HUD NSPIRE November-December 2025 Newsletter: Egress Standard

I am combining November and December into one long Newsletter because it focuses on a topic that needs a lot of discussion – the Egress Standard.
In 2022, a terrible tragedy occurred at a rowhouse in the Fairmount neighborhood of the Philadelphia Housing Authority.  12 people perished (9 of them children) when a Christmas tree caught fire.  Of the 7 smoke alarms present, only 1 worked…in the basement.  Fire safety (smoke alarms, egress, sprinklers, fire extinguishers, etc.) is SO important and very often overlooked.

All 3 deficiencies under the Egress Standard are LIFE-THREATENING Health & Safeties and (for those that get scored REAC inspections) rack up points fast – if you have 1 LT cited in HALF the units inspected, you will fail your inspection because if 30 points or more are lost in the Unit inspectable area…you will receive a score of 59 (fail).
Deficiency #1: Obstructed Means of Egress
HUD defines Egress as “a safe, continuous, and unobstructed path of travel from any point in the building, unit, or structure to the public way.”
There are 3 components to the Means of Egress: Exit Access, Exit and Exit Discharge.  Simply put:
Exit Access: Path from any interior location to an exit.
Exit: Door to the outside or enclosed exit stairway.
Exit Discharge: Path from an Exit to the public way.

First, we’re going to focus on Units and Inside (common areas).
This is the deficiency where resident personal property CAN be cited as an obstruction to the exit access (pathway) and exit (doors).
Here are some examples of an obstructed Exit Access or Exit in the Units from HUD:

I highlighted the most important and most common egress violations above.
“Special knowledge or effort” can mean the door swelled and sticks to the frame making it difficult to open and child safety devices installed on the door handles!

Wandering/Escaping concerns for individuals with Alzheimer’s, Autism, etc.
This is obviously a significant issue.  This article provides a few suggestions on what is permitted by Fire Code:
Minnesota asst. fire marshal warns of dangers with locking a loved one with autism in their room
The absolute best advice I can give here is to reach out to your Building Official (Authority Having Jurisdiction – AHJ) or Fire Marshal to find out what is permitted in your jurisdiction.
Some jurisdictions (and leases) permit:

1. Security chains
2. Flip U-locks
3. Night latch, etc – as long as it does not take a tool (like a key) to exit.

Door alarms or tracking technology like GPS bands and Care Trak are also good ideas.

“Placement of an item or furniture that obstructs a means of egress” is, unfortunately, vague and subjective.  How wide do the doors need to swing?  What is the acceptable width of the exit access (pathway)?
Fire code mandates a 32” clear width with the door open 90 degrees.  Thus, storing ANYTHING behind doors reduces the 32” clear width requirement.

Under HUD’s Door – Fire-Labeled NSPIRE Standard , Deficiency 1 states:

How much is reasonable for HUD?  I am hoping this is clarified when they update the Standards in Summer of 2026.  In the meantime, follow Fire Code.
Regarding the pathway…you want 36” from the bedroom door to the exit door.  Again, you should verify with your Fire Marshal so that if we need to appeal, the pathway measurements must meet your local code requirements.
The code does not specify a minimum pathway width inside the bedroom itself, only that the door and the path to the exit from the bedroom door must meet egress requirements.  Some local jurisdictions interpret this as at least 24–28 inches of unobstructed space around furniture, but that’s not a federal or state-mandated number.  Keep in mind that the egressable window must also be accessible (this is discussed under Deficiency #2).

The following images show commonly cited Obstructed Exit (door) and Exit Access (pathway) deficiencies:

The Obstructed Means of Egress (Deficiency #1) for the Outside focuses on Exit Discharge (path from the exit to the public way).
HUD provides the following examples:

“May” is an important word. A private patio gate that does not provide a required exit path from the dwelling to the public way is typically treated like a fence or barrier.  However, you need to confirm this with your local Fire Marshal or AHJ because they may consider the patio gates part of the exit discharge.

The GOOD news is that since it’s cited on the “Outside,” it will only score ONE TIME regardless of how many times it is cited.

Deficiency #2: Sleeping Room is on the 3^rd Floor or Below and Has an Obstructed Rescue Opening.
This deficiency applies ONLY to the egressable bedroom window in UNITS.
This deficiency does NOT apply to:

1. Common area windows (like offices, laundry rooms, etc)
2. Doors
3. Pathways

Why did I say “egressable” bedroom window?  Some properties are very old, and their windows don’t meet current code requirements – thus they are “grandfathered in” because the cost of replacing them would be ridiculous.
In these cases, HUD’s deficiency would not be applicable.

November – December 2025:
Egress Standard

Here are the Fire Code requirements for bedroom windows:

What about resident furniture that obstructs the rescue opening?
A political decision was made that resident-owned property will NOT be considered an obstructed rescue opening.  None of us know what the reasoning was, however it IS still a Fire Code violation and PHA/POA (Public Housing and Multifamily properties) are still liable!!!
Here is the rule in writing from the NSPIRE Egress Standard:

What does qualify as an obstructed rescue opening for HUD?

“Special knowledge or effort”
If I almost get a hernia trying to open a window…how can the senior resident open it?  I once had a maintenance man tell me that 90% of his job was opening and shutting windows for the residents at a Senior property.  I told him to find a good lubricant or call the window manufacturer for suggestions because that is absolutely nuts!
Here are some examples that do meet the deficiency criteria:

Deficiency #3: Fire Escape Access is Obstructed
2 rules that may shock you:

1. This deficiency ONLY applies to Units just like Deficiency #2.  This may change in the next update, because common area fire escape access should never be obstructed.
2. If the fire escape is obstructed by resident-owned property, it is NOT cited as a deficiency!

Here is the verbiage from the Standard:

What does qualify as an obstructed fire escape access?
It’s the exact same rules as Deficiency #2:

Resources
HUD has PDFs (videos are currently down) on how to appeal and how to close out H&S deficiencies here:
NSPIRE Toolkit
**Remember, if you will be appealing something,
your “defect mitigation in 24 hours” is that you are appealing…not that you fixed it!**

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