HUD Publishes Revisions to Proposed NSPIRE Standards
HUD recently published an update to seven proposed NSPIRE standards, as part of the proposed NSPIRE protocols, which is currently being used in a demonstration program.
It is important to remember that all NSPIRE standards currently being proposed will go into effect once a final rule has been published, which is expected in CY 2023, or later if the demonstration program is extended. Until a final rule has been published, owners and agents should continue using the Uniform Physical Condition Standards (UPCS).
During this demonstration program, HUD is sharing the standards used for these inspections, as well as any subsequent revisions as the standards are tested in field inspections. These revisions can consist of minor adjustments to classification, such as changing a deficiency to a “24 hour repair” designation, or it can be a fundamental update about the nature of how a particular component is being inspected and what owners and agents are required to do to meet the NSPIRE standards.
Revised NSPIRE Standards (Version 2.2)
The seven standards that were most recently updated and the updates to them are as follows:
- Call-for-Aid Standard (version 2.2): For this standard, the actual proposed standard is very similar to what is currently used in UPCS. The standard essentially states that the call for aide cords cannot be (1) more than 6” from the floor, (2) inoperable, or (3) blocked. The update to this proposed standard was simply about the designation of Health and Safety, which has now classified issues with the call for aide system as a “24 Hour Repair” non-life threatening health and safety issue.
- Carbon Monoxide Alarm Standard (version 2.2.1) – Throughout the three deficiencies, the word “detector” has been revised to “alarm.” This update, to use the word “alarm” instead of “detector,” was likely due to the confusion by many of the distinction between the two, when HUD published PIH Notice 2201-01 back on January 31, 2022, on the new requirements to have CO alarms and detectors installed at all HUD properties where required by December 27, 2022.
- This update is significant as carbon monoxide alarms are individual battery or electric hard-wired devices that most properties will have installed where required. These devices detect CO and alert (“alarm”) locally, which have test buttons REAC inspectors will be using to test for operability with.
- “Detectors” are the detection-unit only devices, that are part of a central system, and alert to an approved third-party which do not get tested by REAC inspectors.
- Door – Fire-Labeled Standard (version 2.2.1) – The current inspection standards, UPCS, are designed largely to avoid enforcement of any specific design requirements. With NSPIRE, HUD is decidedly moving in a direction to require minimum design standards not just minimum performance standards. The standards for fire-labeled doors is a good example of this change in direction. With this change, HUD will now require that all fire-labeled doors are equipped with functional self-closing devices (on all common area, exterior, and unit doors). While this is a decided change in direction, insofar as it is adding new design standards, it remains inline with the general mission of NSPIRE – which is to better align inspection standards with safety issues.
- Exit Sign Standard (version 2.2) – In the previous proposed standard, there were three proposed deficiencies. In this update, the standards have been streamlined into a single, concise deficiency. Streamlining and clarifying language is a central part of NSPIRE, as part of feedback from industry stakeholders and HUD was that clear and concise language lead to better understanding and in turn, better compliance. The new standard uses the very concise “Exit sign is damaged, missing, obstructed, or not adequately illuminated,” as the sole standard, which succinctly clarifies all possible issues.
- Fire Extinguisher Standard (version 2.2) – One of the deficiencies in this standard (Deficiency 3) was revised to include “Damaged” as a condition of concern. In this standard, HUD defines a damaged extinguisher as one that is “visibly defective” with damage that “impacts functionality.” The proposed standard lacks some of the specificity and objectivity seen elsewhere in NSPIRE. Hopefully, in subsequent revisions, the definition of “damaged” will become more objectively defined.
- Heating, Ventilation, and Air-Conditioning (HVAC) Standard (version 2.2): The revisions under this standard are simply reclassification of the areas where these issues could be cited, adding HVAC issues to common areas (i.e. “Inside”) as well as units. This revision did not include any revision to any actual language about what makes something deficient.
- Mold-Like Substance Standard (version 2.2) – This is another example of an update which focuses on changing the designation of the deficiency from “Standard” to “Severe Non-Life-Threatening”, which has a 24-hour period to correct.
Staying on top of the proposed NSPIRE standards and any published updates is a critical part of the process of developing and implementing NSPIRE. To make comments as part of the demonstration program, please visit HUD’s NSPIRE website to learn how to make comments and participate in the development of the updated inspection standards.