Ethan Mascoop, MPH, MUA, RS P.O. Box 320029 West Roxbury, Massachusetts 02132 October 4, 2017 Office of the General Counsel Massachusetts Department of Public Health 250 Washington Street Boston, Massachusetts 02108 Re: Comments on Proposed Amendments to 105 CMR 410.000: Minimum Standards of Fitness for Human Habitation (State Sanitary Code, Chapter II) Dear Sir/Madam: The following are my comments regarding the proposed amendments to 105 CMR 410.000: Minimum Standards of Fitness for Human Habitation (State Sanitary Code, Chapter II). I would like to commend DPH for its efforts in improving the readability and clarity of many sections of the proposed amendments. As you are aware, this code is read and used by many people not trained or familiar with inspections, law, regulations and courts. In fact, many tenants and landlords represent themselves in court and attempts to make the code understandable and transparent are welcomed and necessary. SUMMARY There are a number of significant proposals that require additional clarification and guidance for inspectors, tenants, landlords and courts. These include: Kitchen facilities (410.100) Potable water (410.130) Natural and mechanical ventilation (410.220) Means of egress (410.260) Electrical service (410.320) Areas free from mold and other fungi…(410.500(C)) Elimination of pests (410.560) These and other sections of the code are vague, confusing, difficult to inspect/interpret, and would be inconsistently enforced throughout the state. I suggest that DPH provide a guidance document similar to the Food Code Annex (adopted by DPH Food Protection Program). This
Ethan Mascoop, MPH, MUA, RS P.O. Box 320029 West Roxbury, Massachusetts 02132 October 4, 2017 Office of the General Counsel Massachusetts Department of Public Health 250 Washington Street Boston, Massachusetts 02108 Re: Comments on Proposed Amendments to 105 CMR 410.000: Minimum Standards of Fitness for Human Habitation (State Sanitary Code, Chapter II) Dear Sir/Madam: The following are my comments regarding the proposed amendments to 105 CMR 410.000: Minimum Standards of Fitness for Human Habitation (State Sanitary Code, Chapter II). I would like to commend DPH for its efforts in improving the readability and clarity of many sections of the proposed amendments. As you are aware, this code is read and used by many people not trained or familiar with inspections, law, regulations and courts. In fact, many tenants and landlords represent themselves in court and attempts to make the code understandable and transparent are welcomed and necessary. SUMMARY There are a number of significant proposals that require additional clarification and guidance for inspectors, tenants, landlords and courts. These include: Kitchen facilities (410.100) Potable water (410.130) Natural and mechanical ventilation (410.220) Means of egress (410.260) Electrical service (410.320) Areas free from mold and other fungi…(410.500(C)) Elimination of pests (410.560) These and other sections of the code are vague, confusing, difficult to inspect/interpret, and would be inconsistently enforced throughout the state. I suggest that DPH provide a guidance document similar to the Food Code Annex (adopted by DPH Food Protection Program). This
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