Carbon Monoxide Detector and Alarm Requirement Takes Effect

HUD has issued reminders that, as of December 27, 2022, all HUD-assisted units must have carbon monoxide (CO) detectors or alarms installed. The reminders were sent to owners and operators of HUD-assisted Multifamily projects and to public housing agency (PHA) executive directors. In addition, on December 8, HUD’s Office of Community Planning and Development (CPD) issued Notice CPD-22-15 informing Housing Opportunities for Persons With AIDS (HOPWA) grantees of their obligation to install CO devices in every assisted unit. The “Appropriations Act of 2021” is the source of the requirement.

On January 31, 2022, three offices of HUD issued joint Notice PIH 2022-01/H 2022-01/OLHCHH 2022-01, clarifying that the department will enforce the requirement that HUD-assisted properties install CO alarms or detectors by December 27, 2022 (see Memo, 2/7/22). That Notice applied to all Public Housing, Housing Choice Voucher (HCV), Project-Based Voucher (PBV), Project-Based Rental Assistance (PBRA), Section 202 Supportive Housing for the Elderly (Section 202), and Section 811 Supportive Housing for Persons with Disabilities (Section 811) properties. Notice CPD-22-15 adds HOPWA-assisted housing to the list. The CO alarms or detectors must meet or exceed the standards described in Chapters 9 and 11 of the 2018 International Fire Code (IFC).

The new CPD HOPWA Notice differs slightly from the January 31, 2022, joint Notice by providing one set of guidance for housing activities subject to HOPWA Housing Quality Standards (HQS) and another set of guidance for housing activities not subject to HQS requirements (including short-term rent, utility payments, and mortgages (STRUM)).

Previously, HUD issued joint notice PIH Notice 2019-06/H 2019-05/Office of Lead Hazard Control and Healthy Homes (OLHCHH) Notice 2019-01 reminding owners and operators of public housing, HCV, PBV, PBRA, Section 202, and Section 811 properties of their obligation to install working CO detectors where required by state or local law, code, or other regulation (see Memo, 4/22/19).

Carbon monoxide is an odorless, colorless, non-visible, toxic gas produced by incomplete combustion of fuel burned in stoves, lanterns, grills, fireplaces, gas ranges, or furnaces, as well as in vehicles and small engines. CO can build up indoors, poisoning people and animals. The effects of CO exposure can vary from person to person depending on age, overall health, and the concentration and length of exposure. Exposure can cause permanent brain damage, life-threatening cardiac complications, fetal death or miscarriage, and death in a matter of minutes. People who are asleep or intoxicated can die from CO poisoning before experiencing any symptoms.

The Notices explain the difference between CO alarms and detectors and provide examples of sources of CO that can be found in homes and of activities to prevent CO intrusion.

An email sent by HUD’s Office of Multifamily Housing Programs includes a link to a helpful “decision tree” to help owners place devices, as well as a link to help owners purchase devices through Lowe’s.

Read Notice CPD-22-15 at:

Read Notice PIH 2022-01/H 2022-01/OLHCHH 2022-01 at: