The REAC Inspection and The Confusion Caused by the Written Instructions

Page 312 of HUD’s Dictionary of Deficiency Definitions DCD Version 2.3 gives the following definition of the Blocked/Unusable deficiency:

On page 31 of HUD’s REAC Compilation Bulletin, among a list of bullets under the Heading entitled Unit Doors—Blocked Fire Exits (double Keyed deadbolts), is the following sentence:

Now, before we use our reading abilities to say—because of the title of the heading—that the sentence above applies only to Unit Doors, consider that only one out of five bulleted sentences under that heading refers to “double Keyed deadbolts” and that the following bulleted sentence is also among that list, under that same heading:

So we have—again—instructions from HUD which are unintelligible. An argument can be made that a REAC Inspector must apply the “All blockage” sentence to unit doors only and an argument can be made that a REAC Inspector must not apply the “All blockage” sentence to unit doors only. See also Do Emergency/Fire Exits Rules Apply To Common Area Doors?.

Are Doors Which Cannot Be Unlocked From the Inside Blocked/Unusable?

Except for certain doors which have “double Keyed deadbolts,” there are no written instructions from HUD which specifically say that doors which have locks which are unlockable from the interior are Blocked/Unusable. As in the What are Blocked/Unusable Windows? article here is a list of the specific and the subjective Blocked/Unusable instructions from HUD.

Specifically mentioned Blocked/Unusable doors are doors that

• have a broken lock
• are blocked by debris or storage
• have chained panic hardware
• are unit doors with double-sided keyed knob locks and deadbolts
• are Common Area Doors “on the exit point for a building that contains residential units” and which have double-sided keyed knob locks and deadbolts reference

In HUD’s Dictionary of Deficiency Definitions subjective instructions for Blocked/Unusable doors are given with the words, “or other conditions.” In HUD’s REAC Compilation Bulletin, because of the imprecision of the language, some people apply the following subjective terms to Residential Units doors only, others apply them to to Residential Unit, Common Area, and Exterior doors:

• “all blockage”
• “professional common sense”
• “inspector knowledge”

The row of photos above are examples of door conditions that might fall into the subjective description of this deficiency. These are doors that are the primary doors into a room and that:

• have a hasp and a padlock on its exterior
• have a hasp without a padlock on its exterior
• have an eye-hook latch on its exterior
• when locked require a key for exit
• have a slide bolt lock on its exterior (no photo)
• are blocked Common Area doors

I have written evidence that there is at least one HUD employee who considers the subjective instructions to mean that a bedroom door with a lock that cannot be unlocked from the inside is a Blocked/Unusable deficiency. This evidence is an admonishment I once received, in writing, by a HUD employee for missing an eye-hook latch on the exterior of a bedroom door. On the other hand there is also a recent report of a HUD employee who is not sure whether a bedroom door which cannot be unlocked from the inside is a Blocked/Unusable deficiency. See this page of the the Reacinspectors.Org forum, about 11 posts down.

What to do?

If you’re a property representative preparing for the REAC Inspection know, simply, that there are no properly written instructions. It’s safest to assume that all doors which are blocked by the conditions described in this article are potential deficiencies that will affect your final score.

This article is closely related to the Doors With Double Keyed Locks and Deadbolts article.

Last modified: February 16, 2011