• (9/13)
  Q) During an inspection, an inspector visually verifies a property with two towers adjacent to one another. The property representative explains that the properties have common ownership. The 2^nd tower is a separate property and has its own unique property ID number, however the property being inspected, has no laundry facilities or common areas and the residents use the common areas in the 2^nd tower. How should the inspector proceed to inspect common areas in this scenario?
  
  

  - Would it make a difference if the towers given in the example were owned by different owners?

  - Would inspectors use the same guidance regardless of the property type (servicing mortgagee, Section 8 and Public Housing)?

  A) The property profile is correlated to the property ID number, regardless of ownership. In this scenario, inspectors should inspect only the building(s) associated with the assigned property ID number. Off-site common areas such as offices, laundry, etc. should not be inspected as part of the inspectable property. If the inspector has questions/concerns about the property profile he/she should contact TAC to obtain profile verification.

- No, it does not make a difference if the towers have different owners or if they are the same.

- Yes, inspectors would following this guidance for all UPCS inspections.

• (8/13)
  Q) During an inspection, the inspector visually verifies 30 residential buildings and 3 common buildings. While reviewing the profile, the POA notifies the inspector that one of the Common Buildings is temporarily off-line. The inspector does not see any evidence of maintenance or rehabilitation, but does verify that the building is currently not in use.

  In accordance with the protocol, the inspector includes the temporary off-line building in the profile and generates the sample. The sample generated includes 22 residential buildings and all 3 common buildings. The inspector takes 1 common building off-line and notates “uninspectable” in the building tab.  In an effort to meet the sample, does the inspector have to select an alternate building? What should the inspector do if he/she does not have a “like” alternate building? Should he/she replace this common off-line building with a residential building?

  A) If the inspector is unable to meet the sample using an alternate “like” building, he must secure a TAC number, and document the reason for not meeting the sample generated.  The inspector should not replace common buildings with residential buildings, as common buildings and residential buildings are not considered “like” buildings.

  Note:   Public Housing “Temporary Off-Line” buildings should be included in the profile and not designated as “vacant” until after generating the sample (See Reference (2)). The inspector must record any observable health and safety hazards that an off-line building poses to residents under Site - H&S – Hazards – Other.  Inspector must reference the associated building in the comment section.

  Note:  In accordance with Multifamily protocol, the inspector must verify supporting documents from the local HUD Field Office identifying specifically which buildings/units are to be taken off-line (See Reference( 3). The inspector must record any observable health and safety hazards that an off-line building poses to residents under Site - H&S – Hazards – Other.  Inspector must reference the associated building in the comment section.

  Reference (1): Compilation Bulletin, Rev. 2.1, Page 10, Buildings & Units, Paragraph E, Buildings Off-line, 1. During an inspection, the inspector may find that some buildings are off-line. (b) Temporary Off-Line Building:  These are buildings that the property has taken off-line temporarily for rehabilitation activities. These buildings must be 100% vacant and may be boarded-up for security purposes. Include these buildings/units in the profile prior to generating the sample. If selected as a sample building, record the building as “uninspectable” with the appropriate reason after visual verification and select the next alternate building in the listing. If the inspector cannot meet the building/unit sample requirements, the inspector must secure a TAC reference number before uploading the completed inspection.

  Reference (2): Compilation Bulletin, Rev. 2.1, Page 11, Buildings & Units, Paragraph F, Clarification for Off-line Buildings and Units (Public Housing and Multifamily Housing), 1. Public Housing (b) Temporary Off-Line Buildings/Units: The PHA has set these aside and they are undergoing or awaiting modernization or HOPE VI funding for rehabilitation. In all instances, the PHA has plans to bring them back on-line sometime in the future, regardless of how long in the future. These buildings/units may or may not be boarded-up, but they must be vacant. These buildings/units are to be included in the rent roll or some other comparable property management rental records. If the entire building is taken off-line with no sign of maintenance/management activities, the building is considered and recorded as “vacant” after the sample has been generated.

  Reference (3): Compilation Bulletin, Rev. 2.1, Page 11, Buildings & Units, Paragraph F, Clarification for Off-line Buildings and Units (Public Housing and Multifamily Housing), 2. Multifamily Housing, (c) Temporary Off-Line Buildings/Units: In Multifamily Housing, they are considered/treated the same as vacant buildings/units and are subject to the 15% threshold. The inspector is to inspect these off-line buildings/units if selected as a part of the sample. However, the property owner/agent (POA) may designate buildings/units as temporarily off-line at the time of the inspection and these buildings/units are not subject to the 15% threshold inspection requirement. The inspector should follow the procedure outlined below when the POA is requesting the exclusion of off-line buildings/units during the inspection:

  1. The POA must provide to the inspector, (on the day of the inspection before verifying the property profile information), a letter from the local HUD Field Office approving and identifying the buildings/units to be taken off-line.
      
  2. The inspector must reference this letter in the property comment field in the DCD.
      
  3. Buildings/units that are designated and approved as temporary off-line must remain in the building/unit count and the inspector shall include them in the property profile when generating the sample.
      
  4. If a building that is designated as temporary off-line is selected as a part of the sample, the inspector must visually verify that it is off-line and select an alternate.
      
  5. If a dwelling unit that is designated as temporary off-line is selected as a part of the sample, the inspector must visually verify that it is off-line and select an alternate.
      
  6. Though not to be inspected, the inspector must record any observable health and safety hazards that an off-line building or unit poses to other residents.
      
• (5/13)
  Q)  In a sample unit, the inspector notices the hot water heater is under the kitchen cabinet and there is no access to the tank. Since the inspector is unable to observe the unit, how should he/she evaluate this situation?
  
  A)  In some cases, water heaters may be inaccessible or located in permanently secured spaces. If the inspector finds hot water at the tap and observes no signs of a leak, then he/she should record Unit/Hot Water Heater/ NOD.

  (DCD 2.3.4) If hot water is not available at the tap, the inspector should record Unit/Hot Water Heater/Inoperable Unit/Components (L3).  If the inspector observes any evidence of a leak, he/she should record Unit/Hot Water Heater/Leaking Valves/Tanks/Pipes (L3).  Any health and safety concerns are recorded manually in “Health and Safety Hazards”.

  (RAPID 4.0) If hot water is not available at the tap, the inspector should follow Decision Tree as Unit/Location/Water Heater/ Water from the hot water taps is not warmer than room temperature (L3) Defect Applies, Comment Required.  If the inspector observes any evidence of a leak, he/she should follow Decision Tree as Unit/Water Heater/Location/Water is leaking from any water system component, hose bib/Condition May/May Not result in Health and Safety Concern (L3) Defect Applies, Comment Required.

  *Note:  The hose bib referred to here is unit specific. For hose bibs on the exterior of a building that are not unit specific and are accessible by all residents, record deficiencies observed under Building/Systems/Domestic Water.

  Reference: Definition DCD v. 2.3.4, Unit/Hot Water Heater/Inoperable Unit/Components Deficiency: Hot water supply is not available, because the system or system components have malfunctioned. (L3)”After running, water from the hot water taps is not warmer than room temperature.

  Reference: Definition DCD v. 2.3.4, Unit/Hot Water Heater/ Leaking Valves/Tanks/Pipes Deficiency:  You see water leaking from any hot water system component, including the valve flanges, stems, bodies, domestic hot water tank, or its piping. (L3) “You see water leaking.”

  Reference: Definition RAPID 4.0, Unit/Water Heater/Location/Inoperable Unit/ Water is leaking from any water system component, hose bib/ (L3) Defect applies.

  Reference: Definition RAPID 4.0, Unit/Water Heater/ Location/Water from hot water taps is not warmer than room temperature/ (L3) Defect applies. 

• (4/13)
  Q) While conducting an inspection using the 4.0 software for Public Housing, the property representative informs the inspector that they have demolished and sold some of their properties but they have also added some new properties to their inventory. To save time, can the inspector simply change the addresses on the buildings that have been sold to the addresses of the newly acquired buildings in the property profile?
  
  A) No.  Unlike the 2.3 version of the software that determines the building number, in the 4.0 software, the building numbers are taken straight from IMS/PIC. The PIH Information Center (PIC) system is responsible for maintaining and gathering data about all of PIH's inventories of Housing Authorities (HAs), developments, buildings, units, HA Officials, HUD Offices and Field Staff and IMS/PIC Users.  The information that is downloaded into the 4.0 software comes directly from the PIC system. See screen shots below:
  
  
  The new buildings will have their own building identifier # on the Building Detail Report. Ask the Property Representative where that number is (you may need to refer them to their main office or PIC Coach if they themselves do not have access to this building detail report) and add it in the building number box as you add the building or simply request a detailed building list.
   
• (3/13)
  Q) The inspector observes a padlock on the door of the unit mechanical closet.  Is this a blocked egress?
  
  A) No. A padlock or any other locking mechanism used by the property to secure the unit mechanical closet will not be recorded as a blocked egress.  Additionally, similar locking mechanisms, whether installed by the residents or property, to secure the unit exterior storage closet or shed will not be recorded as a blocked egress.  All other unit closet doors will continue to be evaluated for blocked egress as stated in the previous question of the month (ref. - May/2012/QOTM).
   
• (2/13)
  Q) If peeling paint is observed on the bottom part of the sample unit's balcony, where should this be recorded?
  
  A) The peeling paint is located on the ceiling of a unit balcony that is not part of the sample. Therefore it is not inspected. No observed deficiency should be recorded.
   
• (1/13)
  Q) While inspecting the exterior of a building, the inspector observes a  missing or damaged During an inspection, an inspector observes a missing filter for the kitchen exhaust fan in a sample unit. Where should the inspector record this deficiency?
  
  A) The missing filter/screen in itself is not a recordable deficiency, however, if the exhaust is obstructed and cannot vent and there is no operable window in the area, or the fan does not function, the inspector should record "Unit - Kitchen, Range Hood/Exhaust Fans - Excessive Grease/Inoperable". Any health or safety deficiencies that are observed should be recorded as "Unit - Health and Safety, Hazards, Other".

  Reference:  DCD v. 3.2 Definition; Unit - Kitchen, Range Hood/Exhaust Fans - Excessive Grease/Inoperable -  Deficiency: The apparatus that draws out cooking exhaust does not function as it should.  L 1: An accumulation of dirt threatens the free passage of air; L2: N/A; L3: The exhaust fan does not function.

  Reference:  Compilation Bulletin Rv. 2.3, Part II Common Areas, page 27, paragraph I (5) An exhaust fan in a kitchen that has been intentionally blocked is a Range Hood/Exhaust Fans, Excessive Grease/Inoperable Level 3 deficiency, unless there is an operable window in the area.

  Reference:  Compilation Bulletin Rv. 2.3, Part II Unit, page 31, paragraph I (5) An exhaust fan in a kitchen that has been intentionally blocked is a Range Hood/Exhaust Fans, Excessive Grease/Inoperable Level 3 deficiency, unless there is an operable window in the area.

• (12/12)
  Q) While inspecting the exterior of a building, the inspector observes a  missing or damaged foundation screen. Is this a deficiency?
  
  A) No.  Vent openings in foundations are a designed feature and are not required to have screens.
  *Note: Any health and safety deficiencies related to vent openings are recorded under Exterior/Health and Safety/Other.
   
• (11/12)
  Q) While inspecting the first floor common area hallway of a mid/high rise building, an inspector observes a fire hose cabinet. The hose has been removed but the cabinet is intact and the hooks used to support the hose are still present. Is this a deficiency?  If the hooks are removed is this still a deficiency?
  
  A) Yes.  The inspector would look at the missing hose in the same way he would look at a missing fire extinguisher. To determine the correct level of deficiency, the inspector must consider the number of fire control systems and keep a running count of the number of fire extinguishers and hoses in the building.  For the second part of the question, the hooks have been removed but the cabinet remains.  In this scenario, the cabinet is still mounted to the wall. Consequently, the inspector must record a deficiency in the same way he would in the first part of the question. If however, the fire cabinet is missing, and the brackets for the cabinet remain on the wall, then this is not a deficiency.

  Current guidance considers only the number of fire control systems in the building and the percentage of either missing/damaged extinguishers or hoses where there is a fire cabinet without regard for hooks.

  Reference:  DCD v. 3.2 Definition; Missing/Damaged/Expired Fire Extinguisher; Note 1 - This includes missing/damaged fire hoses where there are fire cabinets.  Note 2. – For buildings with multiple fire control systems-stand pipes, sprinklers, etc. – 5% or less of the extinguishers for a given building may be missing, damaged, and/or expired. In such cases do not record a deficiency.

  Reference:  Compilation Bulletin Rv. 2.3, Part II Systems, page 24 paragraph 2 (b) Buildings must meet the requirements of local and state fire and safety codes. As a result, some buildings have fire extinguishers, while others do not. If fire extinguishers are not present and there is no evidence, such as mounting brackets or fire cabinets, that they are supposed to be present, it is not a deficiency.

  Reference: Compilation Bulletin Rv. 2.3, Part II Systems, page 24 paragraph 2 (c) For determining the proportionality of Missing/Damaged Expired Extinguishers, the total number of extinguishers for a building will be calculated by counting all common area and exterior extinguishers, plus the extinguishers located in the sample units. Inspector must tract the number of fire extinguishers located in each building to determine the level of deficiency.

• (9/12)
  Q) How do you inspect a scattered site?
  
  A) A Scattered Site can be defined as a property with multiple locations around a town, city, county, or state. In order to complete the inspection in the most efficient manner, it will be necessary for the inspector to drive from one location to the next. Effective March 10, 2012, inspectors are required to visit all of the locations included in the “scattered” site property to visually verify all building and unit counts prior to sample generation. After generating the sample and selecting the sample buildings and units, inspectors are only required to re-visit and inspect the sample buildings and units and the sites around the sample buildings. If a building that is selected as part of the sample is on a multiple building location, the entire site for that location must be inspected.

  Scenario #1:  For a single family scattered site property (one building per location), consisting of 30 single family homes and 10 duplexes (20 units- 50 units total on property), scattered throughout the city, an inspector must visually verify the entire property (each and every building) included in the scattered site property. After visually verifying the property, the inspector updates the property profile and generates the sample. The software selects a sample of 16 buildings and 18 units. The inspector is required to re-visit only the sample buildings to inspect the five (5) inspectable areas (Site, Exterior, Systems, Common Areas and Units). The inspector does not have to return to the other 24 scattered site locations.

  Scenario #2:  At a scattered site, consisting of 20 buildings and 40 units scattered over 16 locations, where one location has five (5) buildings, an inspector visually verifies all building and unit counts prior to sample generation. The property information is updated and the sample is generated with 16 buildings and 16 units in the sample. Fifteen (15) buildings in the sample are situated at separate locations. One (1) of the sample buildings is located within a group of 5 buildings. The inspector must return to the locations of the 16 sample buildings and inspect the site around each individual building. In the case of buildings located within a group or cluster of buildings included with the property, the inspector must inspect the entire site. In this scenario the inspector would identify the perimeter of the property where the 5 buildings are located and inspect the entire site, then, any buildings and any units in the sample.

  Scenario #3:  For a multi-family property with 9 buildings consisting of 3 high-rise and 6 clustered garden style buildings, (250 units), situated at separate locations within walking distance, an inspector must visually verify the entire property (each and every building) included in the property site. After visually verifying the property, the inspector updates the property profile and generates the sample. The software selects a sample of 8 buildings and 25 units, located in different areas. The inspector is required to re-visit all four (4) locations and inspect the entire site at each location because this is not considered a scattered site.

  Note:  Inspectors should consider the time in verifying property when scheduling these inspections.

  The inspector should consider the time to visually verifying and travel to the different "sites" when scheduling these inspections. In addition, inspectors should inform the POA that these inspections may take more than 1 day to complete and appropriate resident notification is needed.

  Reference:  Compilation Bulletin Rev. 2.1, Page 9, Part I Buildings and Units; C. Scattered Site;

  1. A Scattered Site can be defined as a property with multiple locations around a town, city, county, or state. In order to complete the inspection in the most efficient manner it will be necessary for the inspector to drive from one location to the next.

  Reference:  Compilation Bulletin Revision 2.2

• (8/12)
  Q) Upon generating the units' sample, what should an inspector do if the POA indicates one of the sample units is under legal proceeding? What are valid reasons for choosing alternate units?
  
  A) Inspectors must choose alternate units for vacancies, off-line units etc., as identified under the current UPCS protocol. In some cases, inspectors may have to select alternate units when they have identified other hazards, such as, health related issues, un-restrained pets, legal concerns or other situations.  To avoid discrepancies, inspectors should identify units not available for inspection prior to generating the sample.
  
  If the POA indicates that one of the sample units is under legal proceedings, after the sample has been generated, inspectors must exercise due diligence in assessing the circumstances and employ reasonableness when determining whether or not it is appropriate to select alternate units. If inspectors find an inordinate number of units with legal proceedings or other hazards, they must contact TAC to report the situation.
  
  Note:  To maintain statistical validity, the order of selection for alternates is critical. Inspectors must select alternates in the order in which they are displayed within the UPCS software.
   
• (7/12)
  Q) While inspecting a property with a common area kitchen, the POA notifies the inspector that the oven in the range does not work.  He further explains that replacing the entire range unit is too costly and the property has decided to keep the unit, using the cook top and has added portable ovens for baking. Does the inspector record a deficiency for inoperable range?
  
  A) Yes, the inspector must record all deficiencies observed during an inspection. The deficiency in this case would be recorded as Common Area/Kitchen/Range/Missing Damaged Inoperable, L3- The oven is not functioning.  Note: Properties with special conditions may request a Database Adjustment.

  Reference:  Definition DCD v. 2.3.4, Common Areas /Kitchen/Range/Stove – Missing Damaged Inoperable, L3 -The oven is not functioning.

  Reference: Compilation Bulletin Rev 2.1, Page 3, Part I:  General Information, (g) Inspectors must properly identify and record all observations at the time they are observed as either No Observed Deficiency (NOD), Observed Deficiency (OD) or Not Applicable (NA).

• (6/12)
  Q) While inspecting a nursing facility, the inspector observes that the building has double hung windows on all floors in client rooms and in common areas. The facility director has installed a window limiter/restrictor to prevent the windows from opening up all the way and to limit them to be opened less than 6 inches. However, these windows can be tilted in by releasing the side latches. How should the inspector assess this condition?
  
  A) If the window is designed as the second means of egress, the inspector should record a health and safety – blocked egress under the inspectable area. This applies to all windows located on the third or lower floors or windows on any floor that lead to a designed fire escape and serve as the only second means of egress.
  
  Keep in mind the property’s general population is either elderly or handicapped. Tilting the window open and having the residents climb over the glass pane is not considered as a proper means of escape during an emergency. 
  
  Note: Properties with special conditions may request a Database Adjustment.

  Health and Safety - Emergency/Fire Exits, Blocked/Unusable

  Reference: Definition Definition DCD v. 2.3.4, Common Areas and Units, Health and Safety, Emergency/Fire Exits, Blocked/Unusable, states: The exit cannot be used or exit is limited because a door or window is nailed shut, a lock is broken, panic hardware is chained, debris, storage, or other conditions.

  Reference: Compilation Bulletin Rev 2.1, Page 33, A. Emergency/Fire Exits, (1) On the third or lower floors:
  (a.) The “Blocked/Unusable” deficiency is applicable to blocked or unusable emergency/fire exits on these floor areas (e.g. room, unit or building). If designed, these floors must have a minimum of two independent unobstructed exits, one of which must be a door (primary). If not designed for two exits, then only one will be evaluated.

  (b.) If the only window in a floor area (e.g. room, unit or building) is blocked by a window air conditioner, furniture, or any other obstruction including an inoperable window sash and the area has only one exit door, the inspector must record a “Blocked/Unusable” deficiency.

  (c.) If a floor area has an obstructed window but has another window that is unobstructed or a second unobstructed door, there is no blocked egress.

  Reference: Compilation Bulletin Rev 2.1, Page 33, A. Emergency/Fire Exits, (4) All blockages that limit a person’s ability to exit a room in case of emergency are considered a deficiency.

  Reference: Compilation Bulletin Rev 2.1, Page 33, A. Emergency/Fire Exits, (5) In the comment field for the deficiency, the inspector must explicitly state why the obstruction prevents egress. If a resident could easily climb over or otherwise traverse the furniture or obstruction, there is no deficiency. Keep in mind the property’s resident population (i.e. family, elderly, handicapped), when making a determination of the applicability of this defect.

• (5/12)
  Q) While inspecting a unit, an inspector observes a double keyed deadbolt lock on a closet door. Is this a deficiency?
  
  A) Yes. The closet door is considered primary egress from the closet area.  Any lock, chain, damaged hardware or other device that prevents egress from a floor area, which includes all doors on all floors, is considered a blocked egress.  Any blockage that limits a person’s ability to exit a room in the event of an emergency is considered a deficiency. Professional common sense and inspector knowledge are to be applied.
  
  Reference:  DCD Definition Unit/Health and Safety/Emergency Fire Exits/ Blocked Unusable Emergency Fire Exits; the exit cannot be used or exit is limited because door or window is nailed shut, a lock is broken, panic hardware is chained, debris, storage, or other condition.
  
  Reference:  Compilation Bulletin Rev. 2.1, Part II Health and Safety. Page 33, C. Unit Doors – Blocked Fire Exits (double keyed deadbolts) 1. Double-sided keyed knob locks and deadbolts, when observed on doors that serve as one of the two required means of egress from a unit floor area, are a Health & Safety, Emergency/Fire Exits, Blocked/Unusable deficiency. This applies to all doors on all floors that serve as a main (primary) means of exit. A primary exit door is the main means of egress from a floor area (bedroom, kitchen, living, etc.)

• (4/12)
  Q) You observe a wood frame shed that meets all conditions of the definition of a building except that it is anchored to 12 inch diameter poured concrete piers.  It is assumed that the piers are poured full depth to bearing soil and below frost line.  Is this shed a building by UPCS definition? Is a pier foundation to be considered a permanent foundation?
  
  A) Yes, this is a building by UPCS definition. Pier foundations are considered permanent.

  Reference: DCD Definition, Building/Exterior/Foundation - Lowest level structural wall or floor responsible for transferring the building's load to the appropriate footings and soil.  Materials may include concrete, stone, masonry and wood.
  
  Reference: Compilation Bulletin Rev 2.1, Page 9, P.  Part Buildings and Units: A. Building, 1. An individual building is any structure that has a contiguous roofline, a permanent foundation, is enclosed on all sides and has at least one utility servicing it such as electric, gas, water, or sewer.

• (3/12)
  Q) What constitutes improperly stored flammable material?
  
  A)First remember that it would be impossible to cover every possible situation that could exist on a property for improperly stored flammable materials.  So, inspectors must use professional judgment in evaluating flammable/combustible materials.  Some common sense items to consider are listed below:

  1.  If an inspector observes flammable materials still in the original container (such as, but not limited to: hair spray, other types of aerosol cans, finger nail polish remover, butane lighter fluid, charcoal lighter fluid, paint thinner, etc.), and they are being stored in a safe place (such as under a kitchen sink, hall closet, etc.), then an inspector should not record improperly stored flammable materials.
      
  2. If the above items are being stored in close proximity to an open flame or heat source (such as, but not limited to: a gas hot water heater, a gas HVAC unit, electric heaters, etc.), then improperly stored flammable materials should be recorded.
      
  3. If easily combustible items (such as, but not limited to: paper, plastics, boxes, clothes, etc.) are being stored in close proximity to an open flame or heat source, then improperly stored flammable materials should be recorded.
      
  4. Gasoline fueled power equipment (lawn mowers, weed eaters, motorcycles, etc.) with GASOLINE in the tank being stored in a unit or in a residential building’s basement not designed for such storage, should be recorded as improperly stored flammable materials.
      
  5. Gasoline, propane, and kerosene are never allowed to be stored in a residential unit with one exception.  If a unit has a storage room that is only accessible from outside of the unit (and not accessible from within the unit), then these items can be stored in that storage room without it being improperly stored flammable materials.
      
  6. Propane tanks or gas power equipment being stored outside of a building, but in close proximity to a building should not be recorded as improperly stored flammable materials.
      

• (2/12)
  Q) While updating the profile, the inspector proceeds to record the certificate for the fire alarm. The POA provides him with a copy of the alarm inspection report which includes all of the unit call-for-aid devices. Is the inspector required to test/operate or visually inspect the system and its components?

  A) Yes.  The inspector must first verify whether or not the system is monitored off-site by a third party.  If he/she ascertain the system is monitored off-site by a third party, the inspector accepts the written documentation provided, however, he/she must visually inspect components within the sample units to ensure the system functions as intended. (Note: The inspector should review the document for compliance with the provisions set forth i.e., date within one year, support for system testing. Based on the documentation provided, the inspector should use professional judgment to determine if enough information has been imparted to show evidence the system has been adequately tested.)

  For example:  The inspector has established the call-for aid- system is monitored off-site by a third party. Upon entering the first unit, he/she notices the pull cord in the bathroom is tangled and wrapped around the towel bar.  After evaluating the condition of the cord, he/she concludes the device is not operational in its current state.  Under this condition, the call-for-aid device, as installed does not serve its intended function. In accordance with the Compilation Bulletin, Unit: Call-For-Aid, (see reference below) call-for-aids must function as intended and the inspector must record L3 Inoperable Call-For-Aid addressing functionality in the comment field.

  If the inspector determines the call-for-aid system was inspected and certified by a local alarm company, but is not monitored off-site, then the inspector is responsible to test/operate and visually inspect the entire system.

  Reference: Compilation Bulletin Rev 2.1, Page 7, P. General Information: Systems Designed for Off-site Notification/Monitoring: (1) If the property can provide current (within one year) documentation supporting the testing of a system designed for off-site notification/monitoring (call-for-aid, smoke detector, etc.) the inspector does not need to inspect the individual components and all should be marked “NOD”.  (2) If the property cannot provide the proper documentation and cannot put the equipment into a “test mode” for inspection purposes, all relevant items should be marked “OD”.

  Reference: Compilation Bulletin Rev 2.1, Page 29, C. Unit: Call-For-Aid: (1) Call-for-aid as installed must serve its intended function. (E.g. A bell sounds an alarm, a light is turned on or off-site personnel are notified when the system is activated.). (2) When recording an “Inoperable”, Level 3 deficiency and providing comments such as coiled-up, not fully extended, more than “x” distance from the floor, taped to the wall, etc., inspectors are also required to address the system functionality as supporting justification. Failure to provide the appropriate comments will result in the uploaded inspection being challenged by REAC. (3) If the property has replaced the old Call-for-Aid system with a new electronic neck or hand-held type of system, the presence of any part of an inoperable system that remains must be recorded as “Inoperable”.

• (1/12)
  Q) While inspecting a nursing facility, the inspector observes the window operator handles were removed from the crank windows on all floors in "client rooms" and in common areas. The facility director informs the inspector that he will bring along one window operator handle to test all the windows. How should the inspector assess this condition?
  A) In this scenario, inspectors must evaluate inoperable/not lockable windows and blocked egress separately. Note: Properties with special conditions may request a Database Adjustment.

1. Windows, Inoperable/Not Lockable

If the window operator handle is missing from the window at the time of the inspection and there are no other operable windows in the same floor area, the inspector must record a L3 deficiency for inoperable window.

Reference:  Definition DCD v. 2.3.4, Common Areas and Units, Windows, Inoperable/Not Lockable states:  A window cannot be opened orclosed because of damage to the frame, faulty hardware, or another cause.

Reference: Compilation Bulletin Rev 2.1, Page 16, B. Windows: Common Areas and Units, (1) All windows in sample units and common areas must be inspected (tested) for correct operation.

Reference: Compilation Bulletin Rev 2.1, Page 17, (3) The deficiency “Inoperable/Not Lockable” is broken into two parts: “Inoperable” addresses the operation of a window (i.e. cannot be opened or closed due to damage to the frame, faulty hardware, etc.); and “Not Lockable” addresses the lock only.  (a) Inoperable: All windows must operate as designed. Windows that do not operate as designed and there are no other operable windows in the same floor area, must be recorded as an “Inoperable/Not Lockable”, Level 3 deficiency. Record an “Inoperable/Not Lockable”, Level 1 deficiency for all windows that do not operate as designed with other operable windows in the area.

2. Health and Safety, Emergency/Fire Exits, Blocked/Unusable.

If the window is designed as the second means of egress and the operator handle is missing from the window at the time of the inspection, the inspector must record a health and safety blocked egress. In this situation, the window operator handle is serving as a key (special tool) to open and unlock the window. This applies to windows located on the third or lower floors or windows on any floor that lead to a designed fire escape and serve as the only second means of egress.

Reference:  Definition DCD v. 2.3.4, Common Areas and Units, Health and Safety, Emergency/Fire Exits, Blocked/Unusable, states: The exit cannot be used or exit is limited because a door or window is nailed shut, a lock is broken, panic hardware is chained, debris, storage, or other conditions.

Reference: Compilation Bulletin Rev 2.1, Page 33, A. Emergency/Fire Exits, (1) On the third or lower floors:

(a.) The “Blocked/Unusable” deficiency is applicable to blocked or unusable emergency/fire exits on these floor areas (e.g. room, unit or building). If designed, these floors must have a minimum of two independent unobstructed exits, one of which must be a door (primary). If not designed for two exits, then only one will be evaluated.

(b.) If the only window in a floor area (e.g. room, unit or building) is blocked by a window air conditioner, furniture, or any other obstruction including an inoperable window sash and the area has only one exit door, the inspector must record a “Blocked/Unusable” deficiency.

(c.) If a floor area has an obstructed window but has another window that is unobstructed or a second unobstructed door, there is no blocked egress.

Reference: Compilation Bulletin Rev 2.1, Page 33, A. Emergency/Fire Exits, (4) All blockage that limits a person’s ability to exit a room in case of emergency is considered a deficiency. 

• (12/11)
  Q)  While inspecting a property during the winter season, a REAC inspector observes a swimming pool which is not operational at the time. He/she also notices a fence enclosure which has a six by six inch hole in the chain link fabric. The Property Manager tells the inspector that the fence will be fixed during the spring season since no one is using the pool at this time. How should the inspector assess this situation?

  A) The Compilation Bulletin (Rev 2.1) on Page 28 states the following:  Swimming pools must be operational during the summer season. During the remainder of the year, do not record a deficiency for a pool that is not operational, record as “NOD”. 

  However, the inspector should record the damaged chain link fence as a deficiency under Common Areas\ Pools and Related Structures\Fencing–Damaged\Not Intact, Level 3. This should not be recorded under Site\Fencing and Gates.

  The inspector should also determine if the torn fabric has sharp edges that could harm individuals or children.  If the sharp edge hazard is present, the inspector should record the deficiency under: Common Areas\Health and Safety\Hazards\Sharp Edges.
   

• (11/11)
  Q) While verifying the property profile, a REAC inspector is informed by property representatives that the only financial assistance HUD provides is for Section 8 units. By calling TAC, the inspector confirms that there is no HUD insured loan or mortgage associated with the property - only Section 8 units. The inspector proceeds to record a TAC number in the “Property Information” tab along with the comment “verification of financial assistance”.  While visually verifying the property, the inspector observes a storage shed which satisfies REAC’s definition of a building.  The property representatives claim the storage shed is used exclusively by maintenance personnel.  The inspector also observes a common community building, which satisfies REAC’s definition of a building and contains the management office, laundry, and maintenance shop.  The property representatives confirm that all residents utilize the laundry and management office in the community building. When establishing the building count for this Section 8 property, should the storage shed or community building be included in the profile?

  A) The Compilation Bulletin (R2.1), on page 12, under G. Units, number 3. Section 8 Units, states: 

  Some Multifamily Housing properties have HUD assisted Section 8 units.  The property representative will typically provide the inspector with this information.  Only the Section 8 units for each building will be counted when establishing the building/unit profile and for sample selection.  However, all other inspectable areas including common buildings used by residents and buildings with common areas that have Section 8 units must be inspected in accordance with the protocol.

  According to the Compilation Bulletin, since the storage shed is a common building which has no Section 8 units and is never used by residents, the shed should not be included in the property profile. Since the community building is a common building used by residents, it should be included in the property profile.
  
  Q2) On the same Section 8 property, 11 buildings have dwelling units, however, only 7 of those buildings contain units which receive Section 8 assistance.  When establishing the building count, which of the 11 buildings with dwelling units should be included, and which units should be included for each building’s unit count?
  
  A2) Referencing the same Compilation Bulletin guidance as above, only the 7 buildings which contain units that receive Section 8 assistance will be included in the property profile. Within the 7 buildings containing Section 8 units, only those units which receive Section 8 assistance will be included in each building’s unit count.  

• (10/11)
  Q) Why is paint on a fire sprinkler head considered to be a deficiency?
  
  A) Paint, when observed on the heat sensitive element (glass bulb or fusible metal link), may alter the pre-determined temperature at which the fire sprinkler activates.  Paint, when observed on the fire sprinkler deflector, may alter the specific spray pattern designed for that area.  Paint, when applied to any other component on a fire sprinkler head (except the escutcheon plate) that has not been applied by the fire sprinkler manufacturer, is also considered to be a deficiency.
  
  The Compilation Bulletin R2.1, on page 24, under Systems, Fire Protection, Fire Sprinkler Heads, letter “a” states:

  If paint or any other obstruction is observed on the sprinkler head a deficiency will be recorded. Paint on an escutcheon plate should not be recorded as a deficiency.

  The Inspection Software, V2.3.4, under Systems, Fire Protection, Missing Sprinkler Head states: 

  Deficiency: You see that a sprinkler head--or its components--connected to the central fire protection system is either missing, visibly disabled, painted over, blocked, or capped.

  Level 3:  Any sprinkler head is missing, visibly disabled, painted over, blocked, or capped.

• (09/11)
  Q)  How should inspectors interpret the phrase “normal business hours” relative to scheduling and conducting a REAC inspection?

   A)  The Compilation Bulletin (R2.1), page 6, under General Information, section M, Scheduling, No. 1 states:

  Inspections are to be performed during the property’s normal business hours on Monday through Friday.  Normal business hours will vary from property to property. It is the inspector’s responsibility to ascertain the hours of business and operating policies (i.e. scheduled breaks, lunch time, quitting time) before scheduling the inspection and consider their impact when preparing the inspection schedule.
  
  Also on page 6, under the same section M, Scheduling, No. 3 states:

  Inspections may begin at any time during normal business hours on which the property representative and inspector mutually agree. A morning inspection usually begins no later than 9:00 am and an afternoon inspection usually begins by 1:00 pm. Inspectors must conclude the day’s inspections before the end of the property’s business day. Inspection of site and building exteriors must be concluded during daylight hours.

  The inspector, not the inspector’s scheduler or managing company, will ultimately be held responsible for determining the property’s normal business hours and planning their inspection schedule accordingly.  Property representatives are under no obligation to start an inspection earlier than or continue with an inspection later than their normal business hours.  Also keep in mind, property representatives are not required to work through normally scheduled breaks or lunch.

  In addition to the property’s normal business hours, inspectors should refer to the hours stated on the resident notification letter (if applicable) for the earliest and latest acceptable times to enter units for inspection.  REAC recommends that inspectors do not enter units for inspection after the time originally indicated on the resident notification letter unless given specific authorization by both the property representative and the resident of the unit to be inspected. If either the property representative or one resident whose unit is in the sample does not agree to the inspection after the time indicated on the original resident notification letter, the inspection must resume the following day.  Prior to extending an inspection beyond normal business hours, the inspector should provide the property representative with an accurate estimate of the time required to complete the inspection so the property representative can determine if the inspection should proceed.

• (08/11)
  Q) While inspecting the interior of a high-rise building from the top floor down, the inspector has been testing each trash chute door in each common area trash room on every floor. When the inspector reaches the 1st floor, a mechanically operated trash compactor is observed in a common area trash room.  Has the inspector completed the assessment of the trash collection system, or is the inspector also required to verify the operability of the trash compactor?

  A) The inspection software, under Common Areas, Trash Collection Areas, Chutes - Damaged/Missing Components, states the following:

  Level 3: Broken or inadequate collection structure causes garbage to backup into chutes.  Compactors or components have failed.

  The Compilation Bulletin (R2.1) on page 28 under Common Areas, Trash Collection Areas, states the following: 

  Inspectors must record any trash collection system component (e.g. chute, chute door, lock, counterweight, and compactor) that has failed as Chutes - Damaged/Missing Components, Level 3 deficiency. Inspector must record any other deficiency observed in the trash collection room under Closet/Utility/Mechanical.

  According to the inspection software and Compilation Bulletin, a level 3 deficiency exists if the trash compactor is inoperable.  Since the trash compactor is considered to be an inspectable item, the inspector should request that a property representative demonstrate the operability of the equipment.
   

• (07/11)
  Q1) During the inspection of a basement in a high-rise property, the inspector observes a 2’ X 4’ area of spalling concrete on the floor.  There are no cracks or large gaps observed in the deteriorated area, only surface spalling.  The floor is at the lowest level of the high-rise structure.  How should the inspector assess this condition?
  
  A1) The inspector should not record a deficiency for this condition.
  
  

  The inspection software defines the inspectable item Foundations as follows:

  Foundations (Building Exterior):  Lowest level structural wall or floor responsible for transferring the building's load to the appropriate footings and soil.  Materials may include concrete, stone, masonry and wood.

  According to the inspection software definition, the concrete floor of the basement should be assessed under Building Exterior, Foundations.  There are only two deficiencies listed for Foundations in the inspection software: Cracks/Gaps and Spalling/Exposed Rebar.  The Compilation Bulletin (Rev2.1)under the heading Foundations on page 21 provides further guidance on this subject:

  1. The deficiency “Cracks/Gaps” is applicable to both foundation walls and floors (structure slabs).
  2. For Foundation – Spalling/Exposed Rebar: The inspector is to record spalling (no exposed rebar) deficiency relative only to the percentage of the foundation area observed. The percentage is to be calculated based on each foundation wall of the building. 

  The Compilation Bulletin states that Cracks/Gaps applies to both foundation walls and floors, however, neither the Compilation Bulletin nor the inspection software addresses spalling concrete on a foundation floor – only spalling concrete on a foundation wall is addressed.  Since the spalling concrete on the foundation floor does not meet the definition found in the inspection software for Cracks/Gaps and Spalling/Exposed Rebar only applies to foundation walls, the inspector should not record the observation as a deficiency. 
  
  Q2) While inspecting a 3rd floor common area balcony on the same high-rise property, the inspector observes a 1’ X 3’ area of spalling concrete on the floor.  The concrete floor shows no sign of bulging or buckling.  How should the inspector assess this condition?

  A2)   The inspector should not record a deficiency for this condition.

  The inspection software defines the inspectable item Common Areas, Patio/Porch/Balcony - Floors as follows:

  The visible horizontal surface system within a room or area underfoot; the horizontal division between two stories of a structure.

  This inspectable item can have the following deficiencies:

  Bulging/Buckling – A floor is bowed, deflected, sagging, or is no longer aligned horizontally.
  Rot/Deteriorated Subfloor – The subfloor has decayed or is decaying.

  Since the concrete floor has no sign of bulging or buckling, and rot/deteriorated subfloor normally refers to wood frame construction, the inspector should not record the observation as a deficiency.  In addition, structural slabs are only part of the exterior foundation when they are at the “lowest level” and transfer the building’s load to the appropriate footings and soil. Therefore, this condition is not applicable to Foundations and the inspector should not record the observation as a deficiency.
  
  Note:  Tripping may be the only recordable deficiency if there is an abrupt change in elevation caused by the spalling concrete.

• (06/11)
  Q1)  While inspecting a common area basement, an Inspector observes a GFI.  Does the GFI require testing?
  
  

  A1)  Yes, the GFI does require testing.  An inoperable GFI located in a common area basement is not identified as a deficiency in the UPCS software.  Common Area GFI deficiencies are only identified under Common Area, Inspectable Items:  Kitchen, Laundry, and Restroom.  GFIs are not identified under any other common area, however, like building exterior GFIs, the presence of a GFI device (whether or not identified in the UPCS software) requires the testing and evaluation of the safety device’s functionality.

  Q2)  Where is the GFI deficiency recorded in the DCD?

  A2)  The Compilation Bulletin (R2) under Ground Fault Interrupter (GFI) on page 21, sets the precedent on how to record inoperable GFIs which are not identified in the UPCS software:

  Inoperable GFI outlets located on the building exterior are not a deficiency in the inspection software but will be recorded as a Building Exterior, Health and Safety, Hazards, ”Other” when observed unless that GFI can be associated with a specific inspectable area then any deficiency found is to be cited in that specific area.

  Based on the guidelines for recording inoperable exterior GFIs, the GFI deficiency found in the basement should be recorded under Common Area, Health & Safety, Hazards, Other.  Indicate the deficiency location as “basement” in the deficiency comment section. 

• (05/11)
  Q) While inspecting a high rise property, an Inspector observes resident mailboxes located in the wall of a corridor on the first floor. The Inspector finds a mailbox door with a broken lock. Where does the inspector record this deficiency?

  A)  The correct area to record the deficiency is: Common Areas, Halls/Corridors/Stairs, Mailboxes - Missing/Damaged, Level 3. The inspection software under this deficiency states the following:

  Deficiency: The U.S. Postal Service resident/unit mailbox is either missing or so damaged that it does not function properly.

  Note: Do not inspect commercial deposit boxes--FedEx, UPS, etc.--or U.S. Postal Service “blue boxes”.

  Level 3: The U.S. Postal Service resident/unit mailbox cannot be locked.
  -OR-
  The U.S. Postal Service resident/unit mailbox is missing.

  There are only 2 possible places to record a mailbox deficiency - Site, Mailboxes/Project Signs and Common Areas, Halls/Corridors/Stairs - record the deficiency as applicable.

• (04/11)
  Q)  During the inspection of a unit in an elderly resident hi-rise, the Inspector observes an inoperable closer on the unit front entry door.  The entry door has a fire rating label and factory installed seals around the door frame perimeter which are clearly damaged.  The resident of this unit uses a wheelchair, and the property representative claims the door closer was intentionally de-activated due to the condition of the resident.  The property representative also claims the resident’s wheelchair has caused the damage to the door seals.  How should the inspector assess the unit front door conditions?
  
  A)  Neither the Compilation Bulletin nor the Inspection Software provides information which would allow the Inspector to disregard the inoperable entry door closer hardware or the damaged entry door seals based on the condition of the resident or property representative statements.  The Inspection Software states the following under Unit, Doors, Damaged Hardware/Locks:

  Deficiency : The attachments to a door that provide hinging, hanging, opening, closing, surface protection, or security are damaged or missing. These include locks, panic hardware, overhead door tracks, springs and pulleys, sliding door tracks and hangers, and door closures.
  
  Level 3:  A bathroom door or entry door does not function as it should because of damage to the door’s hardware.
   

  The Inspection Software states the following under Unit, Doors, Deteriorated/Missing Seals:
    
  

  Deficiency: The seals and stripping around the entry door(s) to resist weather and fire are damaged or missing.  (seals may be present which are integral to the fire rating of the door)
   
  Note:  This defect applies only to entry doors that were designed with seals.  If a door shows evidence that a seal was never part of its design, do not record it as a deficiency.
   
  Level 3:   The seals are missing on one entry door, or they are so damaged that they do not function as they should.

  
  

  Based on the Inspection Software text, under Unit, Doors, Damaged Hardware/Locks the Inspector should record Level 3, and also under Unit, Doors, Deteriorated/Missing Seals, the Inspector should record Level 3.

  The property may have de-activated the closer as a valid reasonable accommodation to the resident, or to follow other federal, state, or local requirements.  The property may appeal the deficiency, and if verified by HUD, receive the points back – however, at this time – it is not the responsibility of the Inspector while on site to verify reasonable accommodations or other federal, state, or local requirements which are not specifically addressed in the Inspection Software, Inspector Notices, or the Compilation Bulletin.

• (03/11)
  Q 1) Upon entering a unit for inspection, you observe that there are no GFI outlets in the kitchen, bathroom or laundry area. Are GFI outlets a REAC requirement?
  • A 1) No- they are not. REAC does not require GFI outlets on the properties. Continuing the inspection you observe GFI (Ground Fault Interrupter) breaker or an AFCI (Arc-Fault Circuit Interrupter) breaker in the electrical panel located in the hallway.
     
• Q 2) Are you required to test these electrical devices?
  • A 2) Yes - these devices react in the same way as a GFI outlet. They interrupt the power supply between the source and the appliance being used.
    
    Page 27 of the CB provides the following guidance:
    • GFI and AFCI circuit breakers in electrical panel boxes must be tested by pushing the test button to trip the breaker and resetting. Deficiencies for inoperable AFCI circuit breakers are to be recorded under Unit/Electrical System/GFI Inoperable.
       
• Q 3) How do you test these electrical devices?
  • A 3) Simply push the test button located on the front of each device. Typically yellow for GFI breakers and blue for AFCI breakers.
     

• (02/11)
  (Q):During an inspection, a damaged window sill is observed on a building exterior. The damage is caused by decay but will not compromise the weather tightness of the area. How should the Inspector assess the condition?
   
• (A) Before recording a deficiency, the Inspector should determine which area the window serves. The Compilation Bulletin, on page 20 under Windows, states the following:
  
  If a sample building has sample units and common areas, record window deficiencies in the units and common areas in which they are observed. The exception to this is window screen-related deficiencies observed in sample units and common areas. These must be recorded in Building Exterior because there is no place in unit or common areas to record window screen-related deficiencies.If a sample building has no sample units to inspect, record all window deficiencies observed in any unit in Building Exterior, Windows. Record all window deficiencies observed in common areas in the associated common area. 

The Inspector should assess the condition as follows -

Scenario 1:If the window serves a unit in the sample, record the deficiency in the applicable unit under Unit, Windows, Damaged Window Sill, Level 1.

Scenario 2: If the building contains a unit in the sample, but the window serves a unit which is not in the sample, do not record a deficiency.

Scenario 3: If the building is in the sample, but contains no units in the sample, record the deficiency under Building Exterior, Windows, Damaged Sills/Frames/Lintels/Trim, Level 1.

Scenario 4: If the building is in the sample, and the window serves a common area, record the deficiency under Common Areas, (applicable area), Windows, Damaged Window Sill, Level 1.

The Inspector should also be aware that the inspection software under Unit and Common Area Windows does not include deficiencies for exterior window frames, lintels, or trim - these deficiencies, when observed, should be recorded under Building Exterior regardless of which area the window serves.

• (01/11)
  Q)  When daylight is observed around a unit entry door, how should the Inspector assess the condition?
   
  A)  Scenario 1:  If the entry door never had seals as part of the door’s design, the Inspector should not record a deficiency.  The inspection software under Unit, Doors, Deteriorated/Missing Seals states:
   
  Note:  This defect applies only to entry doors that were designed with seals.  If a door shows evidence that a seal was never part of its design, do not record it as a deficiency.
   
  Scenario 2:  If the entry door has seals as part of the door’s design, and the seals are damaged or missing, the Inspector should record a Level 3 deficiency under Unit, Doors, Deteriorating/Missing Seals.  The inspection software for this deficiency states:
   
  Level 3: The seals are missing on one entry door, or they are so damaged that they do not function as they should
   
  Scenario 3:  If the entry door has seals as part of the door’s design, but the seals are not damaged or missing, yet the Inspector can still see daylight around the door, page 18 of the Compilation Bulletin gives the Inspector specific guidance in this situation:
   
  When the Inspector observes light around a closed entry door with a seal that exhibits no evidence of seal damage, it is a deficiency that is to be recorded as Doors – “Damaged Frames/Threshold/Lintels/Trim”, Level 3.
   
  Scenario 4:  If the entry door has seals, but the Inspector can determine that the seals were not factory applied or professionally installed, page 18 of the Compilation Bulletin also gives the Inspector specific guidance in this situation:
   
  When recording seal defects, Inspectors must use their own professional experience to observe and determine whether or not a factory applied or professionally installed seal is or was present. Inspectors are not to record a deficiency for missing or deteriorated after-market seals applied by the residents.
   
  An example of an after-market seal: “peel and stick” foam weather-stripping tape.  An example of a professionally installed seal: a rubber seal with a metal bar/bracket/ reinforcement, which is cut to fit, then drilled and fastened to the door or door frame.
   

• (12/10)
  (Q): According to a property representative, a fire extinguisher is located in an elevator equipment room. All other items within the room are clearly associated with the elevator system. The room does not provide access to any other rooms or areas. Should the inspector enter this elevator equipment room?
   
• (A): Inspector Notice No. 2009-03, UPCS Inspection Protocol for Inspecting Elevator Equipment Rooms states the following: UPCS inspectors will not enter and inspect enclosed rooms, closets, or areas (hereafter "rooms") on HUD assisted and insured properties that house ONLY elevator equipment.
  
  UPCS inspectors will:
  • (1) enter and inspect rooms that house elevator equipment when the room also contains inspectable items not associated with elevators (for example water circulation pumps, compressors, and electrical panels for various building electrical systems such as timers or exhaust fans); and
     
  • (2) enter rooms that house elevator equipment when the room provides the only access to another area that the inspector must inspect (for example, the roof or other common areas on the property).
    
    So should the inspector consider the fire extinguisher as an inspectable item that is "associated with elevators"? Although the fire extinguisher does not directly affect the operation of the elevator, most, if not all elevator equipment rooms will contain a fire extinguisher based on code and/or industry requirements. Therefore, the inspector should consider the fire extinguisher located in the elevator equipment room as "associated with elevators". Based on the conditions stated in our example, whether the elevator equipment room door is locked or unlocked, the inspector should not enter the room. Also, there is no requirement for the property representative to remove the fire extinguisher from the elevator equipment room for the inspection.
     
• Inspector Notice No. 2009-03 gives the following guidelines when the inspector has determined they should not enter the elevator equipment room:
  • 1. Review the elevator certificate(s) and record the applicable notation under the Certificate tab. For example, if the certificate is expired, the inspector would mark "No."
  • 2. Inspect the operation of the elevator(s) itself and record any deficiencies in "Building Systems."
  • 3. Record any observed health and safety violations related to the elevator(s) in "Health and Safety."
  • 4. If the door to the elevator room is not locked at the time of the inspection, record a health and safety deficiency in "Health and Safety" under inspectable item "Hazards," inspectable defect "Other." Include a comment stating "Door to the elevator room was not locked."
  • 5. Record any deficiencies observed that are associated with the elevator room door (such as missing hardware) in "Common Areas" under inspectable item "Closet/Utility/Mechanical."

• (11/10)
  (Q):During the inspection of a building exterior, the inspector observes a sanitary system clean out cover that appears to have been damaged by a lawn mower. The clean out cover is still there, but has been damaged, creating a hole through which sewer gases may escape. How should the inspector assess the damage to the clean out cover?
  
  

  • (A) The inspection software under Systems, Sanitary System, Missing Drain/Cleanout/Manhole Covers states:

   Level 3: A protective cover is missing.

  In our example, the clean out cover is still there, but due to the damage, the cover no longer functions as designed - sewer gases may escape and unwanted material may enter the drainage system. So can the inspector substitute a damaged clean out cover for a missing clean out cover? The Compilation Bulletin, under the heading Professional Common Sense on page 5 states:

  This is a common sense approach that inspectors are to use when conducting inspections. It includes exercising sound, practical, and prudent judgment based on the HUD physical inspection training and the inspector's experience. Professional common sense is to be applied in conjunction with REAC guidance.

  The clean out cover is still there, but may as well be missing due to the damage. Professional common sense should be used in determining the applicability of the terms "damaged" and "missing" when assessing inspectable items. In this case, the inspector should record a L3 deficiency under Systems, Sanitary System, Missing Drain/Cleanout/Manhole Covers.

  ---

• (10/10)
  (Q):While passing a detached shed, the inspector learns that the structure is used for storage by a specific unit which is in the sample. The storage shed structure however, does not meet the definition of a building. The inspector observes a broken window with sharp edges on the storage shed's exterior. What should the inspector record, if anything?
  • (A) The Inspector should record a deficiency under Site, Health and Safety, Hazards, Sharp Edges. The Compilation Bulletin gives specific direction for such a situation under General Information, Buildings, on Page 6, Item:

  If a storage shed, garage, carport or other free-standing structure does not meet the definition of a building, do not inspect it as a building. However, if a Health and Safety deficiency is observed on the structure, it should be recorded as a H&S deficiency under Site/Health and Safety.

• (09/10)
  (Q):During the inspection of a unit, the inspector observes a missing bedroom door with evidence of hinges and a strike plate still remaining. The Property Representative states that the door has been removed to help the handicapped resident gain easier access to the bedroom. How should the inspector assess the missing door?
  • (A) Note number 2 under Unit, Doors, Missing Door in the inspection software states:
    

    • If a bedroom door has been removed to improve access for an elderly or handicapped resident, do not record this as a deficiency
      
      
      The Compilation Bulletin on page 26 under Unit, Doors, also states:
       
    • Doors in units that have been removed by the property, other than in elderly or handicapped units, must have all evidence of their previous existence removed. The holes where the hinges were located as well as the mortised area of the hinges and the strike must be filled, sanded, and painted; otherwise it is recorded as a "Missing Door" deficiency.
       

    The inspector should have requested a list of the 504 (handicapped) units during the organization of the all-inclusive list (rent roll), and the inspector may also accept a Property Representative's statement regarding the population of elderly or handicapped resident units - no further documentation is required from the property. The inspection software advises us that the door may be removed to improve access for elderly or handicapped residents, and the Compilation Bulletin further clarifies that in elderly and handicapped units, evidence of the door is not required to be removed. The missing door for the unit in our example is not a deficiency.

•  (08/2010)
  
  (Q):During the inspection of a unit, the inspector observes three (3) call-for-aid pull cords located in separate rooms. First, in a bedroom, a call-for-aid cord is located adjacent the bed, and is easily accessible to someone laying on the bed. However, the cord is not accessible to someone laying on the ground. The second call-for-aid cord in the living area extends to the floor, but is coiled up in the middle. The third call-for-aid cord is located in the bathroom and is coiled up so that it is not accessible to someone laying on the floor. How should the inspector proceed with the assessment of each of these three different call-for-aid pull cord scenarios?
   
• (A) The key to correctly assessing a call-for-aid system is to determine if the system functions as intended. Pull cords should be considered an integral component of the call-for-aid system. Regardless of where the call-for-aid cords are placed, the cords may not be accessible from every position or distance in a given area, but the system may still function as intended. Deficiencies should not be recorded when the call-for-aid system functions as intended. If a call-for-aid pull cord is inaccessible or one of the system components (light, buzzer, or notification signal/annunciator board) does not function when tested, then the Inspector should record a Level 3 deficiency.
   

In our example, the first call-for-aid pull cord in the bedroom has been located adjacent the bed and is accessible from the bed, so if the system components function correctly when the cord is pulled (light, buzzer, and notification signal/annunciator board work as applicable, for the situation), the system functions as intended and there is no deficiency.

The living area has a coiled call-for-aid pull cord that extends to the floor. A coiled call-for-aid cord is not automatically a deficiency - the system components should also be tested. The cord should be pulled in a way which would reflect how someone laying on the floor in distress might pull the cord. If the coil in the cord causes the system to fail when the cord is pulled, the Inspector should record a Level 3 deficiency. If the components of the system function when the cord is pulled, the call-for-aid system functions as intended and there is no deficiency.

The third cord in the bathroom is coiled up in a way which causes the system to be inaccessible to someone laying on the ground. In this situation, the call-for-aid system does not serve its intended function, and the Inspector should record a Level 3 deficiency. Although a deficiency should automatically be recorded in this situation, the system should still be tested to determine if the other call-for-aid system components are functioning.

Page 25 of the Compilation Bulletin provides further clarification on the inspection of call-for-aid systems, including how Level 3 comments should specifically address system functionality:

 

• Call-for-aid as installed must serve its intended function. (e.g. A bell sounds an alarm, a light is turned on, or off-site personnel are notified when the system is activated.)
   
• When recording an "Inoperable", Level 3 deficiency and providing comments such as coiled-up, not fully extended, more than "x" distance from the floor, taped to the wall, etc., inspectors are also required to address the system functionality as supporting justification. Failure to provide the appropriate comments will result in the uploaded inspection being challenged by REAC.
   
• If the property has replaced the old Call-for-Aid system with a new electronic neck or hand-held type of system, the presence of any part of an inoperable system that remains must be recorded as "Inoperable", Level 3.
   

Professional common sense should be applied when evaluating the functionality of call-for-aid system components.

• (07/2010)
  (Q):Upon entering a unit, the inspector observes door hardware missing from a closet door, leaving a 3 inch hole in the door. The property representative states that the door hardware has been removed by the resident. Which of the following should the inspector record under Unit, Doors?
  
  A. L1 - Damaged Hardware/Locks
  B. L2 - Damaged Surface
  C. L3 - Damaged Surface
  D. NOD
  • (A): The correct answer is "C", L3 - Damaged Surface. The Compilation Bulletin, under Unit, Doors, gives specific direction on how to assess missing door hardware:

Page 26: Holes left in doors from the removal of hardware must be evaluated as door surface damage.

• The DCD 2.3.3 inspection software for Level 3 under Unit, Doors, Damaged Surface states:
  

  Level 3: One door has a hole or holes larger than 1 inch in diameter, significant peeling/cracking/no paint, rust that affects the integrity of the door surface, or broken/missing glass.
  
  
  
  Door Surface Damage
  

• (06/2010)
  (Q):A storage closet dedicated for the use of a sample unit is located outside the unit. The closet door swings towards the exterior and has broken lock hardware. Where should the inspector record this deficiency and at what level?
  • (A): The inspector should record this deficiency under Unit, Damaged Hardware/Locks, Level 1 (L1). In this case, since the door is a unit door in the sample, the deficiency is recorded under Unit, and the direction of the swing (towards the exterior) does not affect the location where the defect is to be recorded. When determining the level of the deficiency, a unit closet door is not to be considered an entry door, even when the door is located on the exterior of the building.
    
    The Compilation Bulletin, on page 18, clarifies which doors should be considered entry doors:

There are two types of entry doors:

1. A building entry door that leads from the exterior of a building into the building interior, and
2. A unit entry door that leads from the exterior of a building or from a building common area into a unit. If an inspector observes a deficiency on the entry door of a single family building, the deficiency must be recorded under Unit/Doors. (Doors under Building Exterior would be marked as "NA".)

The DCD software version 2.3.3 specifies under Unit, Damaged Hardware/Locks, Level 1: A closet door that requires locking cannot be locked because of damage to the door's hardware. The software also notes: If a door is designed to have a lock, the lock should work. If a door is designed without locks, do not record it as a deficiency.