In this April 2022 issue of our HUD-REAC Monthly Newsletter, I have analyzed the few updates HUD just released to the NSPIRE Standards and provided my professional opinion as to whether these changes were good or need more work. Bottom line – most of these are good changes but MORE FEEDBACK IS NEEDED – only a few of the Standards were updated where many, many more need serious work.
Click here to see how you provide feedback to HUD on the NSPIRE Standards: How Do I Provide HUD with Feedback?
Call-For-Aid (aka Emergency Pull Cords)
- Deficiency 1 – Units and Inside – Pull cord is missing or end is higher than 6 inches off the floor
- Changed from a Standard Health & Safety (H&S) to a Severe Non-Life-Threatening (NLT) H&S – shortening the time frame of correction from 30 days to 24 hours.
- Voucher units still have the 30-day timeframe to repair
- Deficiency 2 – No change
- Deficiency 3 – Units and Inside – System is blocked
- Changed from a Standard H&S to a Severe NLT H&S shortening the time frame of correction from 30 days to 24 hours
- Voucher units still have the 30-day timeframe to repair
- Re-worded the Deficiency Criteria from “Call-for-aid system is blocked” to “Resident is physically impeded from using the call-for-aid pull cord
- OPINION: Reasonable. The Call-For-Aid is a lifesaving tool for residents, therefore it makes sense that, if not working, it be repaired within 24 hours. Although, with that logic, I’m not sure why HCV units have 30 days to repair.
Carbon Monoxide (CO) Alarms
- Inside and Units – Updated the previous Deficiency Criteria to a much more understandable outline format by providing scenarios to which you can more easily determine when and where you would need a CO alarm.
- You can read all about it here: NSPIRE – CO Alarm Updated Verbiage
- Updated some verbiage like changing “Detector” to “Alarm” throughout
- Allegedly revised the Rationales and Explanations but actually eliminated it – I believe this is an error.
- Under the “Inside” category (meaning common areas) – the verbiage specifically points out “classrooms” because that is how it reads in the Code. HUD further clarifies that, “a classroom may include but is not limited to daycare centers, community centers, and preschools.”
- You don’t want to put a CO alarm directly in a water heater or furnace closet because, upon firing, the appliances tend to burp out a bit of carbon monoxide that would cause the CO alarm to sound off incessantly. When in doubt – trust your Fire Marshall to accurately tell you where to place your CO alarms!
- OPINION: MUCH BETTER! The last version was very confusing and had to be re-read over and over to barely grasp what they wanted you to do.
Door – Fire Labeled
- Added 2 more deficiencies for a total of 6 in this category. The new deficiencies are:
- Deficiency 5: An object is present that may prevent the fire labeled door from closing and latching or self-closing and latching (such as kick-stops like the image shown here, but HUD also states furniture, tape, trash cans, rubber bands and wood wedges also cannot be used)
- Deficiency 6: Fire labeled door that serves as an entry door cannot be secured (Unit only) – it has to have at least 1 installed lock.
- Deficiency 5: An object is present that may prevent the fire labeled door from closing and latching or self-closing and latching (such as kick-stops like the image shown here, but HUD also states furniture, tape, trash cans, rubber bands and wood wedges also cannot be used)
- Added verbiage to Deficiency #2 to include damaged or missing self-closing devices like springs, spring hinges door closers.
- OPINION: Smart move. Fire doors serve a purpose – they hold the fire back a certain amount of time to allow for egress, protect escape routes from smoke gas and flames and potentially limit how much oxygen feeds the fire to slow it down. This is a retroactive Fire Code NFPA 80 requirement – looks like HUD is enforcing it! If you have a unique situation, check with your local Fire Marshall or Building Official (AHJ) for any code exemptions or provisions you may have applied to you.
Exit Sign
- HUD consolidated 3 deficiencies into one – Exit sign is damaged, missing, obstructed, or not adequately illuminated.
- The word EXIT must be clearly visible, and the sign must be securely affixed.
- They also removed some confusing code language. Bottom line, just like with REAC inspections, Exit signs are only considered missing if there is evidence one used to be there.
- OPINION: No major change here and appears to have been done to decrease the number of excessive deficiencies.
Fire Extinguisher
- In addition to “Fire Extinguisher is missing,” HUD included “damaged.”
- OPINION: No major change here. In my REAC/UPCS trainings, I teach that the words “damaged and missing” are synonymous according to HUD. With NSPIRE – it appears they are attempting to be as transparent as possible
Heating, Ventilation, and Air Conditioning (HVAC)
- HUD reworded deficiencies 1 and 2 to try to incorporate the words “damaged, inoperable, missing or not installed”
- Deficiency 1:
- Version 2.1: “Outside temperature is below 68 degrees Fahrenheit and the resident is unable to maintain a minimum temperature of 68 degrees Fahrenheit through a safe heating source.”
- Version 2.2: “A permanently installed heating source is damaged, inoperable, missing or not installed and the outside temperature is below 68 degrees Fahrenheit.”
- Deficiency 2:
- Version 2.1: “Outside temperature is 68 degrees Fahrenheit or above and the resident is unable to maintain a minimum temperature of 68 degrees Fahrenheit through a safe heating source.”
- Version 2.2: “A permanently installed heating source is damaged, inoperable, missing or not installed and the outside temperature is 68 degrees Fahrenheit or above.”
- OPINION: Mixed feelings. The code states: “…every dwelling unit shall be provided with heating facilities capable of maintaining a room temperature of not less than 68°F (20°C) at a point 3 feet (914 mm) above the floor and 2 feet (610 mm) from exterior walls in habitable rooms at the design temperature.”
The verbiage in the previous version of the Standards better reflected the actual code requirement because in the new version, they omitted the fact that 68 degrees must be maintained INSIDE THE UNIT. That being said, adding “damaged, inoperable, missing or not installed” seems to clarify the deficiency better than just stating “through a safe heating source.” Also, if it’s 68 degrees and above outside, perhaps they should address air conditioning in this deficiency…not heat. Good news is that if it’s 68 degrees or warmer outside, the deficiency is not considered a Health & Safety.
Mold-Like Substance
- Consolidated the Rationale verbiage for Deficiency 3 and 4 (Inside) – saying the same thing with less words.
- Changed Deficiency 4 (Unit) “Presence of mold-like substance at extremely high levels is observed visually” to a 24 hour repair for all programs (HCV and everyone else)
- OPINION – Good – they corrected an error from previous versions. “Extremely high levels” is considered more than 9 square feet per room. I would say that should be an immediate repair!