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Mold on a shower curtain
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Gizmo
Inspector


Joined: 10 Sep 2007
Posts: 2201
Location: Virginia and elsewhere

PostPosted: Thu Feb 25, 2010 6:45 pm    Post subject: Mold on a shower curtain Reply with quote

Has anyone been told to write up mold on a shower curtain? I heard a QA told a newbie to do this recently.

Personally, I think this is going a little too far since the shower curtain is not under the mortgage and is disposable.

Your thoughts please.

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Bow Tie
Utility Infielder


Joined: 21 Feb 2009
Posts: 963
Location: Upper Midwest

PostPosted: Thu Feb 25, 2010 7:05 pm    Post subject: Reply with quote

Trash fits both those criteria and we write that up if it is stored improperly.

I'm just sayin'.

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Bernie1603
Dark Inspector


Joined: 12 Nov 2007
Posts: 501
Location: National but NY Based

PostPosted: Thu Feb 25, 2010 7:26 pm    Post subject: the DILEMMA Reply with quote

here is your dilemma and it is very simple,

REAC desires us to use "professional common sense" and they depend on that because it is lacking in thier standard and thier interpretations.

Why does a tree root that has been there for 20 years take of 7 points on the site but a smoke detector takes off none......

there are hundreds of anomolies like this and REAC fails to manup to it.

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Bernard J. Morosco
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Scheistekopf
Inspector


Joined: 09 Sep 2007
Posts: 227

PostPosted: Thu Feb 25, 2010 8:43 pm    Post subject: Reply with quote

Yep, and the infamous missing sprinkler escutcheon is the same as shutting off your sprinkler system! Or paint on said escutcheon!
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CheezHead
Inspector


Joined: 13 Apr 2008
Posts: 1720
Location: California

PostPosted: Fri Feb 26, 2010 12:14 am    Post subject: Reply with quote

Where are you guys getting this "paint on the escutcheon" thing...paint on the sensor or the head I can understand but not the escutcheon!

I don't write up the curtain...but I point it out to the POA's who are always scribbling furiously. Until I'm told otherwise that is.
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Bernie1603
Dark Inspector


Joined: 12 Nov 2007
Posts: 501
Location: National but NY Based

PostPosted: Fri Feb 26, 2010 11:59 am    Post subject: Sprinklers Reply with quote

Page 22 of the CB1
If the escutcheon plate or any other components are missing or damaged, it will be recorded as a deficiency.

the problem is twofold
1. I am a certified sprinkler system inspector in NY State. If you talk to ANYONE in this business, Escutcheon plates are ornamental and are not critical to the actual function of the sprinkler
REAC has argued to me on appeals that.
A. They prevent water damage above the ceiling (like that would be a serious issue if the sprinkler head goes off)
B. They prevent the sprinkler head from moving up in the ceiling (false if the sprinkler system is installed according to NFPA 13 and the code there are support rods every 24 or 36 inches depending on the pipe and pressure size)

2. The statement does not talk about paint but (Damage) I dont consider paint as damage on the e-plate (my professional common sense judgement) and If there is a QA out there who has been certified in sprinkler installation or maintenance they would know that (but they arent)

Just thoughts rambling around in my HAID

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Bernard J. Morosco
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defectL3
Inspector


Joined: 10 Jul 2009
Posts: 134
Location: USA

PostPosted: Fri Feb 26, 2010 7:27 pm    Post subject: Reply with quote

Why do we record deficiencies on sprinkler heads anyway? Shouldn't the sprinkler inspection and certification supercede us? I can see if sprinklers are 'painted over' but any speck of paint anywhere on the head including the threads...18 pt deduction on a single bldg inspection. I write them up but I don't agree with it.
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Gizmo
Inspector


Joined: 10 Sep 2007
Posts: 2201
Location: Virginia and elsewhere

PostPosted: Fri Feb 26, 2010 7:40 pm    Post subject: Reply with quote

From the new Technical Review and Database Adjustment (Appeals) Notice:

Objective and Verifiable Documentation for sprinkler components painted over:

An inspection report, dated on or immediately after the inspection with accompanying photographic evidence, from the Sprinkler Company or fire code official that clearly states the specific painted components (frame, thermal linkage, cap, deflector, or escutcheon) do not affect the effectiveness of the fire suppression system.

Note that the specific parts, including the escutcheon, are listed.

The definition of deficiencies are published in the Federal Register. It would take an act of Congress, literally, to change them.

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CheezHead
Inspector


Joined: 13 Apr 2008
Posts: 1720
Location: California

PostPosted: Fri Feb 26, 2010 11:34 pm    Post subject: Reply with quote

Agree Giz, but why put the property through a needless appeal on paint on an escutcheon...it's ludicrous. Personally, I believe paint does not equal damage and thus I will never record it - there is no harm in paint being on an escutcheon as there are obviously no moving parts and, as Bernie stated, it's (in 99% of cases) a cosmetic plate.
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Gizmo
Inspector


Joined: 10 Sep 2007
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Location: Virginia and elsewhere

PostPosted: Sat Feb 27, 2010 8:15 am    Post subject: Reply with quote

I don't disagree, Cheezhead. There are some things that I prefer not to write because I don't agree with the deficiency---but we don't have that option--to agree or disagree.

And, in today's world, we are all fortunate to be able to put food on the table. I want to keep that food coming my way!!

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Bernie1603
Dark Inspector


Joined: 12 Nov 2007
Posts: 501
Location: National but NY Based

PostPosted: Sat Feb 27, 2010 5:51 pm    Post subject: Hey Reply with quote

as a REAC inspector you should not utilize the technical review database adjustment as a guide to inspect, the problem is quite clear here. As an inspector, REAC holds your certification over your head to follow whatever they say irregardless of if its in a regulation or not.

Most Properties do not have the skillset or knowledge to effectively fight what is not backed in regulation (FACT: if its not in regulation HUD can not penalize you for it) I have one client who will and has taken HUD to court on issues like this for example

A missing door in a unit, is it worth points?
according to regulation it has a critical value of ZERO
what happens when you multiply anything by ZERO.

REAC in an initial appeal actually stated that this was an error or typo in the regulation but according to CFR if its there it has to be enforced unless corrected in a later regulation which REAC has not done.

REAC when threatened with litigation on something that is enforced but NOT in regulation has at least in my experience ALWAYS backed down and restored the points.

Now you may ask is this worth it and that is the question for the PHA/Property....sue for a half point, no.....

Also for those interested there is NO REGULATORY Authorization issued by HUD for the allowance of an LQA yet they do it.

This is a complicated issue but

REAC inspectors should be following ONLY They Dictionary of Definitions and the Compilation Bulletin (even though that makes changes to the regulation illegally), other protocol bulletins (same issue) and Professional Common Sense, all other documents like the Technical Review Guide are not meant for you and using them is in my opinion prejudicial.

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Bernard J. Morosco
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Gizmo
Inspector


Joined: 10 Sep 2007
Posts: 2201
Location: Virginia and elsewhere

PostPosted: Sat Feb 27, 2010 6:52 pm    Post subject: Reply with quote

Bernie - I respect your opinion. And, yes, we need to follow the Dictionary of Definitions, the Comp Bulletin, and professional common sense.

However, I am of the opinion that the more people know, the more they understand, and the better they do in the future.

Just because I know other HUD regulations, policies, and procedures, this doesn't make me less of an inspector--it allows me to use more "professional common sense" because I understand the "bigger" picture.
It is not "prejudicial" to understand how all of this fits together--it is helpful.

In my 40 years in this business, I have just about seen it all. There is a need for the consultant---and there is a need for the REAC inspector--and there is a need for HUD in this process.

What most REAC inspectors do not realize is that their work is scrutinized and analyzed not only by REAC, and not only by the Owner and the Managing Agent, but also by the HUD Contract Administrator, the HUD Field Office, and, in some cases, by the HUD Regional Office and by HUD Headquarters. Some are reviewed by the Office of Inspector General and some are reviewed by the people in charge of the Previous Participation Certification, which is required for Owners and Managing Agents, and some are reviewed by the HUD attorneys.

When a QA visits with a REAC inspector, the QA has reviewed an analysis of the inspector's work. Have you ever wondered how they know where you need training, or where you have been confused, or where you haven't been writing deficiencies?

Have you ever wondered why a QA will show up at a property with multiple EHS deficiencies on the third day?

What a REAC inspector does, or does not do, has far reaching implications.

And now I will plug the need for a consultant--because what we do as inspectors have far reaching implications.

Those who don't take a REAC inspection, and the resulting score, seriously don't understand the process, nor do they understand the "bigger" picture.

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Bernie1603
Dark Inspector


Joined: 12 Nov 2007
Posts: 501
Location: National but NY Based

PostPosted: Sun Feb 28, 2010 10:27 am    Post subject: REAC and the Inspector Reply with quote

40 years? your giving your age away. (LOL) Actually you make sense but one question.

HUD has been around since 1968, from 1968 - 1998 thirty years there was no REAC or REAC inspector and Public and Assisted Housing survived and functioned.

With the advent of REAC and its 4,000 plus pages of appropriate regulation the Government has taken a one page inspection and turned it into a complete industry. I havent been in housing as long as you, I started when Jack Kemp was HUD Secretary back in 1984 but what I believe to be clear is when the Gumint gets involved to "simplify" things the opposite usually happens......

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Bernard J. Morosco
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Scheistekopf
Inspector


Joined: 09 Sep 2007
Posts: 227

PostPosted: Sun Feb 28, 2010 7:56 pm    Post subject: Reply with quote

I have been told by several QA's about the escutcheons/paint and I can't believe they haven't hammered everyone at some point.
As far as the escutcheon's function, according to UL, they are a component of the sprinkler system. I actually called them to find out.
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Gizmo
Inspector


Joined: 10 Sep 2007
Posts: 2201
Location: Virginia and elsewhere

PostPosted: Mon Mar 01, 2010 8:06 pm    Post subject: Reply with quote

I agree - when I started in this business, the ENTIRE handbook for affordable housing was less than 1 inch thick. The Gumint adds--but the Gumnit does not take away. Nothing is simple any more--wish it were!!
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