HUD Will Enforce Carbon Monoxide Alarm/Detector Installation in HUD-Assisted Housing

HUD issued joint Notice PIH 2022-01/H 2022-01/OLHCHH 2022-01 clarifying that it will enforce the requirement that HUD-assisted properties install carbon monoxide (CO) alarms or detectors by December 27, 2022, as required by the “Appropriations Act of 2021.” The requirement applies 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.

The source of the requirement is Section 101, “Carbon Monoxide Alarms or Detectors in Federally Insured Housing,” of Title I of Division Q of the “Consolidated Appropriations Act of 2021.” The act requires CO alarms or detectors to be installed in each dwelling unit receiving HCV or PBV assistance or that is owned or operated by a public housing agency (PHA) or by an owner of a dwelling unit receiving project-based rental assistance. The CO alarms or detectors must meet or exceed the standards described in Chapters 9 and 11 of the 2018 International Fire Code (IFC).

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 to have working CO detectors where required by state or local law, code, or other regulation (see Memo, 4/22/19).

CO 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 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.

PHAs operating public housing units may use either their Operating Funds or Capital Funds to purchase, install, and maintain CO alarms or detectors. In addition, the act provided a set-aside in the Capital Fund Program that PHAs can compete for to secure additional funds for CO alarms or detectors. In the HCV and PBV programs, property owners or landlords are responsible for the cost of CO alarms or detectors. In addition, PHAs may use their HCV administration funds for landlord outreach and education about these requirements. Owners of properties receiving assistance through PBRA, Section 202, and/or Section 811 may use a property’s reserve or replacement account, residual receipts, general operating reserves, owner contributions, or secondary financing to fund the purchase, installation, and maintenance of CO alarms and detectors.

The joint notice explains the difference between CO alarms and detectors and provides examples of sources of CO that can be found in homes, as well as examples of ways to prevent CO intrusion.

The act directs HUD to provide guidance to PHAs regarding methods for educating tenants about health hazards in the home, including CO poisoning, lead poisoning, asthma induced by housing-related allergens, and other housing-related preventable outcomes. HUD’s Office of Public and Indian Housing (PIH) will develop additional materials for residents, and HUD will develop CO materials for property managers to support their educational activities.

Read notice PIH 2022-01/H 2022-01/OLHCHH 2022-01 at

Find more information about HCVs on page 4-1 of NLIHC’s 2021 Advocates’ Guide.

Find more information about public housing on page 4-30 of NLIHC’s 2021 Advocates’ Guide.

Find more information about PBRA on page 4-64 of NLIHC’s 2021 Advocates’ Guide.

Find more information about Section 202 on page 4-70 of NLIHC’s 2021 Advocates’ Guide.

Find more information about Section 811 on page 4-74 of NLIHC’s 2021 Advocates’ Guide.