HUD REAC Presentation Recap March 9, 2017
HUD has released a new PowerPoint presentation as of March 9, 2017, as part of their Dine & Learn series. Many of these clarifications are reiterations of existing rules. Many of the rules that need clarification and reinforcement are a little surprising, as the issues are not new and the clarifications are really reinforcing basic rules. It appears that these clarifications are the result of some observations made through reviews of photographs from REAC Inspections as well as observations made by Quality Assurance REAC Inspectors.
Recording the Same Issue Twice
For example, if a bedroom door was missing the hardware, some inspectors were recording both Level 2 for inoperable hardware and Level 3 for surface damage because there was a hole greater than 1″. They are to record one of the two deficiencies, and they must choose the higher-level deficiency, in this example: The Level 3 hole.
Two Issues on Exterior Walls in the Same Vicinity
Much like the doors, building exterior walls were another discussion in the webinar with REAC. When there are both cracks and gaps, and missing pieces/holes/spalling in one area of an exterior wall, the inspectors are to only record one of the two deficiencies and choose the highest severity level; the only time in which two to record two is if there is an associated Health and Safety deficiency.
Erosion is displaced or runoff of soil
Grounds without ground cover is not necessarily erosion. Inspectors must be sure that they see signs of runoff such as rutting or gathering of sand/dirt on walkways or driveways instead of recording erosion based only on the grass not growing in certain areas. To clarify, if a section of the lawn has been worn down as tenants or others have used the lawn as a path of travel, it should not be recorded as a deficiency unless the soil has been displaced or a rut/groove has developed.
Tenant Owned Items Creating Hazards
During a REAC inspection, all life safety hazards created by resident-owned personal property (except blocked egress and improperly stored flammables) are to be recorded under Health and Safety – Hazards-Other for any defects that could cause bodily harm. It is important to know that any items recorded under Health and Safety Hazards-Other are non-point scoring. It should be noted that appliances (stoves, fridges, air conditioners) are always inspected with the assumption that the property owns the appliances.
Gaps in Breaker Panels
Breaker Panels will be recorded for a deficiency if there is a gap of more than one-quarter of an inch ONLY between the breakers and the interior panel cover. The inspectors must now physically measure each gap in front of the property representative. A visual determination without a measuring device is no longer acceptable.
The presentation also included a list of examples of pictures that provided clarification on certain situations for REAC Inspectors. Some of these include:
Holes in a Door from Removed Hardware
If a self-closing device that was removed by someone at the property, but the screws remained, creating a deficiency of inoperable hardware. You must eliminate the screws and bolts, fill in the holes, and then paint the door. Bathroom sink and tub stoppers are only an L1 deficiency and not a Level 3 for missing hardware.
Loose Outlet Covers:
Inspectors are no longer allowed to pull on the plastic switch and outlet covers to create a gap, but loose and damaged outlet covers are still a Level 1 deficiency if observed without a physical test.
Stairs without Handrails:
When counting stairs that require handrails, inspectors are to count the risers; if there are three steps and a landing, then that would have four risers and require a handrail. A property only needs to have a handrail on one side of the stairs, but if two are present, both will be inspected.
Homemade heater covers:
Makeshift or homemade panel or space heater covers are no longer acceptable, and you must try to locate the appropriate heater covers and end caps to match the existing components.