New Mold and Mildew Requirement for REAC Inspections

HUD REAC has instituted some new changes to how it will be testing for Mold and Mildew in apartments and common areas. On a select number of REAC Inspections, an additional process using infrared technology will be utilized. In this undated memorandum, HUD REAC discusses the dangers to health and safety that mold and mildew can pose to residents and staff working on a property. HUD is looking for ways to reduce the number of occurrences and the overall risk to residents by trying to detect issues with moisture and mold before it becomes a health hazard.

Every room will be viewed by infrared and tested with a moisture reader if any moisture is observed by the inspector, generally meaning that they see darkened areas or water damaged surfaces. The infrared device is managed by a second inspector who will accompany the primary inspector for the sole purpose of using the infrared device. The good news is that any results which are observed through the infrared technology will not affect your score, at least not directly. Just as with any other inspection, having a second inspector present during the process inevitably slows the inspection down and frequently affects the score as there are two people reviewing the property.

From the view of one of our Inspection Consultants, they found the process to be awkward and slowed the pace of the inspection. It was also observed that once the inspector realized the infrared device found an issue, that area became more closely scrutinized and investigated.

What should you do differently for your inspection?

  • Be prepared to have additional staff in the units.
  • Be prepared to move resident's belongings. If the infrared device observes moisture under a kitchen sink, or under clothing piles on a floor (for example), the inspector will need to take moisture readings; therefore, there is a significant amount of things that may be necessary to move. This can be very time consuming and tedious.

Additionally, the local HUD Offices have started to follow up with the Owner/Agent after any REAC inspection (not just inspections with the infrared testing) to ensure that all mold and mildew issues have been addressed and are asking for verification of these repairs. This doesn't necessarily mean that you have to conduct additional mold testing, and the response does not need to include any scientific data, but it will need to verify that the issue has been mitigated. 

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