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April 15, 2021 Kathi Markan

NSPIRE Standards (Deficiencies) Updated

You spoke up…and HUD listened! This is the first step in the right direction in developing the NSPIRE program which will eventually replace the current HUD-REAC inspection. This April Newsletter will highlight some of the significant positive changes HUD just released as well as the next changes that will need to be advocated. It’s a bit long, but organized into:

  1. Breakdown of the Update
  2. The Good News
  3. Both Good News and Bad News
  4. HUD Needs More Feedback!

Important Note: These are still PROPOSED changes to the NSPIRE program – nothing is set in stone yet and all current REAC deficiencies remain unchanged.

Breakdown of the Update

  • You can find the standards here: HUD NSPIRE (National Standards for the Physical Inspection of Real Estate)
  • There are 62 Standards posted down from 63. Bathroom ventilation was moved to a deficiency under the category “Mold-Like Substance.”
  • 43 of the 62 Standards were significantly updated (mostly good news but some still need work) and are listed in the table below. I will be highlighting a few in this Newsletter:

The Good News

  1. They changed the “Fire Extinguisher Missing” deficiency so that you do NOT have to supply one to every unit if you never have before!

  1. They made the Carbon Monoxide deficiency criteria MUCH more understandable, less restrictive (no longer a 15 foot requirement), and added that all requirements of the IFC Section 915 and IFC Section 1103 must be met even though only a few of the criteria is inspectable under NSPIRE:

  1. They removed the deficiency “Missing Safety Divider or Shield” for water heaters.
  2. Per the Proposed Rule that you provided Feedback on from last month:
    1. They did NOT add a deficiency for the inadequate number of outlets in habitable rooms.
    2. They indirectly added the requirement for a permanent heating source:– They added the verbiage requiring a Guardrail where the drop off is 30 inches or more vertically even if there is no previous evidence of a prior installation. (Yes, this is a good thing)- – GFCI/AFCI and Lighting are discussed later in this Newsletter.

Both Good and Bad News

  1. At first, I was excited that they removed the requirement for GFCIs within 6 feet of a water source and outside. Then I saw they just moved the deficiency to the Outlet & Switches category.

Good News:

Instead of a blanket “within 6 feet of all water sources,” they allowed for a few exceptions – which should decrease the financial burden:

Bad News:

For those with older housing stock, this could still be a pretty substantial financial burden to comply with.

  1. The previous Smoke Alarm requirement was confusing. HUD seriously simplified the deficiency.

Good News:

For many years NFPA 72, National Fire Alarm and Signaling Code, has required as a minimum that smoke alarms be installed inside every sleep room (even for existing homes) in addition to requiring them outside each sleeping area and on every level of the home. Looks like HUD is enforcing this and it’s a good idea safety-wise. However, unless your insurance requires it or you are new construction, hard-wired smoke detectors are not required.

Bad News:

This could be a financial burden for many of you – especially if your insurance company requires the smoke detectors to be hard-wired.

  1. Under Doors – Entry

Good News:

They changed the damaged seal defect for thermopane windows from a 30 day repair (Health & Safety) to an observation (NO H&S) with an unspecified length of time to repair.

Bad News:

Don’t get too excited…it’s still a Standard Health & Safety with a 30 day repair requirement for Unit Windows. Either the Doors will change to match the Windows or vice versa. Probably.x

 

HUD Needs More Feedback!

  1. There are 56 Health and Safeties to be repaired within 24 hours (Severe Health & Safeties) compared to the 16 current REAC/UPCS exigent health and safeties.
    1. For example, an infestation of 3 or more live cockroaches in a unit is a 24 hour repair….good luck with that!
  2. I didn’t even bother to count the Standard Health & Safeties (repair required within 30 days) because other than a few stragglers, ALL of the deficiencies listed are either Standard Health & Safety or Severe Health & Safety. Even the Address Signage!
  3. They modified the Lighting – Interior deficiency so that a permanently mounted fixture in the bathroom or kitchen is not required, but “sufficient illumination” in those areas is required. Unfortunately, although I understand their intention, by changing this verbiage they have made this deficiency absolutely subjective – which goes directly against NSPIREs Primary Goal of objectivity and replicability of inspections:
  4. There are quite a few deficiencies (Standards) that need SERIOUS work like Egress and Site Drainage. As my thoughts are long on both subjects, either contact me or attend one of my Webinars to hear all about it!