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Required Items on a REAC Inspection

What You "Have to Have" on REAC and UPCS Inspections

This fall US Housing presented short and long format sessions at conferences from coast to coast, and the question that we received most frequently was related to what items were actually required as part of a REAC/UPCS Inspection.

To clarify this issue relates to instances when a property can be cited for a deficiency for not having a component installed. This commonly is asked about items such as Self-Closing devices on entry doors, Exit Signs, GFCI Oultet protection, and other common elements. These items are not required under UPCS, but they may be required under your local code, but this does not make it a deficiency under UPCS - unless the item is present and not functioning as designed.

To put it another way - if you have a self closing device on a door - it needs to function properly, but it is not a deficiency to not have one on any door. The same thing can be said of Exit Signs, GFCI Outlet Protection, Appliances, and other devices. The following is a list of required items under UPCS:

  1. Handrails on Steps - Anywhere you find 4 or more consecutive steps, you need to have a handrail installed, it does not have to be on both sides.
  2. Bathtub and Bathroom Sink Stoppers - In Units - bathtubs and bathroom sinks must have a sink stopper, this does not apply to handicapped accessisble design sinks
  3. Water Heater Pressure Relief - Water Heater Pressure Relief Valves are required to have an extension pipe that extends to no more than 18" from the floor
  4. Gas/Oil Fired Boiler/Water Heaters - Need to have exhaust (and the exhaust can't be misaligned)
  5. Active Utilities - All buildings need active utilities such as running water and electric
  6. Window Locks - Windows are required to have window locks on ground floor or entry from fire escapes
  7. Paint/Finish on Doors - Every door, regardless of use, purpose, or location needs to have a finish, paint, stain, or varnish/clear coat on the door (all sides)
  8. Smoke Detectors - all dwelling units need to have one working smoke detector per dwelling floor in each unit
  9. Splashblocks - anywhere a downspout exits onto grass or dirt a splashblock is required - a splashblock is not required where the elbow of the downspout exits onto gravel, asphalt, or cement.
  10. Paint on Drywall - All drywall and sheetrock surfaces need to be painted, regardless of location, purpose of the location, or use of the location
  11. Dryer Exhaust - All dryers present are required to have a proper exhaust, but there is no requirement to have laundry equipment.
  12. Light Fixtures - All rooms must have light fixtures present to provide illumination
  13. Hot Water - Common Areas and Units, all fixtures with a hot water faucet must produce hot water that is at least room temperature

What if something is required under my local code?

Then it would be a violation of your local code to not have it, but that does not mean that it is a REAC violation - they are two seperate, independent concepts. If your city requires that you have self-closing door hardware, then you should have it present, and REAC will inspect it to determine if it is operating properly. But just because REAC inspects the items for functionality, does not mean that the item is "required" - only that because the item is there, it needs to work.

If I have Exit Signs Over Most Doors - Do I Have to Have One Over Every Door?

No - as REAC does not explcitly require Exit Signs, there is no deficiency if there is not a sign present in any particular location. An exit sign is considered to be "missing" only if there is evidence that the sign did exist and was partially removed.

But I have heard something different in the past....

If you attended trainings, heard anyone tell you somethign contrary to what is stated here - all of this information is derived directly from 24 CFR 200.853(b), you can search the link to the UPCS violation list in the Code of Federal Regulations on any item to determine the precise, exact requirements for each and every item.

Feel free to contact us with any questions about this or any other compliance issues. You can search our website atwww.us-hc.com for past issues of "The Score" or to look at our upcoming seminars. 

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