis”, or minor. The Authority’s determinations exempted the work from H