April 15, 2020 Kathi Markan

Fire Extinguisher & Fire Hose Deficiencies


In this April edition of our HUD-REAC Blog, I will be discussing the defects associated with your Fire Extinguishers and Fire Hoses.

Most Important Takeaways: 

  • For a single building property, a Level 3 defect is a ten-point deduction!
  • Fire extinguisher deficiencies are cumulative (explained below)
  • Fire extinguishers supplied by the property that are missing, expired, discharged, or otherwise damaged will be cited as a deficiency regardless if it is or is not required by local code.
  • Defective or expired extinguishers clearly owned by the resident will be recorded as H&S: Hazards/Other (a non-scoring area)
  • If fire extinguishers are not present and there is no evidence (such as mounting brackets or fire cabinets) that they are supposed to be present – there is no deficiency. This is dependent on your local/state codes!
  • If an extinguisher tag is missing during the inspection, you can show proof they have been inspected/serviced (within a year of the inspection) from an authorized agency and no deficiency will be recorded!
  • Inspectors should not evaluate fire extinguishers not obviously positioned for service (such as multiple stored extinguishers located in the shop)

HUD’s Defect Definition from the Federal Register: 

  • NOTE:
    • This includes missing/damaged fire hoses where there are fire cabinets
    • For buildings with multiple fire control systems, 5% or less of the extinguishers may be missing, damaged and/or expired. In such cases, do not record as a deficiency.
    • If the tag is missing, the accompanying POA may produce proof that the certification is current. If you see the proof, do not record a deficiency.
  • Level 1: For a building with only 1 fire control system, 5% or less of the fire extinguishers are missing, damaged or expired.
  • Level 2: For all buildings, 5% to 10% of the fire extinguishers are missing, damaged, or expired.
  • Level 3: For all buildings, more than 10% of the fire extinguishers are missing, damaged, or expired – OR—There is not an operable/non-expired fire extinguisher on each floor.

What do you mean “Fire Extinguisher deficiencies are cumulative”?

  • The inspector is to count all of the fire extinguishers/hoses in each building including common areas, exteriors, and sample units (not all the units – just those in the sample).
  • The inspector then divides the damaged, missing, or expired extinguishers by how many are present to determine a percentage per building.
    • Example: (Assume all units have extinguishers) An 80 unit, high-rise building has 10 common area extinguishers and 20 sample units. The fire extinguisher in a mechanical room and 2 sample units have expired extinguishers – therefore, 3 out of 30 inspectable extinguishers (or 10%) are expired. A level 2 deficiency would be recorded. (See above for Level criteria)

How are Fire Hoses inspected?

  • If ALL fire hoses and hanger hardware have been removed from within a hose cabinet, no deficiency should be recorded.
  • It is permitted for fire hose cabinets to be left in place
  • If the fire hoses have been removed, but hanger hardware is still in place, the missing hoses will be counted by substituting the hoses for extinguishers for calculation.
  • The UPCS protocol does not require fire hoses to have inspection tags, thus no deficiency will be recorded for hoses with expired or missing tags.

What exactly is inspected on Fire Extinguishers?

  • The gauge needs to be in the green – overcharged, under/discharged is a deficiency

  • For UPCS Protocol, the tag must be punched within 1 year of the inspection and should be signed (most inspectors do not cite a deficiency for an unsigned tag). Some local jurisdictions require maintenance to document on the back of the tag their inspection of the gauge and tag once a month.

If you purchase a new extinguisher prior to inspection, make sure you punch and attach the tag that came in the box.

NOTE: It is very common for extinguisher companies to punch multiple tags at once and not see that there is a different year on one of the tags.  I had a tag punched for 2036 once!

  • Missing fire extinguishers – noted by an empty mounting bracket or cabinet

  • Disposable extinguishers are NOT evaluated for an inspection tag – only whether the gauge is in the green or not.

In conclusion, during the inspection, the REAC inspector will typically record a Level 3 and take a photo at the very first damaged, missing, expired tag, or over/undercharged fire extinguisher they find. This is so they will not have to go back after doing the calculations for the building – they have no idea how many they will find during the inspection and no inspector wants to rewalk the property again.

You must keep track and remind the inspector of how many fire extinguishers are in the building because, if the total defective is under 10%, you can get a lower level deficiency (or no deficiency) which is a much lower point deduction!