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Carbon Monoxide Alarms/Detectors

Subject: Carbon Monoxide Alarms or Detectors in US Housing and Urban Development (HUD)-Assisted Housing

  1. Purpose

    Public housing agencies and authorities (PHAs), and Owners of properties that receive federal rental assistance have an important role in preventing potential loss of life and severe injury associated with carbon monoxide (CO) in housing they own or manage. This notice reminds PHAs and Owners of CO poisoning risks in housing, identifies resources for preventing and detecting CO exposure, and provides notice of Section 101, "Carbon Monoxide Alarms or Detectors in Federally Insured Housing" of Title I of Division Q, Financial Services Provisions and Intellectual Property, of the Consolidated Appropriations Act, 2021, Pub L. No 116-260, 134 Stat. 2162 (2020) ("the Act"), which requires CO alarms or detectors to be installed in certain HUD-assisted housing within two years of enactment.

    This notice clarifies that HUD will enforce the requirements instituted by Congress requiring that all Public Housing (PH), Housing Choice Vouchers (HCV), Project-Based Vouchers (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) comply with the International Fire Code (IFC) 2018 standards on the installation of CO alarms or detectors by December 27, 2022. For the full 2018 IFC Code, as well as Chapter 9 and Chapter 11 regarding CO alarms or detectors, please visit:
    • 2018 Intl Fire Code
    • Chapter 9: Fire Protection and Life Safety Systems
    • Chapter 11: Construction Requirements for Existing Buildings.

      PIH Notice 2019-06, HN 2019-05, and Office of Lead Hazard Control and Healthy Homes (OLHCHH) Notice 2019-01 reminded Owners and operators of PH, PBRA, HCV, PBV, and Section 202/811 properties to have operational CO detectors, where specified, as required by the state or local law, code, or other regulation.

      This notice remains in effect until amended, superseded, or rescinded.

      Additionally, this notice identifies resources for the types of devices to install, ideal placement, maintenance, and monitoring; and is applicable to housing with fuel-fired/burning appliance(s) or an attached garage.

  2. Definitions

    Carbon Monoxide Alarm: A single or multiple-station alarm intended to detect carbon monoxide gas and alert occupants by a distinct audible signal. It incorporates a sensor, control components, and an alarm notification appliance in a single unit.

    Carbon Monoxide Detector: A device with an integral sensor to detect carbon monoxide gas and transmit an alarm signal to a connected alarm control unit.

  3. Background

    The Act requires the installation of CO alarms or detectors in certain Federally Assisted Housing by December 27, 2022. The Act CO alarms or detectors be installed in each dwelling unit(s) receiving tenant-based or requires project-based assistance or is owned or operated by a PHA or by the owner of a dwelling unit receiving project-based assistance in a manner that meets or exceeds the standards described in Chapters 9 and 11 of the 2018 publication of the International Fire Code (IFC), as published by the International Code Council (ICC).

    This notice is being issued to provide notice that the Secretary of Housing and Urban Development will, consistent with the Act, enforce standards relating to CO alarms and detectors and in support of decent, safe, and habitable housing in HUD's low-income housing assistance programs.

    HUD recognizes CO poisoning as an important safety issue for families in assisted housing. According to the National Center for Environmental Health, "each year more than 400 Americans die from unintentional CO poisoning not linked to fires, more than 20,000 visit the emergency room, and more than 4,000 are hospitalized."

    CO is an odorless, colorless, and toxic gas. It is impossible to see, and is a tasteless gas produced by incomplete combustion of fuel burned in vehicles, small engines, stoves, lanterns, grills, fireplaces, gas ranges, or furnaces. It can build up indoors and poison people and animals who breathe the toxic fumes. 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 harmful health conditions, permanent brain damage, life-threatening cardiac complications, fetal death or miscarriage, and death in a matter of minutes. Individuals who are asleep or intoxicated may die from CO poisoning before experiencing any symptoms.

  4. Requirement to Install Detectors and Alarms

    The ICC publishes the IFC and periodically updates it. Among other standards, the IFC establishes minimum requirements for CO alarms or detectors in jurisdictions that adopt the IFC into its codes or laws, except for properties where the International Residential Code (IRC) applies. In its administration section, the 2018 IFC notes the model code provisions do not apply to properties covered under the 2018 IRC (Single Family Housing, Duplexes and Townhomes) with some limited exceptions.

    HUD encourages PHAs and Owners to adopt standards at or above the standards of the 2018 International Fire Code (IFC) as soon as possible for the health and safety of residents. PHAs and Owners are on notice that these requirements will be enforced by HUD after the effective date of December 27, 2022.

  5. Preventing CO Intrusion and Funding Resources

    This Notice provides HUD's intent to identify building-related sources of CO for PHA and Owner awareness and education for residents or tenants. The material in this and the next section summarizes guidance provided by the US Environmental Protection Agency (EPA), the Centers for Disease Control and Prevention (CDC), the Consumer Product Safety Commission (CPSC), the Federal Emergency Management Agency, and the US Fire Administration. CO alarms or detectors are not a replacement for the proper installation, use, and maintenance of fuel-burning appliances or well-ventilated garages. PHAs, owners (eg, landlords), and managers should ensure that combustion equipment is maintained and properly adjusted. Vehicle use should be carefully managed adjacent to buildings and in vocational programs through signage or policy updates. Where feasible, owners and managers can provide additional ventilation as a temporary measure when high levels of CO are expected for short periods of time.

    • Examples of activities to prevent CO intrusion include:

      • Ensure gas appliances are properly adjusted.
      • Install, properly maintain, and assure through periodic inspection that exhaust fans are functional and vented to the outdoors over gas stoves.
      • Ensure that flues over fireplaces are operational and capable of opening and closing by residents.
      • Use appropriately sized wood stoves certified to meet EPA emission standards with tightly fitting doors.
      • Perform annual inspections, clean, and tune up central heating systems (furnaces, flues, chimneys) and ensure that these activities are conducted by a trained professional.
      • Ensure leaks are repaired promptly.
      • Provide regular resident CO education through policies or signage.

    • Sources of CO that can be found in a housing environment, as described in the EPA's webpage Carbon Monoxide's Impact on Indoor Air Quality, include:

      • Unvented kerosene and gas space heaters.
      • Leaking chimneys and furnaces.
      • Back-drafting from furnaces, gas water heaters, wood stoves, and fireplaces.
      • Gas stoves.
      • Generators and other gasoline-powered equipment.
      • Automobile exhaust from attached garages.
      • Auto, truck, or bus exhaust from attached garages, nearby roads, or parking areas.
      • Incomplete oxidation during combustion in gas ranges and unvented gas or kerosene heaters.
      • Worn or poorly adjusted and maintained combustion devices (eg, boilers, furnaces) if the flue is improperly sized, blocked, or disconnected; or the flue is leaking.

    • Rental property owners, managers, and residents all play an important role in preventing CO intrusion and responding quickly when it occurs and where sources of CO exist. Common exposures occur when residents introduce a CO source or result from building-related sources, such as an inadequately exhausted vent or a faulty boiler. Other CO exposures occur during a natural disaster or utility interruption. Residents should avoid the use of portable generators, fired grills, vehicles, or fuel-burning space heaters as heat or fuel-burning electric sources indoors. Therefore, resident education is strongly encouraged particularly during seasonal increases in CO use or during periods of electric or heat outages. PHAs and Owners should inform residents that CO exposure can be prevented. Examples to avoid unintentional CO poisoning include:

      • Avoiding portable generators indoors and only using generators outdoors in well-ventilated areas away from all doors, windows, and vents
      • A gas-burning stove or oven should not be used for heat
      • A fuel-burning space heater that is not vented to the outdoors should not be used
      • A car should not be left running in an enclosed garage

    • PHAs operating public housing units may use either Operating Funds or Capital Funds for purchase, installation, and maintenance of CO alarms or detectors Based on the Act's set-asides, the Capital Fund Program conducts competitions for additional funds for CO alarms or detectors For the HCV and PBV programs, the property owner or landlord is responsible for the cost of CO alarms or detectors PHAs may use their HCV administration funds for landlord outreach and education on these requirements Owners of properties receiving assistance through the PBRA, Section 202, and/or Section 811 program may utilize the property's reserve for replacement account, residual receipts, general operating reserves, owner contributions, or secondary financing to fund the purchase, installation, and maintenance of CO alarms and detectors These expenditures may be subject to a standard approval process where applicable, but the purchase, installation, and maintenance of CO alarms and detectors are deemed eligible expenses

  6. Resident Education

    In the Act, Congress directed HUD to provide guidance to public housing agencies on how to educate tenants on health hazards in the home, including CO poisoning, lead poisoning, asthma induced by housing-related allergens, and other housing-related preventable outcomes, to help advance primary prevention and prevent future deaths and other harms. This notice provides initial information and guidance for PHAs, Owners, and managers PIH will develop additional materials for residents to promote healthy housing and prevent CO exposure. Planned materials include a highly graphic flyer using plain language tailored to federally assisted housing Owners and residents. The flyer will be available for black-and-white printing or color printing.

    HUD is developing CO materials for property management to support its educational activities. Materials will be posted to HUD's Website. Program notices and supplemental documents will inform owners and managers of their responsibilities under the Act Educational materials will be available for download without cost.

  7. Resources for Additional Information