The Housing Opportunity Through Modernization Act (HOTMA) has brought numerous updates and changes to the Housing Choice Voucher (HCV) and Project-Based Voucher (PBV) programs, particularly regarding life-threatening conditions that directly impact the safety and security of residents. One such update, under the new NSPIRE protocols, pertains to the integrity of fire-rated doors in residential units. These fire-rated doors are essential safety features designed to prevent the spread of fire and smoke, and they play a critical role in ensuring tenant safety. However, new standards have made compliance more challenging, as even minor alterations to these doors can now result in significant inspection penalties.
Deficiency 3: Fire-Rated Doors Under NSPIRE
Under the NSPIRE protocols, specific criteria have been established for fire-rated door assemblies. One of the key deficiencies cited under this standard is DOOR – FIRE LABELED D3, which outlines the conditions under which a fire-rated door assembly is considered deficient.
According to Deficiency 3 – Unit, a fire-rated door assembly can be cited for two primary reasons:
- The door has a hole of any size.
- The door is damaged in such a way that its integrity or functionality may be compromised.
This means that even minor damage, such as scratches, small holes, or other surface defects, could potentially result in a life-threatening condition under NSPIRE standards. The rationale behind this is that even the smallest compromise in the door’s structure could impact its ability to withstand heat or prevent the spread of flames in the event of a fire.
Why Fire-Rated Doors Matter
Fire-rated doors are specifically designed to slow or prevent the spread of fire from one section of a building to another, protecting both residents and property. These doors are rated based on how long they can resist fire, typically measured in increments such as 20, 45, 60, or 90 minutes. The integrity of these doors is critical to the safety of residents, especially in multifamily housing or units within large buildings where fires can spread quickly.
However, under the updated NSPIRE standards, any alterations to a fire-rated door can result in significant scoring deductions during a REAC inspection, making it crucial for property owners to understand the new guidelines and ensure compliance.
Field Alterations and HUD Requirements
One of the key concerns raised by many Public Housing Authorities (PHAs) and Property Owners/Agents (POAs) is related to field alterations on fire-rated doors. According to HUD, any alterations or repairs made to a fire-rated door in the field (such as adding door numbers, installing kick plates, or making minor repairs) require official documentation from the door manufacturer that the changes will not compromise the fire rating of the door.
This includes:
- Screws or fasteners used to affix door numbers.
- Kick plates installed at the base of the door.
- Any modifications to the door’s structure or appearance.
Without proper documentation from the manufacturer, these alterations may be cited as a defect during an inspection. Moreover, this is not just limited to large structural changes. Even small screws or minor adjustments can potentially compromise the door’s fire rating, and NSPIRE inspectors may cite this deficiency if they believe the alterations have impacted the door’s integrity.
The Impact of Defects on NSPIRE Scoring
Under NSPIRE, the penalties for fire-rated door deficiencies can be significant. In many cases, fire-rated doors are installed at the entry of every unit, which means that a defect found on multiple doors could result in a substantial point deduction.
For instance, if an inspector cites the same defect (such as an unapproved alteration or hole in the door) for multiple unit entry doors, this could lead to a deduction of nearly 15 points. Since NSPIRE inspections are now unit-focused, these point deductions can quickly add up, especially if you lose more than 30 points in the unit category. Losing 30 points in the units would result in a failed inspection, which has serious ramifications for property owners and agents.
If you cannot provide documentation from the manufacturer proving that your alterations to the fire-rated doors are compliant, there is little chance of successfully appealing these citations.
Preventing Deficiencies and Ensuring Compliance
Given the severe penalties for fire-rated door deficiencies under NSPIRE, it’s crucial for property owners and managers to take proactive steps to ensure compliance. Here are some recommendations for maintaining fire-rated doors and avoiding citations:
- Avoid Unauthorized Alterations: Before making any alterations to a fire-rated door, consult with the manufacturer to ensure that the changes won’t impact the door’s fire rating. Obtain written documentation confirming that the modifications are compliant with fire safety standards.
- Regular Inspections: Conduct routine inspections of all fire-rated doors to identify any damage, holes, or unauthorized alterations. Address any deficiencies promptly to prevent them from being cited during an official NSPIRE inspection.
- Pre-NSPIRE Inspections: Consider scheduling pre-NSPIRE inspections with professionals to identify potential issues before the official inspection. This proactive approach can help you address concerns early and avoid penalties.
- Training for Maintenance Staff: Ensure that your maintenance staff is trained in the proper handling and repair of fire-rated doors. They should be familiar with HUD’s requirements and know how to document any alterations or repairs made in the field.
Questions?
The new NSPIRE standards have brought about significant changes for property owners and agents, particularly regarding the handling of fire-rated doors. Even minor alterations can now result in substantial penalties, making it essential for property owners to understand the requirements and take proactive steps to ensure compliance.
The Inspection Group is here to help you navigate the complexities of NSPIRE and ensure that your properties are always inspection-ready. From pre-inspection assessments to NSPIRE training classes, our team of experts can provide the guidance and support you need to maintain compliance and achieve high scores during REAC inspections. Contact us today to learn more about our services and how we can help you stay ahead of the curve in the changing landscape of HUD inspections.
