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February 23, 2022 Kathi Markan

February HUD-REAC Newsletter: Door Hardware

In this February 2022 issue of our HUD-REAC Monthly Newsletter, I am going to discuss the Door Hardware deficiencies that can be recorded under Exterior, Common Areas and Units.  As far as scoring value, it depends on how large your property and where the door is recorded as a deficiency.  Generally, doors recorded under Exterior are the highest scoring then Common Areas and then Units.  For a single-building property, an Exterior door can be as high as 10 points!  On average, a Level 3 Unit door is worth approximately 0.2 points.

Door Hardware:

Compilation Bulletin and Federal Register rules regarding door hardware:

  • A lock is not required on any door – but not having one for the Unit entry doors opens you up to liability. Otherwise, if it’s there, it has to work with 3 exceptions:
    1. Bedroom doors on public housing can have missing OR broken locks – this is in the Federal Register only.
    2. Common Area interior doors can have missing locks (not damaged)
    3. 504 Units may have missing locks (not damaged)
  • Door closers – can be a spring, spring hinge or closer
    1. Must self-close AND latch the door
    2. The inspector must try to door at 2 different angles (45° or 90°) – if it does not latch after the 2nd try, it’s a deficiency.
    3. You and/or the resident are not permitted to open a window to allow the door to self-close. Although with the current COVID-19 protocol, you’re required to open all of the windows and doors!  Bottom line, the door closer should work with and without the windows/doors being opened.

 

  • If your door alarm doesn’t work, fix it or remove all the evidence of its existence! (Although HUD does not require door alarms, clear the removal of them with your Fire Marshall and insurance companies)

 

 

  • A stick can no longer substitute for the primary lock of a sliding glass door, but can still be used as a secondary lock.

 

  • Units absolutely can have chain locks, U-locks, sliding locks, etc.
    1. IF DAMAGED, the inspector must determine if you installed it or the tenant and only record it as a deficiency if you installed it (not the resident).
    2. If most of the units have the same type of lock installed, the inspector will assume you installed them and only record the deficiency if it’s damaged.
    3. It CANNOT take a tool (key, scissors, screwdriver) to unlock it from the inside – otherwise, it’s a blocked egress.

 

 

  • You are not permitted to reinstall the pin into the track for bi-fold doors – it will be recorded as a Level 1 (very low scoring)

 

 

  • A missing strike plate from a door frame is a deficiency – whether it is a wood or metal frame. MAKE SURE YOU USE A LATCH STRIKE PLATE FOR THE LATCH – NOT A DEAD BOLT STRIKE PLATE – or it will be recorded as a Not Industry Standard (NIS) repair!