Virginia Regulatory Town Hall
Department of Professional and Occupational Regulation
Virginia Board for Asbestos, Lead, and Home Inspectors
Home Inspector Licensing Regulations [18 VAC 15 ‑ 40]
Action SB 607 Amendment
Stage Proposed
Comment Period Ended on 9/1/2023


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7/3/23  7:44 pm
Commenter: Huffman Home Inspections LLC

smoke alarms

Since it is recommended that smoke alarms should be replaced every 10 years and most have no manufacture or installation date on them, I always recommend that if one can not determine the age of the detector then it should be replaced. Worth consideration for recommended language for a report? 

CommentID: 217669

8/7/23  12:24 pm
Commenter: AMS Home Inspections LLC

Smoke Alarm proposed language.


Paragraph J. D. 3.  Recommended modification.

CommentID: 218488


8/31/23  10:56 am
Commenter: Ken Black

Smoke detector language clarification

For general consideration:

Is there a state standard or requirement in the VCC code for what defines "in good working order" for systems or life safety equipment? Is this left solely to the licensed professional's judgement to determine?

For example, a previous comment used a recommended timeline for replacement a possible method to define "in good working order" which could work, or do smoke detector manufacturers have a preferred testing method or industry standard? 


CommentID: 220034

8/31/23  1:08 pm
Commenter: Alex Aderton, Virginia Association of Real Estate Inspectors (VAREI)

VAREI Supports the Proposed "Smoke Alarm" Language

On behalf of the Virginia Association of Real Estate Inspectors (VAREI), I write in response to proposed amendments to 18VAC15-40-130 which require that a home inspection and the report on its findings include a determination of whether the home's smoke alarms are in "good working order”.

VAREI supports protecting the health and welfare of the public by informing homebuyers and sellers about best safety practices. We appreciate the work of the Virginia Board for Asbestos, Lead, and Home Inspectors to develop amendments that capture the spirit of SB 607 (2022), provide homebuyers with needed piece of mind, but that also do not place undue or arduous burdens on home inspectors. We also appreciate the opportunity for representatives from VAREI and our industry to provide input on the drafting of these amendments.

It is important to note that home inspections are snapshots that assess the readily accessible components within a home at a specific point in time. As they are normally conducted shortly after a home goes under contract, there can be a significant amount of time that passes between them and when a homeowner takes possession of the property. Additionally, the majority of components inspected have a lifespan that can vary greatly. As the proposed amendments state, any inspection is not a guarantee, warranty, or any form of insurance.

Assessing the functionality of smoke alarms can be tricky. The only true way to determine their full viability is with actual smoke, which would certainly be difficult for the purposes of a home inspection. That being said, we believe the proposed amendments strike the appropriate balance by providing homebuyers with useful knowledge about their smoke alarms, while not placing unnecessary liability on home inspectors.

In order to determine if a smoke alarm is in good working order, it must be accessible. That distinction is important since there are times where they are located in homes in places that are inaccessible, such as near the tops of cathedral ceilings. Furthermore, some smoke alarms are now connected to larger security systems whereby utilizing their test function would notify the local fire department. The amended requirements for home inspection reports in 18VAC15-40-130 address these issues appropriately.

Many home inspectors already include language in their inspection reports that recommends placement of smoke alarms, and that home owners should follow manufacturer’s recommendations. We believe the new language requirements for home inspection reports related to smoke alarms provide homebuyers with sufficient knowledge about smoke alarms, and the importance of proper placement, installation, and maintenance.

Thank you again for the opportunity provide input on this matter.

Alex Aderton

2021-2023 President, Virginia Association of Real Estate Inspectors

CommentID: 220036