NSPIRE Exposed Electrical Conductors: New Inspector Guidance for this High-Scoring Deficiency!
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Because this will be a long Newsletter, I am combining October and November’s Monthly Newsletter into this single topic. This Newsletter details the new inspector guidance from HUD for the high-scoring NSPIRE deficiency: Exposed Electrical Conductors located under the Electrical – Conductor, Outlet and Switch Standard.
This is considered a Life-Threatening deficiency.
On a 100-unit property the total points lost for each inspectable area are:
There are 2 parts to the Deficiency Criteria and the first one is GREAT news!
Part 1: An opening or gap is present and measures greater than ½ inch
This is incredible, amazing news because it was only ¼ inch under HUD’s UPCS Protocol (about the size of a #2 pencil). Now that HUD has made it ½ inch, filling the gap with a dummy breaker or a manufactured blank will be much easier!
Now the bad news:
Part 2: Electrical conductor is not enclosed or properly insulated.
Doesn’t sound too bad, right? Then HUD provides examples of when the deficiency should be cited:
- Wiring that is insulated but not protected by sheathing or conduit.
Let’s stop and explain this one….
HUD wants ALL insulated wires to be enclosed in either a sheath or conduit.
If you have an older range hood…your lightbulb looks something like this:
What about this…should it be cited since it’s not enclosed in a sheath or conduit?
My advice is for maintenance to KNOW which wiring is low voltage and which isn’t. That way if an inspector wants to cite thermostat or fire alarm wiring…you can confidently tell him/her it is LOW VOLTAGE and HUD states it cannot be cited.
- Knockouts missing
This is the same as it was under the UPCS protocol – do not forget to check UNDER j-boxes (including any j-boxes located outside), breaker panels, disconnects, timer boxes, and garbage disposals!
- Visible wire nuts on electrical conductors
HUD wants ALL wires to be sheathed or within a conduit terminating into a junction box or other secured cover to where wire nuts cannot be observed.
- HARDWIRED SMOKE ALARM WITH EXPOSED CONDUCTOR
In previous versions of the Standards, HUD had it listed as just “Hardwired smoke alarm missing.” After pointing this out to HUD, they changed it to read, “Hardwired smoke alarm with exposed conductor.”
This was SUPPOSED to mean that the white terminal was missing…exposing wires.
Appeal every one of these. The electrician needs to state that the wires are not designed to be enclosed by a sheath nor conduit, all conductors are technically covered, and that there are no safety issues.
This one is really going to hurt. Smoke alarms cited as missing under the Smoke Alarm Standard are not scored…but if the inspector cites them as exposed conductors – it is scored at the LIFE-THREATENING scoring level once per Unit!
- Improper material –
HUD says inspectors are not permitted to say NIS anymore (Not Industry Standard)…but that does not mean they should not cite it!
Some examples of improper material used in electrical boxes are:
Leather Wood
Caulk/Silicone Foam
Rubber Tar
Metal that is not UL-rated for the box Cardboard
Tape (electrical, scotch, duct, etc).
- Missing Screws
Most inspectors will view missing screws as missing covers…which means exposed conductors.
MAKE SURE A SCREW IS PRESENT IN EACH SCREW HOLE!!!
Want some Good News?!
- HUD has instructed inspectors NOT to open timer boxes, disconnect boxes, generator transfer switches…even if they are unsecured!!!
Inspectors will need access to ALL breaker panels, even if there is only 1 breaker in the panel.
It is ok to lock the breaker panel – you just need to have the key!
Here is the guidance straight from HUD:
See the highlighted area? The doors are NOT required to be secured!
So what’s the catch? Inspectors are not on board with this yet. On a recent NSPIRE inspection, a federally employed QA (Quality Assurance) cited this on the property:
For an appeal, the problem is now it’s our word against HUD’s QA that the box was NOT open at the time of inspection…that the QA opened it which violates protocol.
You need to make this a non-issue. Keep putting zip ties on all disconnects and timer boxes and make sure all boxes are closed at the time of inspection. You can also nicely remind the inspector that HUD states under the Standard that only breaker panels should be opened by the inspector and nothing else.
- We already discussed that low voltage wiring cannot be cited as a deficiency, but also devices DESIGNED to intentionally have a gap or space to support ventilation should NOT be cited!
Here are 2 examples of breaker panels that are designed to have a gap. Let the inspector know it’s designed to be that way, but worst case scenario it is an easy appeal: a letter from a certified electrician stating the box is designed that way.
- Light fixtures that have exposed wiring by design are NOT to be cited as exposed conductors.
Probably because they usually have the wiring enclosed in a sheath or conduit like this:
- This one has to be a mistake…
But until HUD fixes it, if you have a missing or damaged ceiling-mounted light fixture – it CANNOT be cited per protocol. These 2 examples will show why I believe HUD made an error here…..
- The last bit of good news is that a missing light bulb from a fixture is NOT considered an exposed conductor!
It used to be…but HUD was shocked by how many residents had missing light bulbs and, when literally every property failed as a direct result, opted to remove that scenario as an example of an exposed conductor.
Let’s hope they do the same thing with hard-wired smoke alarms!!!