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HUD Announces Rule for Carbon Monoxide Detection

On January 31, 2022, HUD issued a notice (PIH Notice 2022-01), announcing that HUD will enforce the installation of carbon monoxide alarms or detectors in HUD-assisted housing by December 27, 2022. Essentially, this is the action plan of applying a law passed several years ago that required all HUD housing to meet or exceed carbon monoxide safety requirements.

Since that law passed, there have been questions about when, where, and how owners would need to install and maintain CO detectors. HUD has adopted the CO safety standards of the International Fire Code (IFC) 2018. Furthermore, HUD states all properties must have CO detectors installed in all dwelling units that meet or exceed the standards in Chapters 9, Fire Protection and Life Safety Systems, and Chapter 11, Construction Requirements for Existing Buildings, of the International Fire Code.

Where Are CO Alarms Required?

We have included a summary of the requirements for building designs typically found in HUD-assisted housing.

  1.  “Carbon Monoxide Detection shall be installed in dwelling units that contain a fuel-burning appliance or fuel-burning fireplace.” IFC – Chapter 9, Section 915.1.2 – Locations
  2. Carbon Monoxide detection shall be incldued in any dwelling units with attached private garages” IFC, Chapter 9, Section 915.1.5 Private Garages
  3. Carbon Monoxide detectors shall be installed in dwelling units outside each sleeping area and in the immediate vicinity of the bedroom. If a fuel-burning appliance is installed in the bedorom, a CO detector must be installed in the bedroom” Seciton 915.2.1.

What Kind of CO Alarms are Required and Where are They Installed?

  1. Carbon Monoxide alarms shall receive their primary power from the building’s wiring, and when the primary power service is interrupted, serviced by a battery (i.e., it has to be hard wired and have a battery back-up). Section 915.4.1 Power Source
  2. The CO Alarm must meet the UL 2034 standard for sensitivity and UL 217. When purchasing CO alarms, please ensure that meets this standard for sensitivity.  Combination smoke and CO alarms must comply with UL2075 and UL 268
  3. If not combined with a smoke detector, CO detectors should be installed approximately 5’ from the floor, and not within 6” of a conjoining wall. If wall placement is not feasible, place on the ceiling no less than 6” from any wall.

What are “Fuel Burning Appliances”?

Fuel-burning appliances include any heating or cooking appliance which uses natural gas, propane, or oil. These can include any of the following:

  • Gas/Fuel-fired ranges/stoves
  • Gas/Fuel-fired fireplaces
  • Gas/Fuel-fired Furnaces/Air Handlers
  • Gas/Fuel-fired Boilers/Water Heaters

What are the Exceptions?

CO detection shall not be required in dwelling units that do not have openings between the fuel-burning appliance or underground garage and the dwelling unit (paraphrased 915.1.4 Fuel Burning Appliance outside of dwelling units). In other words:  If you have a central heating or hot water system that does not distribute heat via forced hot air, CO detection is not specifically required in the dwelling units. IF the CO detection is installed in required locations between the fuel-burning appliance and the dwelling units. In other words – you would have to have CO detection between a boiler/water heater and a dwelling unit in the common areas/mechanical rooms, and any garages.

Answers to Frequently Asked Questions Regarding Carbon Monoxide

  • Question: HUD’s notice makes a distinction between an alarm and a detector. What are the key differences between a detector and an alarm?”
  • Answer: There is a distinction between the two devices. A CO “Alarm” is defined as “a single or multiple-station alarm intended to detect carbon monoxide gas and alert occupants by a distinct audible signal. It incorporates a sensor, control components, and an alarm notification appliance in a single unit“, whereas a CO detector is a “Device with an integral sensor to detect carbon monoxide gas and transmit an alarm signal connected alarm control unit.”    In short, a CO Alarm” is defined as a single unit or multiple interconnected units that provide an alert locally that only occupants in the immediate area, while a “CO Detector” is the sensor-only unit placed as part of a central system, much like a fire alarm system.
  • Question: The international fire code (IFC) 1103.9. refers to existing dwellings and the requirement of “alarms”. Are battery-operated CO alarms permitted”
  • Answer: HUD’s notice appears to refer to IFC for the specifics of when, where, and how CO detection is required. In this case, the reference to 1103.9 refers to the following language, “Carbon monoxide alarms are permitted to be solely battery operated where the code that was in effect at the time of construction did not CO detectors to be installed.”  Before choosing to install battery-operated detectors instead of hard-wired CO detectors, the property owner should consult an engineer or architect who could clarify what the building codes were at the time of construction.
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