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April 18, 2023 Kathi Markan

April HUD REAC/NSPIRE Newsletter: Door Surface Damage

ANNOUNCEMENTS

‘NSPIRE: What We Know So Far!’ is a 2-hour live webinar training

which will be held on April 28th

from 10 am – 12 pm PST (1 pm – 3 pm EST)

Register here: “Getting REAC Ready” Training

Don’t forget that you have until April 27th to provide HUD with feedback on their NSPIRE scoring model – instructions are here: NSPIRE Scoring Feedback Instructions

In this April 2023 issue of our HUD-REAC/UPCS/NSPIRE Monthly Newsletter, I am going to be discussing Door Surface Damage. This is currently a deficiency for REAC and will continue to be a deficiency for NSPIRE. It has come to my attention that there are a few inspectors recording kick plates as a NIS (Not Industry Standards) deficiency when the industry, as well as HUD themselves, clearly endorse the use of kick plates and other surface guards as a way to protect, reinforce and increase the lifespan of the door!

 

REAC – Doors – Damaged Surface

  • Definition: Damage includes holes (1/4” or more), significant peeling/cracking/no                                     paint, or rust that:
  1. May affect either the surface protection or strength of the door
  2. May compromise building security
  • Fire, Entry, Bathroom and Security doors are always a Level 3. If the hole is between ¼” to 1” then it could be a Level 2 for bedroom or closet doors.
  • The scoring value depends on where the door is recorded (Exterior, Common Area, or Unit), how many buildings/units the property has and how many N/A’s the inspector records. Basically, it’s complicated…the point range is 0.2 to 10 points dependent on the factors listed above.
  • Missing hardware is considered a hole and should be recorded under Damaged Surface
  • Delaminated doors that are screwed together is not an acceptable repair and will be recorded under Damaged Surface with a NIS comment.
  • If most of the doors are unpainted or unvarnished, do not record them as a deficiency (I never understood this rule – it does not make sense)

 

NSPIRE – Doors – Damaged Surface

  • Entry Door Standard
  1. Deficiency 5 (Units and Inside – Moderate H&S (30-day repair)): Hole or a crack with separation is present, or the glass is missing within the door, sidelights or transom
  2. Deficiency 7 (Units and Inside – Moderate H&S (30-day repair)): Delamination or separation that affects the integrity of the door (i.e surface protection or the strength of the door)
  • Fire Labeled Door Standard
  1. Deficiency 3 (Units, Inside, Outside – Severe H&S (24-hour repair)): Hole of any size or is damaged such that its integrity may be compromised. This deficiency is also applicable to damage to the frame and/or glass.
  • General Door Standard
  1. Deficiency 2 and 3 (Units and/or Inside – Advisory (unspecified time requirement to repair)): A passage door component is damaged, inoperable or missing.
  2. Deficiency 4 (Outside – Moderate H&S (30-day repair) – An exterior door component is damaged, inoperable or missing.

 

HUD Supports Kick Plates

  1. From HUD’s Public Housing Modernization Standards Handbook 7485.2 Chapter 10:

10-7B.j: Kickplates. In locations where door bases are continually abused, kickplates that are the width of the door and a minimum of 18 inches high may be provided.

***Important Note: If the door is Fire Labeled, anything over 16 inches must be tested and approved for fire assemblies (NFPA 80)***

  1. Fair Housing Act Design Manual pg 3-4 mentions optional kickplates “to protect surface of door.”

 

Acceptable Industry Standard Solutions

Door surface guards provide an added layer of protection to strengthen doors and to prevent scratches, scuffs, and dents, helping to keep your doors looking new for longer. It goes without saying that these, in the long run, will save properties a lot of money in labor and material costs!

When an inspector sees these, they should not assume the management is covering up damage but rather preventing damage from occurring.  I heard one inspector say, “The kickplates are not on every door!”  My response was, “What if the other tenants are not mobility-impaired and don’t need one?”  The fact that some doors have them while others don’t should NOT be a red flag for the inspector.  Here are some common, industry standard door surface guards:

Door Edge Guards example photo for NSPIR HUD REAC Inspection