Leased Spaces – What is a Common Area?
From the Day of the Inspection Series of Articles
All the spaces within your property that are used or leased by other organizations are considered “Common Areas” and are therefore supposed to be inspected by the REAC inspector. These spaces include:
- occupied retail spaces (photo right)
- unleased retail spaces
- offices
- municipal offices (i.e. police departments)
- nurse’s stations
- day care centers, senior care centers
- medical offices, etc. reference
Common Areas are also
- rooms, closets and spaces you “never use”
- rooms, closets and spaces “no one ever enters”
- rooms, closets and spaces “no other REAC inspector ever asked to enter”
REAC Inspectors are taught that property representatives are required to provide access to every Common Area space on the property. reference
HUD Definition of a Common Area is
any interior area on the property that is not in a residential unit. reference
Including
- storage closets, janitor’s closets, slop sink closets
- garages
- mechanical rooms
- storage rooms
- offices
- locker rooms
- locked Tenant Association closets and rooms
- the superintendent’s office
- areas that are only accessible from exterior doors
- dark dank rooms in the basement
Consequences
Be prepared to have all areas of your property inspected. Pay particular attention to high scoring items in areas that no one ever enters or that are not under your control. A high scoring deficiency like a leaky sewage pipe, an expired fire extinguisher, or a painted sprinkler head in an area that you thought wouldn’t be inspected can make an impressive dent in your final score.
The following entries are from HUD’s REAC Compilation Bulletin
Page 25
“The property representative must provide access to all building common space … within each building.”
Page 4
“Commercial or leased space must be inspected and the deficiencies observed recorded in the appropriate Common Areas.”
Page 1 of HUD’s document “Preparing for REAC Inspections”.
“ … all areas within a building that are not residential units are considered Common Areas for the REAC inspection and you will need to provide access to each of these areas.”
Page 1 of a HUD document entitled “Inspector Helpful Hints, January 18, 2008.” This document is distributed to new inspectors during their training.
“Make Site Representative aware that all Common Areas are to be made accessible for inspection. YOU MUST SEE BEHIND ALL DOORS — NO EXCEPTIONS”
[The emphasis created by the capital letters was NOT added. It is original to the document.]
Last modified: February 7, 2011
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