REAC Compilation Bulletin 4.0

Documentation of REAC inspection policy clarifications and changes has slowly broken down over the last several years to the point that it was housed in several different documents that had differing authors and formats.  These also contained statements that could be read as contradicting each other in some cases.  The primary clarification document was Compilation Bulletin 4.0 version 2, but there were several other supporting documents published at random intervals.

The two most distressing problems in this were that:

1) The overly vague and broad “non-industry standard repairs” (NIS) memo seemed to throw out all the rules and leave defect definitions to the imagination of the inspector.

2) The real definitions used by our REAC inspectors are actually contained in the decision trees embedded in the RAPID 4.0 software. These have never been published in any printable, distributable document.  Even if one was familiar with all the various policy documents, one did not have easy access to the decision trees. The only way to access them was by installing the public version of the software on their computer and referring to the decision trees there.

Finally, REAC has published Compilation Bulletin 4.0, version 3. It is supposed to draw together the still useful content of all previous documents and to supersede them with some new interpretations of policy and new answers to old questions.  This document is available in two versions, which are identical except that one version has added highlighting.

The NIS policy that became effective in August 2016 is still with us.  It appears at the bottom of page 4, continuing to page 5 in a newly abbreviated, but still vague-as-ever form.  REAC scores have dropped across the board in both the multi-family and public housing segments of the housing industry since this policy went into effect, allowing inspectors to cite defects for any repair that the inspector thinks “doesn’t look right” and requiring the inspector in some cases to enter false data into the inspection report to override the decision trees.

One of the most interesting changes is that REAC has changed how inspectors determine when two buildings that touch each other are to be considered either one building or two buildings.  Prior to this bulletin, almost any contact like overlapping corners or a small connecting walkway between two buildings resulted in them being considered a single building.  This placed a higher scoring deduction value on all building level defects.  REAC is finally saying that two apparently different buildings that are connected by a section containing only common areas are to be considered two separate buildings.

blog pic 10.4.17

A second significant change for the better is that stairs leading up to the common porch or entry of a building will now be considered part of that building’s Common Areas instead of part of the Site.  A loose handrail at these stairs might be worth 5 or 6 points when cited at the Site level.  When cited as a Common Areas defect the scoring value would be much lower, and much more fair.

Housing providers will find other changes confounding and frustrating.  Examples:

  • Moss on roofing shingles or small plants in gutters will now be cited as Site; Grounds; Overgrown/Penetrating Vegetation.
  • Broken privacy chain locks on doors will now officially be cited as Door; Damaged Hardware; Level 3 even though the door is lockable and has both an operable deadbolt and knob lock.  (The legal L3 definitions says “the door cannot be locked.”)
  • Repairs to any electrical device using any kind of non-manufacturer’s parts or materials – such as a metal patch pop-riveted in place – will be considered an electrical hazard, always a high scoring defect.  Appeals for this defect have become nearly impossible, with REAC expecting us to prove that local code specifically allows the use of such methods, as opposed to simply proving that local code does not expressly prohibit it.

This new Compilation Bulletin 4.0 version 3 is 95 pages long, so it is impossible to summarize it fully here.  We have placed copies online for easy download at https://reacguru.com/cb43

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