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April’s Newsletter reviews the only deficiency under the Flammable and Combustible Item Standard. This is quickly becoming the number one misrecorded deficiency on NSPIRE inspections and honestly has me pretty fired up because it is scored at the highest-scoring, Life-Threatening H&S level!
Why did HUD use the verbiage, “an appliance that provides heat for thermal comfort?”
Because HUD did NOT want inspectors citing paper/plastic/wood in or on stoves!!!
What do stoves provide heat for? Cooking!!!!
We all know some residents use their stoves to heat their unit although this is against fire code and common sense. HUD says in 2 different Standards that stoves are NOT considered an appliance that “provides heat for thermal comfort!”
HVAC Standard:
Cooking Appliance Standard:
In every single Standard, if something else is wrong with an inspectable item – HUD makes it clear which Standard that should be cited in. This is NOT the case for flammable/combustibles for stoves where HUD only states to make sure nothing will burn or melt on the burners or inside the oven.
This should not be shocking to anyone. Under UPCS (the old protocol), if we found anything that could burn on top of or inside stoves – we were directed to cite it as “Health & Safety: Hazards: Other” which was a NON-SCORING section!
NSPIRE does not have a non-scoring section which is why HUD directs inspectors only to cite appliances that provide heat for thermal comfort.
What if the inspector insists on citing the storage in or on top of the stove as a deficiency?
Ask them to cite it under the Cooking Appliance Standard – the highest-scoring deficiency under that Standard is Severe H&S. Severe Health & Safeties are a 24-hour required correction on scored properties and a 30-day correction timeframe for Voucher properties. This works out to be 0.6 per unit on a 100-unit property. This is A LOT better than 2.40 points per unit on a 100-unit property!!!!
I know many of you try to speak as little as possible to the inspector, however this is an instance where you need to speak up! It is difficult to convince the reviewers at HUD to permit an appeal on storing paper and plastic in the oven when everyone knows you shouldn’t do it.
Why is there confusion?
Because HUD listed stoves and ovens as potential “locations” under this Standard. So, while the Deficiency and the Criteria match perfectly and seem crystal clear…HUD throws this in to confuse everyone:
This is not the only Standard where “Locations” make little to no sense or are the complete opposite of what the deficiencies within the Standards direct inspectors to actually cite as deficient.
Additionally, HUD still has not provided a thorough training for the inspectors and many of the Standards raise more questions than provide answers.
What are some appliances that provide heat for thermal comfort?
- Forced air furnaces
- Electric heaters (including portable space heaters)
- Gas fired wall heaters
- Hydronic (radiant) heaters (typically don’t get hot enough to burn – need clearance for air circulation only)
- Heat pumps (generally no clearances for indoor air handler but outside needs 24 inch clearance JUST for maximum airflow)
3 feet…which direction?!
There are clearances for many reasons including working space, ventilation, and fire prevention. HUD is focusing on preventing fires in this Standard.
Required clearances depend on the heating system you use and your local fire code! Some clearances are 12 inches, and some are 2 feet. HUD, being federal, went with the strictest code which, for most of you, makes for an easier appeal.
ANY time you can get the Fire Marshall to state, in writing, that something is acceptable per fire code – it’s a slam dunk appeal. Fire trumps HUD 100% of the time.
Also look at the manufacturer’s instructions! For instance, on many electric baseboard heaters, clearance in front is 3 feet…but it’s 6 inches on the sides and 12 inches above!
3 feet clearance for fuel-fired water heaters?
Honestly – I’m not sure where HUD got this guidance. The general rule is a 12-18 inch clearance for flammable and combustible items stored near fuel-fired water heaters. If anyone has a stricter code than this, I would love to see it!
Check your manufacturer instructions for clearance distance and/or your Fire Marshall. It’s worth the effort appealing this high-scoring item!
What does HUD mean by “improperly stored chemicals?”
Gas, propane, butane, kerosene, etc should NEVER be found Inside (common areas) nor in a Unit.
This includes gas-fired equipment like motorcycles, lawn mowers, etc.
Electrical components are NOT considered ignition sources now!
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