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Strobe Smoke Detector

Keystone

SAWHORSE
Joined
Feb 23, 2010
Messages
1,274
Location
Lehigh Valley, Pennsylvania
Recieved a written compliant from tenants of a house owned by lawyer. The occupants - father is 100% deaf, mother is 80% deaf, 3 children range in age from 14 to 2 and hear just fine. The owner, well lets just leave good enough alone. Issues raised by complainants are valid and while conducting a site visit they showed me many additional issues which is a seperate dealing but as I'm walking through the premises, it struck me that there was not one visually illuminating smoke detector. We have adopted 2009 IPMC (Pennsylvania) with minor changes but what section would I use to cite/justify requiring visual strobe smoke detectors?
 
It is a part of the federal Fair Housing Law.

It requires that landlords make special provisions for people with disabilities, defined as “a physical or mental impairment which substantially limits one or more of person’s major life activities; a record of having such an impairment; or being regarded as having such an impairment.”
 
The tenants may be interested in a product that they could take with them wherever they go, like a bed vibrator with a 520hz sounder by SafeAwake or LifeTone that actuate upon "hearing" the sound of a standard smoke alarm. This may provide better protection than a residential smoke alarm with an integral light.

Consider this report:

AbstractThis paper assesses the waking effectiveness of strobe lights and pillow and bed shakers as smoke alarm warning devices and compares them to an auditory signal. The signals were activated at increasing intensity levels during slow wave (deep) sleep in two groups, (i) 38 adults aged 18-77 years with hearing loss of 25-70 dBA in both ears, and (ii) 32 young adults aged 18 -26 years impaired with alcohol at 0.05 blood alcohol content. Three quarters of both groups slept through the strobe light activated at above the intensity required by the standard whereas a 75 dBA 520 Hz square wave T-3 sound woke over 90%, and at a louder volume 100%. The pillow and bed shakers did not wake 17-20% of the hard of hearing participants at the intensity level as purchased. Hard of hearing participants aged ≥60 years were less likely to wake up to the bed shaker than those aged <60 years. The pillow and bed shakers tested were not an effective means of waking moderately alcohol impaired young adults from deep sleep, with 36%-42% not waking up at the intensity level as purchased. For both groups the pillow and bed shakers were less effective than the 520 Hz square wave T-3 sound at 75 dBA at the pillow. This study supports earlier research showing that when sleep stage is assessed strobe lights have poor waking effectiveness. The 520 Hz square wave sound was more effective than the non-auditory signals for both groups.

Conclusion

Strobe lights, presented alone, were not an effective means of waking either of the two population groups tested. Under the testing conditions three quarters of the people in the hard of hearing and alcohol impaired groups did not wake up to the lowest strobe light intensity, which was more intense than that required by NFPA 72. Thus it is not appropriate to recommend strobe lights, either alone or in tandem with the current high pitched smoke alarm, as an effective means of waking people whose hearing loss is less than moderately severe (i.e. hearing thresholds of less than 70 dBA) or who have even a low (0.05) blood alcohol level.

Under the testing conditions the pillow and bed shakers, presented alone, did not wake 17-20% of the hard of hearing participants at the intensity level as purchased (vibrating in intermittent pulses) and those hard of hearing participants who were aged 60 years or more were less likely to awaken to the bed shaker than those aged below 60 years. No age group differences were found for any other signal. The pillow and bed shakers tested were not an effective means of waking moderately alcohol impaired young adults from deep

sleep, either at the intensity level as purchased, or at higher intensity levels. At the intensity level as purchased 36%-42% did not wake up.

These studies add to previous research suggesting a low frequency square wave (with a fundamental frequency of 520 Hz or thereabouts) is the most effective alerting signal tested to date and would be an appropriate emergency alerting device for those with hearing loss within the range tested in this study. Further study should be undertaken with people with higher levels of hearing loss (including deaf people) to determine the best signals, or combination of signals, that will reliably awaken this population from deep sleep. This should include bed shakers, pillow shakers, low frequency square waves (beneficial for those with residual hearing) and perhaps could include strobe lights.
 
Section 100.204 of the Fair Housing Amendments Act (FHAA), titled "Reasonable Accommodations". This section states, in pertinent part: "(a)It shall be unlawful for any person to refuse to make reasonable accommodations in rules, policies, pratices, or services, when such accommodations may be necessary to afford a handicapped person equal oppotunity to use and enjoy a dwelling unit, including public and common use areas."

Typically, the owner or manager of the apartment complex is on the hook for these improvements. If you want to look into this further, the information is contained in the Monday, January 23, 1989 edition of the federal register, 24 CFR Part 14 et al.

What happens if providing a requested accommodation involves some costs on the part of the housing provider?

Courts have ruled that the Act may require a housing provider to grant a reasonable accommodation that involves costs, so long as the reasonable accommodation does not pose an undue financial and administrative burden and the requested accommodation does not constitute a fundamental alteration of the provider’s operations. The financial resources of the provider, the cost of the reasonable accommodation, the benefits to the requester of the requested accommodation, and the availability of other, less expensive alternative accommodations that would effectively meet the applicant or resident’s disability-related needs must be considered in determining whether a requested accommodation poses an undue financial and administrative burden.

http://www.hud.gov/offices/fheo/library/huddojstatement.pdf
 
After quick review, it doesn't appear I will use, 24 CFR Part 14 et al., due to this being a HUD program by Faith Based Organizations.

I have come up with, 42 U.S.C. §§ 3601 et seq., but the langauge specifically states, "The Fair Housing Act requires owners of housing facilities to make reasonable exceptions in their policies and operations to afford people with disabilities equal housing opportunities. For example, a landlord with a "no pets" policy may be required to grant an exception to this rule and allow an individual who is blind to keep a guide dog in the residence. The Fair Housing Act also requires landlords to allow tenants with disabilities to make reasonable access-related modifications to their private living space, as well as to common use spaces. (The landlord is not required to pay for the changes.) The Act further requires that new multifamily housing with four or more units be designed and built to allow access for persons with disabilities. This includes accessible common use areas, doors that are wide enough for wheelchairs, kitchens and bathrooms that allow a person using a wheelchair to maneuver, and other adaptable features within the units.

Still on the hunt, maybe the occupants will be required to pay for thier own warning system of choice.
 
Good subject have not had to deal with it.

Sounds like certified letter to owner

Along with copies to city or state agencies first

Sounds more like owner problem
 
A certified violation letter will be going out the door but prefer to have my I's dotted and T's crossed early on,

I can suggest a request but much rather have a leg to stand on with an attorney.
 
Has the state adopted the international fire code???

If so there is retrofit provision in it to site
 
Meet with owner onsite, reviewed several issues and he flat out stated he will not complete work that isn't required by code. I'm certain if I went through my house I could find violations of the IPMC, I guess he hasn't reviewed the IPMC to see the vast amount of doushism that can be created.

CDA, I may be able to cite IPMC 704.1 General, which in a nut shell refers to the IFC, what section are you reviewing?
 
The tenants need to contact HUD, or the "state" version of HUD.

I am not a lawyer, nor do I play one on TV.

They can save themselves a headache and buy the portable units themselves $64
 
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You can file a complaint right now, by using our online form .

(It is recommeded that all pop-up blockers be turned off in order to access this form. Otherwise, press the "Ctrl" button as you click on the link.)

You can call toll-free 1 (800) 669-9777.

You can print out a form , complete it, and drop it or mail it to:

Office of Fair Housing and Equal Opportunity

Department of Housing and Urban Development

Room 5204

451 Seventh St. SW

Washington, DC 20410-2000

You can write us a letter with:

Your name and address

The name and address of the person your complaint is about

The address of the house or apartment you were trying to rent or buy

The date when this incident occurred

A short description of what happened

Then mail it to the Fair Housing Hub closest to you:

http://portal.hud.gov/hudportal/HUD?src=/topics/housing_discrimination
 
2003 ifc got pushed to chapter 46 in the 09 edition

907.3.2 Single- and multiple-station smoke alarms. Single-

and multiple-station smoke alarms shall be installed in

existing Group R occupancies in accordance with Sections

907.3.2.1 through 907.3.2.3.

907.3.2.1 General. Existing Group R occupancies not

already provided with single-station smoke alarms shall

be provided with approved single-station smoke alarms.

Installation shall be in accordance with Section

907.2.10, except as provided in Sections 907.3.2.2 and

907.3.2.3.

907.3.2.2 Interconnection. Where more than one smoke

alarm is required to be installed within an individual

dwelling unit in Group R-2, R-3 or R-4, or within an individual

sleeping unit in Group R-1, the smoke alarms

shall be interconnected in such a manner that the activation

of one alarm will activate all of the alarms in the individual

unit. The alarm shall be clearly audible in all

bedrooms over background noise levels with all intervening

doors closed.

Exceptions:

1. Interconnection is not required in buildings that

are not undergoing alterations, repairs or construction

of any kind.

2. Smoke alarms in existing areas are not required

to be interconnected where alterations or repairs

do not result in the removal of interiorwall

or ceiling finishes exposing the structure, unless

there is an attic, crawl space or basement

available which could provide access for interconnection

without the removal of interior finishes.
 
Mark, after reviewing past and present posted case law on HUD's website, wow the Fair Housing Act is much broader than I would have ever guessed and for the most part expeditious. By the time I send a notice, give adequate time for appeal and compliance, file a charge at the local level and get into court and who knows what will transpire then, HUD would have issued an opinion, slapped the hand and fined for factual violations
 
Keystone said:
Mark, after reviewing past and present posted case law on HUD's website, wow the Fair Housing Act is much broader than I would have ever guessed and for the most part expeditious. By the time I send a notice, give adequate time for appeal and compliance, file a charge at the local level and get into court and who knows what will transpire then, HUD would have issued an opinion, slapped the hand and fined for factual violations
They can save themselves a headache and buy the portable units themselves $64
 
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