REAC Physical Inspection Clarifications

Regulation | October 16, 2017 | by Colleen Bloom

An updated REAC Compilation Bulletin for certified UPCS Inspectors has been issued for effect on October 2, 2017.  The new bulletin incorporates more visual examples, clarifications to procedures, and some troubling reversions in understanding on items like call-for-aid, and vegetation.

REAC's new Compilation Bulletin RAPID 4.0 Version 3  (not yet posted on the main REAC inspection webpage) incorporates explanations of new procedures and more pictures to enhance revisions to guidance previously distributed to inspectors. Many of the updated examples appear to be related directly to last year’s addition of industry standard repairs requirements. Notes are now required in the comments section for any non-industry standard repair (NIS). Interestingly, however, it does not specifically require that a photo be included.

New guidance concerning inspection protocols and inspector behavior includes:

  • Property/Owner Participation: recommendations are that properties have three distinct individual participants, of which one must actively participate in the inspection, yet guidance limits inspection participants to “appropriate property representatives/escorts.
  • Time of Day: a directive not to enter units before 9 am or after 6 pm,
  • Testing Safety Equipment: inspectors are not to carry any type of testing equipment such as GFCI tester, canned smoke, etc (p. 7)
  • Smoking/E-cigarettes: inspectors are specifically prohibited from smoking or using tobacco products including e-cigarettes anywhere on the property (p. 16).
  • Third-party certifications: documentation current within one year from a local authority having jurisdiction or a licensed third-party supporting the testing of a system designed for off-site notification/monitoring (call-for-aid, smoke detector, etc) may be provided (p. 15)

It has also been clarified that, for multifamily properties without an active HUD loan, no market-rate, non-revenue units or any other type units not receiving Section 8 assistance will be included in the unit count (p. 28). Additionally, where there is no active HUD loan, commercial lease spaces are not to be inspected, nor included in the building count unless these are spaces Section 8 residents would otherwise use (p. 4).

The new bulletin adds clarifications for various items reflecting guidance given to inspectors and implemented over the past year. Of particular interest:

  • Building redefined: helpful clarifications on the definition of a “building” include illustrations on how different connective structures may separate components into separate buildings (which is likely to significantly impact scoring in an advantageous manner, by limiting impact of deficiencies to the “building” in which it was found, and spreading out the points over more structures)
  • Walkways/steps: four (4) or more steps/risers without a landing in between must have a handrail; unit v. site steps have been redefined and illustrated (p. 36)
  • Security Devices on Doors/Windows: Sliding glass doors allow use of a stick for secondary, but not primary, securement (pp. 41, 61, 73,80); Use of slide/chain (pp. 38, 78); locking devices on windows over 8 feet from the ground will not be opened, but inspected visually from the ground (pp. 73-74, 91-92)
  • Electrical: Unacceptable repairs to electrical panels have new image and text examples, and zip ties (pp 43-45, 51-53, 64-66), information on resetting tripped breakers (p.82); exterior outlets (p. 45)
  • Call-For-Aid: pull cords now have a specified ‘correct length’ - fully extended to “baseboard” height (p 76); and details on inspection if unit has been removed but components remain
  • Chair-lifts: devices installed on stairs are now to be scored/inspected as elevators (p. 54)
  • Vegetation: anything found to be growing on buildings, such as moss or weeds growing in gutters is now to be cited as "SIte -Overgrown Vegetation"
  • Fire Safety: specific detail is now provided concerning certifications for and/or removal of fire extinguishers (p. 56), fire sprinklers (p. 55) or fire hoses (p. 56)
  • Resident-owned HVAC units are to be inspected and deficiencies recorded (p. 86)
  • Reasonable Accommodations: unplugged stoves may be plugged in by property staff for inspection purposes (p. 70)
  • Health & Safety: Burnt electrical outlets are to be recorded as deficiencies in the appropriate inspectable areas (pp. 45-6, 71, 88)
  • Trip hazards: any observed on a walkway or driveway that are NOT owned by the property, such as a city owned walkway, are now to be recorded as HAZARDS-OTHER, which is way to record and acknowledge the issue but it will remain a non-scoring issue (i.e. Hazards - Other is zero points).

LeadingAge is particularly concerned that definitions concerning the call-for-aid (pull cords) and overgrown vegetation seem to be reverting to former standards resulting in undue citations of deficiency. Since the inception of the REAC inspection protocol, there has never been a specific proximity or height requirement for Call-For-Aid (pull cords), but the definition now clearly requires full extension of the cord to “baseboard” height – no rolling, knotting or moving it up and around obstacles.

As always, should members have difficulties with or need help analyzing/responding to a REAC inspection, please contact us.