Access to the Exigent Health and Safety, EH&S, Reports which are posted on the Secured System, are now available. For additional information please contact the Technical Assistance Center, TAC, at (888) 245-4860.

Facts:   A property subject to UPCS inspection has windows that do not open fully.  The property has modified the functionality of the windows to comply with either a local or state code that prescribes the windows are not to open fully for the safety of the residents.

UPCS EHS deficiency by the Inspector:   In accordance with UPCS protocol, as part of the inspection the inspector will cite the windows as inoperable.  This, in turn, is a blocked egress EHS deficiency. 

Correction/Remedy of EHS deficiency: 

Properties with windows that do not fully open in compliance with local or state law are encouraged to submit a pre Database Adjustment (DBA) request to REAC.   For information on pre-DBAs, including how to submit them, please go to: 

/program_offices/public_indian_housing/reac/products/pass/pass_guideandrule 

Properties that have a REAC approve pre-DBA for this condition who are cited for this EHS deficiency need only contact their field office or program office after receipt of the EHS ticket to advise the office that there is a REAC approved pre-DBA and discuss what if any action is necessary with respect the requirements to correct or remedy the EHS deficiencies.   Because the property has a pre DBA, when the inspection report is issued the windows will not be cited as inoperable nor will the corresponding EHS deficiency for this being a blocked egress be cited.

If a property cited for this EHS deficiency does not have a REAC approved pre DBA for this “condition,” upon receipt of the EHS ticket the POA also must contact its HUD field office or program office to determine what if any action is necessary with respect to the requirements to correct or remedy EHS deficiencies.   In addition, however, for these properties, when the inspection report is issued the inoperable windows will be cited as a deficiency for which points will be deducted and there will be a corresponding EHS deficiency.  In these cases, the property must submit a request for a DBA with all required and appropriate documentation in order for REAC to consider restoring the points and removing the corresponding EHS deficiency from the inspection report.

EHS Reporting Procedures:

	Notice PIH 2006-08 (HA) - This notice extends Notice PIH 2005-4 (HA), same subject, which will expire on January 31, 2006, for another year until January 31, 2007. (Note: The appendices in the original notice have been updated and are provided below for reference).
	Appendix 1 - EHS Deficiency Correction Certification PHA User Instructions - These revised user instructions explain how PHAs are to certify to the correction or abatement of the life-threatening (i.e., EHS) deficiencies observed during inspections.
	Appendix 2 - EHS Deficiency Correction Certification Field Office User Instructions - These revised user instructions explain how PHA Field Office staff record any follow-up activities that they have completed to ensure that EHS deficiencies have been corrected or abated.

For Multifamily Housing Property Owners

Multifamily Housing EHS Reporting Procedures - This form is exclusively for Multifamily Housing property owner use. Property owners should use this form to certify to the correction of the life-threatening (i.e., EHS) deficiencies observed during inspections. Please send or fax a signed copy to your Local Multifamily Housing Field Office until further notice. For additional information regarding EH&S certification, please contact the Technical Assistance Center (TAC) at 1(888) 245-4860.

For Inspectors

Notification of Exigent and  Fire Safety Hazards Observed - This form is exclusively for Inspector use. Inspectors should leave a signed copy of this form with the property representative.