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HUD REAC & Non-Industry Standards: Spray Foam

Of the many REAC Compliance questions that come to us at US Housing Consultants, the one that has been presented to us most frequently recently has been about if the use of “spray foam” is appropriate under the REAC “non-industry standards” requirements. Essentially the question is: is there ever a moment when you can use spray-foam-in-a-can (such as “Great Stuff”) to seal penetration and holes. There is not a single clear answer, but instead, it is slightly more nuanced. We are going to attempt to explore the concept here.

Not all Spray Foam Is Equal

This is part of the issue for many in the industry – not understanding that the use of products such as Great Stuff can be used if the materials are properly rated. For example, if you are looking to enclose a penetration, such as around a pipe going through a wall or a cabinet, you need to use a spray foam that is rated to have been tested by ASTM E84 and ASTM E814. This spray foam will be bright orange to differentiate it from other standard spray foam, as this orange foam is intended for fire-blocking purposes. If you use this properly rated spray foam to fill in penetration, it should not be cited as an issue, as the non-industry standard rule states that so long as the appropriate material is used and applied properly, then it shouldn’t be an issue.

Repairs Need to Be Done Professionally

The other part of the REAC Non-Industry Standards requirements is that repairs must be done professionally. To quote, “Each repair shall be made by the industry standard for that particular inspectable item (e.g., hole in the drywall be repaired using the same or equivalent materials, have the same texture, and shall have the minimal deviation from and have an indistinguishable difference from the original appearance.” So, if you use spray foam, it needs to be applied professionally and not be applied in a “sloppy” or haphazard fashion.

Where Can I Not Use Spray Foam?

In our opinion, the use of spray foam should be limited to enclosing penetrations, and it must be done using a fire-blocking grade spray foam. Use of spray foam to fill in holes in an exterior wall or foundation should be strictly avoided, as should use of spray foam to fill in damaged areas on doors, walls, and ceilings. Use of spray foam in these locations would be against the specific requirements of the non-industry standards rules of evaluation, “All repairs shall be made in a good and workmanlike manner with materials that are suitable for the purpose and free from defects.”

Please call US Housing Consultants with any questions that you might have about preparing for your next REAC Inspection or for scheduling a private REAC training event for your staff. Remember, the best way to ensure that you excel on your next REAC Inspection is with a Pre-REAC Inspection from US Housing Consultants – see the entire depth of every issue that you might ever need to address and learn to prepare for your next inspection with an analytic plan and not panic and fear.


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