HUD NSPIRE Standards Version 2.1 Released
HUD REAC has published an update to the NSPIRE standards – which is version 2.1. The previous version was 1.3, and in this new version, some of the standards in the previous versions have been changed dramatically, some subtly, and others have remained essentially as previously proposed.
This update of the NSPIRE standards provides industry stakeholders with additional time to provide comments on the proposed NSPIRE inspection standards. Unless subsequently updated, these standards will be used for NSPIRE demonstration inspections. A final version of the standards will be updated and published in the Federal Register for additional review and comment.
NSPIRE is a Work in Progress
We have heard from many people in the industry who find themselves receiving conflicting information about what NSPIRE is, and what it is not. Some other companies who provide some form of training on REAC inspections have communicated these proposed standards as “New Rules” – which NSPIRE is not – yet. The updated standards are being used as part of the NSPIRE demonstration program – and much of the aim of the demonstration program is to make adjustments after extensive field inspections and solicit public comments on the proposed rules. These are not new requirements; they are a draft of standards to perform live testing.
While many of the NSPIRE standards show a terrific advancement in terms of setting a new focus on safety and encouraging regular maintenance – these standards have changed several times already – before the bulk of the site-level demonstration inspections have even begun. Several months ago, standards were introduced that would have required safety shields at water heaters, and in a recent publication, a competitor of ours suggested that owners/agents should take immediate action to meet this standard – which has now been eliminated as part of these revised standards.
What we recommend in our seminar series on “Preparing for NSPIRE” is to develop better internal procedures for annual inspections, work orders, oversight on completed work, and regular training on all staff on best practices. The part of NSPIRE which will likely require the biggest adjustment is not the new inspection standards – it is the proposed requirement for comprehensive self-inspections. Creating serious, extensive reporting and compliance as part of maintenance and inspections is going to represent a sea change in procedures for many companies. The time available during the NSPIRE demonstration program is a great time to re-invent your maintenance compliance procedures.
Notable Changes In NSPIRE Version 2.1
- Egress – This standard has been revised significantly from version 1.3. One of the most notable changes is the removal of the requirement for inspectors to measure openings of doors, windows, and pathways. There are also some changes to scenarios and conditions that would block emergency egress. Some of the language in the revision is a little unclear, and we expect there to be future updates to this standard.
Water Heater – The core deficiencies appear similar to 1.3 (discharge piping, flues, etc.), but the requirement for installed safety shield has been removed, and a new standard was added for Gas Shutoff Valve is Damaged, Missing, or Not Installed.
- Toilet – There are new categories for Toilet damage based on whether it may “limit the resident’s ability to safely discharge human waste”. And, there is also categorization for whether or not there is one operational toilet elsewhere in a Unit or Inside area.
- Structural – They are now calling this Structural Systems Standard – but have changed significantly how it is recorded. It now says it should be recorded under the standard of the affected item, for example, a wall ceiling, floor, foundation, and even fence is given as an example. It then says only record issues under the structural standard if the deficiency cannot be associated with the affected item itself.
- Carbon Monoxide Alarm – The changes to this standard are substantial. There were a number of changes, including removing a standard that would require a CO2 detector within 15 feet of fuel-fired appliances. Most notably, the revised standard now includes the following much-needed disclaimer, which puts local codes and requirements at the forefront of the standard.
This is not a replacement for a code inspection. All requirements of IFC Sections 915 and 1103 must be met, even though only the criteria listed herein will be inspected for in an NSPIRE inspection. Local or state code will take precedence over HUD requirements if that code is more protective than the HUD requirements, with documentation and approval.
- Electrical Conductors – The revised standard now includes language about a ¼ inch gap again, which was was omitted in 1.3. However, now the standard specifically requires inspectors to measure the gap/opening before citing the issue.
- Electrical Service Panel – This was called Electrical Enclosure Standard in 1.3. This standard addresses blocked access to service panels (same as in Version 1.3), but now it also includes a new deficiency for “The Overcurrent Protection Device is Damaged”, which it says would be for a breaker or fuse that is so damaged visibly, that it may not work. This is similar to the UPCS deficiency for melted breakers, arcing scars, etc.
- Entry Doors – The revised standard removes language about a damaged thermo-pane window lite deficiency, as well as standards for entry door security devices and “secondary lock”. However, the new standards add a new deficiency (#10) to record damage that “does not affect the door’s ability to provide privacy or protection from weather or infestation”.
- Mold-Like Substance – Version 2.1 shows some significant changes to this standard. In earlier versions, the standard was simplified and was defined as any mold observed by sight or smell. Now, the revised standard includes five total deficiencies that include measurements of affected areas and requirements for ventilation in bathrooms.
- Site Drainage (Erosion) – The revised ground erosion standard represents a significant change from version 1.3. The standard now includes a deficiency for site drainage grates that do not secure or cover drainage points, clogged site drainage, and erosion. Erosion removes some of the measurements from previous standards and now aligns the deficiency on erosion which results in “footers” being exposed, as well as the following language, which is pretty unclear: “Erosion is more than 2 feet away from the built environment and its depth is equal to or greater than its measured distance from the built environment, and the inspector believes it may undermine the supporting soil”.
- Infestation – This standard in version 2.1 now includes a new deficiency for Extensive Cockroach Infestation – which is cited in scenarios when more than three live roaches are observed.
- Potential Lead-Based Paint – Similar to mold standard, this standard got a name change to Potential Lead-Based Paint Hazards. And there are major changes to the deficiency criteria too, with four total deficiencies now. It will be categorized as Inside/Unit Vs. Outside, then also whether it is below or above the “level required for lead-safe work practices by a lead certified firm or for passing clearance”. Specific criteria for the size of peeling paint areas at target properties are defined here now as well.