HUD has released a document titled “UPCS Guidance & Protocol Clarification.” This guidance was effective on May 23, 2016, and changes some of the prior guidance inspectors followed during REAC inspections. Primary changes/clarifications are as follows:
- HUD has clarified that vegetation touching a fence but not causing damage is not a violation. However, since changes to protocol issues published in the Federal Register need to be revised through regulatory changes, this guidance applies only to fences in land areas that are not in active use. Owners and managers should still consider vegetation contact with fences in primary residential areas as being a level 2 violation.
- If the exterior cover plate for a clothes dryer is missing or damaged, it will be considered a penetration and reported as a hole in the building’s exterior and will be a level 2 finding.
- When an inspector chooses to test a zip tie used to secure electrical boxes, if the tie breaks and wires are exposed, it is a defect; if no wires are exposed it is not a defect.
- When testing Self-Latching doors, inspectors are to make only two attempts to confirm that the door closes – no more and no less. If the door does not close on the first attempt, it should be opened at a different angle for the second attempt. The resident/owner/manager may not open a window to assist the door closing. The door needs to operate whether or not a window is open.
- A missing strike plate is a deficiency even if a door operates.
- Caulking on a breaker or fuse panel is now considered a Health & Safety hazard. No foreign material – including caulk – may be used to repair an electrical panel. When there is an opening in an electrical panel, repairs must be made using materials specifically designed for such repairs.
- Overgrown weeds and grass in an area that is not in use is not a defect.
- Stains on exterior walls that are painted are a defect; stains on non-painted exterior walls (vinyl, brick, aluminum, etc.) are not a defect.
- Handicap chair lifts or stair lifts are considered elevators and must operate in the manner intended by the manufacturer. Property staff may demonstrate operability.
- If a showerhead in a unit leaks when turned on (even if it does not leak when turned off) it is a defect.
- Level 1 if contained and level 3 if not contained.