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REAC Inspections and Hoarders

Is there a specific REAC deficiency for hoarding and other housekeeping issues?

One of the most regular questions we receive has to do with hoarders. More specifically, is there a REAC deficiency which addresses tenants who are collectors of large volumes of belongings, commonly known as “Hoarding”?

The answer is: No. There is no specific deficiency for hoarding.

That, however, does not mean that there are not relevant deficiencies that might occur in units that occur in apartments where there is hoarding. It is common to see issues such as these in hoarding units:

Health & Safety – Excessive Garbage and Debris – Indoors

If an apartment has excessive items of trash or debris collected- it should be cited as “Health and Safety – Garbage.” This deficiency is defined as a disorderly accumulation of garbage in an area not designed for storing garbage. If the resident has a pile of pizza boxes, it would be considered excessive garbage. Whereas a collection of phone books would not, no matter how large the amount.

Housekeeping Issues During REAC Inspections

    1. A tenant has clothes thrown all over a unit: this is not a UPCS Issue unless you determine that the clothes are actually garage (not in a fashion sense).
    2. Disorderly accumulation of papers, empty boxes near appliances or gas water heaters – this would be an H&S UPCS Issue.
    3. The unit and everything in it is covered in tin-foil: this is not a UPCS Issue unless it prevents access to exits or breakers or fuses.
    4. Dirty Dishes in the sink, piles of clothes on top of washing machines – not a UPCS Issue.
    5. Overflowing Closet – only H&S if (a) there is a breaker or fuse panel in the closet that cannot be accessed because of the overflowed items or (b) the “stuff” in the closet is would be considered “garbage”.

Health and Safety Issues Related to Hoarding

Health & Safety – Blocked emergency exits.

In some cases of hoarding, the items being stored by the tenant actually create a barrier that prevents windows from being accessed and doors from being opened. This is not Hoarding in UPCS but Blocked Emergency Egress. The definition to keep in mind here is that you can be cited for blocked egress if there are “fixed objects of significant size and weight impeding access to a room’s exits in the case of an emergency”. This only applies to the third floor and below, unless the stored items prevent any access to a room at all. If the inspector believes that a tenant can easily move the stored items in the case of an emergency, or climb over the items, then it should not be considered a blocked egress.

Health & Safety – “Other”

If the REAC inspector observes a condition created that is so unsanitary that it should be noted, the inspector can record it as “Other Hazards”. Other hazards is a deficiency that is defined as “Something hazardous that is not defined elsewhere“. On a REAC inspection, this would be a non-scoring citation. On a UPCS Inspection for LIHTC, the scoring distinction is not relevant and anything cited as “Other” is treated the same as any other H&S issue.

If you should have any questions, please do not hesitate to contact us.

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