REAC Flash News Report
October 2, 2020
 REAC issues unsafe inspection guidance
under COVID to its REAC inspectors

REAC is starting up REAC inspections as promised, and against the advice and counsel of industry leaders.  How it will conduct the inspections during the pandemic is outlined in a newly released Inspector Notice 2020-01.  It describes inspection protocols for REAC inspectors during the virus pandemic. The Notice is addressed to Inspectors only, yet also contains requirements for property owners. This Notice provides complicated and unclear guidance for conducting REAC inspections. Note further down what it says about stopping an inspection.

REAC inspectors must be tested for the virus no more than 30 days prior to an inspection. Inspectors have to carry proof of a negative test result. Property reps should ask for the proof of testing before allowing an Inspector onto your property.  This is important because REAC inspectors are only required to be tested within 30 days prior to an inspection (Section 4.0). 

That is compared to most businesses and the other Government agencies that require more frequent testing. A person can catch the virus within 24 hours of being tested. Thirty days is an eternity by comparison. President trump and the first lady have contracted the virus and tested every day, not once in a month!

Plus, REAC will not pay for its inspectors virus tests which can cost up to $200, which inspectors are complaining about. So expect inspectors to avoid testing due to costs. Without inspectors REAC has no inspection program, so it would seem paying for the tests would be a no brainer.

Inspectors will be required to wear personal protective equipment (PPE) (e.g., mask and gloves) throughout the inspection process. A couple days before the Notice in a REAC conference with its inspectors REAC said something different. So the PPE policy is unclear to inspectors.
Owner/agents, can have the REAC Inspector submit to a temperature check each day of the inspection (Section 2.3). Probably a good idea that POAs have thermometers readily available.  However, temperature checks not a sure sign of virus absence.

Within 14 days and again within 2 days of the inspection REAC inspectors are required to reconfirm with the property that there are no known cases of the virus. If there are cases then the inspection can be canceled (Section 1.2.1).

Important to know: Per Section 1.3.1 inspections CANNOT go forward in an area of the country that is other than green on the RSHM Heat Map, even after the 14 day notification has been issued. Green can change in a heartbeat to red. Keep a close eye on the Heat Map.

REAC is requiring properties to wear a mask, even though it has no legal authority to do so. “Section 2.4 All POA participants on the inspection are required to wear the minimum recommended PPE throughout the duration of inspection process, in accordance with local and state directives. When there are no state or local requirements, the POA is required to wear a mask and gloves. If the POA or any other participant refuses to wear the minimum required PPE, CI [inspector] shall inform the participants of the following: 2.4.1 Refusal to wear PPE is grounds for stopping the inspection and uploading it as unsuccessful. 2.4.2 If there is still a refusal to wear the PPE CI shall stop the inspection, notify TAC, record the TAC reference number, notify their Contractor, and upload the inspection as unsuccessful.”

The consequence for not abiding REAC’s arbitrary rule is an unsuccessful inspection. If the property does not want to wear PPE per REAC’s Notice, then REAC will simply have to conduct its inspections after the pandemic has been declared ended by the Government.  REAC would rather put lives at risk and hurry up inspections again.  Seems odd since REAC’s mission is one of keeping residents safe.

REAC is forcing properties to submit to inspections during a pandemic and has promulgated guidelines that will put peoples lives at risk with unsafe inspection protocols. Thirty days or even 15 day testing intervals is not a safe virus containment practice, just as is requiring inspectors to enter bed bug units thus spreading bed bugs around the building and not testing Carbon Monoxide detectors are proven unsafe practices, practices REAC ignores wholly or in part.

REAC staff are working from the comfort of their homes while they force contract (non-employee) inspectors who need the work to risk their life and that of residents whose apartments they inspect. Easy for REAC to have non-employees do their dirty work.

If you have questions about REAC’s Notice, REAC says to contact the Technical Assistance Center (TAC) at 1-888-245-4860 or via email (REAC_TAC@hud.gov). The Notices author can also be contacted at james.e.cunningham@hud.gov, or his boss at dave.vargas@hud.gov.  

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