REAC inspectors have unambiguous instructions from HUD to inspect “All flat roofs that have a permanent means of access. . .” These instructions are on page 22 of the 5/25/2011 Compilation Bulletin, goes on to say, “A stairway leading to a roof, a ladder permanently affixed to a wall, or any other apparatus that does not require the use of a portable ladder is considered a permanent means of access.” And then finishes with, “An inspector is not required to access the roof when a permanent means of access is not available.”
A permanently affixed ladder. REAC inspectors are instructed to climb this ladder and inspect the roof
If the access to the roof is a ladder affixed to a wall, you could temporarily remove that ladder for the duration of the REAC inspection. You don’t have to explain it. The ladder’s simply not there. The REAC inspector will be happy to move on because “An inspector is not required to access the roof when a permanent means of access is not available.” Contact your local municipal inspector before you temporarily remove roof access to make sure that it’s allowed in your building.
If the roof is not perfectly flat, cite the Compilation Bulletin (“All flat roofs that have a permanent means of access. . .”) and mention your liability insurance, the inspector’s safety, staff safety, OSHA, and point out that there is not an OSHA approved roof harness available. If the REAC inspector insists and this is important to you, politely suggest that you all go to the office to sort the matter out with HUD, the building owner, the local fire department, OSHA, and your insurance company.
Keep in mind that generally, if you’ve got a flat roof and a permanent means of access, your roof is going to be inspected.
It could be easy to let your guard down if you witnessed your last two REAC inspectors passing the roof access without a word. That happens more often than HUD knows. No two REAC inspectors are alike and it could be costly to assume that your next REAC inspector will likewise ignore the roof access.
Don’t forget to pre-inspect roofs on top of roofs
A lot of high scoring losses can happen on a flat roof: unsecured electric boxes, damaged flashing, damaged membranes, unevenly distributed ballast, ponding, evidence of ponding (efflorescence), missing drain baskets or clogged drains, inoperable exhaust fans, damaged chimneys, and more. Get yourself up there before the REAC inspection and remember to pre-inspect the roofs on top of roofs, no matter how troublesome they are to reach. According to the instructions, they are also inspectable.