Door Locks: Not Required vs. Missing

From the Doors Series of Articles

Consider the following paragraph from page 26 of HUD’s REAC Compilation Bulletin

Locks are not required on doors, but if a lock was installed it must be inspected to ensure that it functions as designed with three exceptions: (1) Common Area interior doors (not unit entry) may have missing locks; (2) 504 units may have missing locks; and (3) Public Housing bedroom doors may have missing or damaged locks.” [Emphasis added]

I don’t understand the exceptions. I don’t understand the difference between doors for which locks “are not required” and doors which “have missing locks.”

I’ve tried to approach it this way: the difference lies in the distinction between a door that never had a lock and a door for which a “lock was installed” some time in its past. How can a REAC Inspector tell that a door use to have a lock? I’ve thought of two ways:

  1. there are holes or other evidence on the door where there used to be a lock
  2. part of the lock is missing

In the 1st case, again, how are doors with “missing locks” different than doors for which “locks are not required”? If a property decided to remove a lock then there is no longer a lock and “locks are not required”—anywhere—so why the the exceptions?

door with a partially removed lock

Is it the 2nd case? Perhaps HUD is saying that partially removed lock hardware (photo right) should not be considered a deficiency in the case of the three exceptions.

Maybe I should be focused on the part of the instructions which say “if a lock was installed it must be inspected to ensure that it functions as designed with three exceptions:” In other words, do not inspect to ensure that a lock functions as designed when a lock is on the following types of doors:

  • Common Area interior doors
  • 504 unit doors
  • Public Housing bedroom doors

In that case the “have missing locks” phrases are superfluous and add needless confusion. Honestly, sometimes this stuff is harder to figure out than the implications of time travel.

An explanation to come?

I doubt it. I e-mailed HUD about this question twice in April 2008, and have not, as of the day you’re reading this, received a reply.

How Missing/Damaged Lock Hardware is Recorded

A missing or damaged lock is recorded in the Doors: Damaged Hardware section of the inspection software. If we consider the exceptions noted above the level of deficiency depends upon upon what kind of door has the damaged or missing lock.

For a residential unit it is

  • Level 1: A closet door
  • Level 2: Any door that isn’t a closet, bathroom, entry, Public Housing bedroom or, a 504 unit door
  • Level 3: An entry or a bathroom door that is not in a 504 unit

For a Common Area or an Exterior Doors it is

  • Level 1: A closet door
  • Level 2: n/a
  • Level 3: A restroom, entry, or fire door reference

Page144 and 233 of HUD’s REAC Compilation Bulletin

From "Public Housing Assessment System Physical Condition Scoring Process Interim Scoring, Corrections and Republication, Notice." Federal Register 66 (26 November 2001): 59085.

“ . . . one of three levels that reflect the extent of damage associated with each deficiency . . . ”
and
“Based on the severity of each deficiency, the score is reduced.”

[From the author of this website: A property will lose more points with a Level 3 deficiency than a Level 1 deficiency but there are other mathematical factors which determine a deficiency’s point reduction.]

From HUD’s website

“The Physical Inspection Data Collection Device (DCD) software is used by inspectors to record and submit conditions of HUD properties into a centralized database.”

This term refers to a HUD program. It is explained on HUD’s
Public Housing Program page of its website.

504 units are designed for residents with special requirements. For example, a resident who uses a wheelchair. More information can be found on HUD’s Section 504 Frequently Asked Questions page of its website.

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 …  ”

Last modified: February 4, 2011

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This website uses standard rules of American English to examine what the written instructions from HUD actually say or don’t say about the rules of the REAC Inspection. This website is not about what should be in the UPCS Protocol. That is a separate cause for other advocates. This website is also not about what the writers of the UPCS Protocol and guidance meant to say, or what any particular HUD employee or HUD contractor told you.

I advocate clear writing and argue that unless the written instructions are made understandable they will never be uniformly and objectively applied and there will never be replicable, reasonable REAC Inspections.

In the article at left, mouse over for additional information and references

In the article at left, mouse over for additional information and references

In the article at left, mouse over for additional information and references