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September 30, 2024 Kathi Markan

HUD NSPIRE September Newsletter: Deficiencies that Start Scoring October 1st 

September Newsletter:

Deficiencies that Start Scoring October 1st

NSPIRE TRAINING ANNOUNCEMENT!
‘HUD-NSPIRE Demystified: A Deep Dive into the New Inspection Process’

4-day Training is scheduled for January 22, 23, 29, and 30th
9 am – 12:30 pm PST (12 pm – 3:30 pm EST):
NSPIRE Demystified Training

Click here to check out free, downloadable REAC Resources

September’s Newsletter discusses the deficiencies that will begin scoring on October 1st…and the deficiencies that will remain non-scoring “for the foreseeable future!”
Click here to see all the NSPIRE Standards and their deficiencies: NSPIRE Standards
Click here to read the Final Scoring Notice from 07/07/23: NSPIRE Final Scoring Notice

Deficiencies that remain NON-SCORING in all applicable inspectable areas

  1. Carbon Monoxide Alarms and Detectors – ALL deficiencies

These remain “Life-Threatening” and must be repaired/corrected within 24 hours (or communicated to HUD why you need additional time) …but are NOT SCORED.

  1. Smoke Alarms and Detectors – ALL deficiencies

Same as CO Alarms – these will stay Life-Threatening but not scored against the property. Battery-only (not hard-wired) smoke alarms will have to be 10-year, tamper-resistant, sealed batteries and contain a way to hush/silence by December 29th, 2024.If a hard-wired smoke alarm is missing, there is a chance that the exposed wires could be cited AND scored thanks to a webinar training approximately a year ago…although this was not HUD’s intent.

  1. Call-for-Aid – ONLY Deficiency #1, “System is blocked, or pull cord is higher than 6 inches off the floor.”

Both deficiencies listed under the Call-for-Aid Standard are considered Life-Threatening, but only Deficiency #1 is not scored. Deficiency #2, “System does not function properly” is absolutely scored and is often mistakenly clicked on by inspectors. Deficiency #2 should only be cited in the following scenarios:
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  1. Handrail Standard – ONLY Deficiencies #1 and #4 are not scored: “Handrail is missing” and “Handrail is not installed where required.”

The other 2 deficiencies, “Handrail is not secure” and “Handrail is not functionally adequate” will continue to score at the Moderate H&S level.
Additionally, there is no requirement to install a handrail where the inspector believes it is required. It is the ONLY deficiency out of all the Standards categorized as a N/A under Units.Under the Inside and Outside inspectable areas, it is listed as a Low H&S…but there is no requirement to install the handrail per the 35-page “Complementary Document” to the NSPIRE Rule here: Inspection Standards – 35 page Supplemental Document

Deficiencies that START SCORING 10/01/24

  1. Door – Fire Labeled Standard – All 7 Deficiencies

To be cited as a Fire Labeled Door, a tag/plug must be on the door or frame. If unable to determine if a tag/plug is present (missing or painted over), and one other door along the egress path has a fire tag/plug, then the door will be considered fire labeled.

  1. Electrical – GFCI or AFCI – Outlet or Breaker Standard – Deficiency #3, “An unprotected outlet is present within 6 feet of a water source.”

Up until now, this deficiency was cited but not scored – primarily to give properties time to comply with this expensive requirement.  I have fully analyzed this deficiency in a few previous Newsletters.  Click here to read them: August 2024 Newsletter and  January 2024 Newsletter

  1. Guardrail Standard – both deficiencies.

Both deficiencies are Life-Threatening and can be cited in all 3 inspectable areas. Any time you have a drop of 30 inches or more, the inspector will be evaluating whether you need to have a guardrail installed. Please note: this also includes the balusters connected to the handrail for staircases.

  1. HVAC Standard – Deficiencies 1, 2 and 7

Instead of looking them up, the bottom line is if your heater is not working – it will be scored at the Life-Threatening level. MAKE SURE YOU REPLACE ALL THE BATTERIES ON THE THERMOSTATS PRIOR TO INSPECTION! There is nothing in writing by HUD allowing you to change the thermostat battery on the day of inspection.

  1. Lighting – Interior Standard – Deficiency #3, “At least one (1) permanently installed light fixture is not present in the kitchen and bathroom.”

I cannot imagine any property other than historical housing will have an issue with this deficiency.

  1. Minimum Electrical and Lighting Standard – At least two (2) working outlets are not present within each habitable room OR at least one (1) working outlet and one (1) permanently installed light fixture is not present within each habitable room.

The 4 habitable rooms are: Living room, Bedroom, Dining Room, and Kitchen
Keep in mind that HUD defines a “working outlet” as one that allows the user to SAFELY access power. This means that the inspectors will have to be able to gain access to the outlets to test them with their circuit tester! Units subject to hoarding may have a difficult time providing access to 2 outlets (if there is no permanent light source) so please start informing your residents immediately! Although not expressly permitted in writing by HUD, common sense indicates that if the resident or the property contact is willing to move furniture to provide access to test the outlet receptacle, this deficiency would not be cited.

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