CRS INSIGHT
Carbon Monoxide Detection Requirements
for Military Housing
Updated July 30, 2019 (IN11149)
|
G. James Herrera
|
G. James Herrera, Analyst in U.S. Defense Readiness and Infrastructure (gherrera@crs.loc.gov, 7-8812)
Carbon monoxide (CO) is a colorless, odorless, and tasteless gas that can cause sudden illness or death if a person is
exposed to certain quantities. Often referred to as the "silent killer," CO poisoning kills over 430 people
annually in the
United States (U.S.), and approximately 50,000 people seek emergency medical treatment. Most states have enacted
statutes or adopted regulations that require CO detectors or alarms in private dwellings. In these states, owners are
required to install at least one battery-operated or hard wired CO detector or alarm in a housing unit.
Likewise, the Department of Defense (DOD) and the Military Services have taken CO risk reduction measures for
housing they own and operate. However, DOD estimates about 63% of military families live off-post in private sector
housing, or otherwise not on a military installation in DOD-maintained property. This military population is subject to
the CO safety measures enacted by state or local jurisdictions, which vary from robust to nonexistent. In addition,
another 24% of military families live in military privatized housing (i.e., housing built, maintained, and operated by
private developers, though leased from DOD through a ground lease). Military privatized housing can be off-post or on
a military installation, but in either case, CO detector or alarm requirements are generally determined by state and local
laws, not DOD, unless explicitly written into privatized housing lease agreements.
What is DOD's Policy for CO Detectors?
DOD's Unified Facilities Criteria (UFC) requires the installation of CO detectors as part of its building facilities criteria
for family housing constructed on DOD property. UFCs apply to the Military Departments, the Defense Agencies, and
DOD Field Activities in accordance with DOD Directive 4270.5 (Military Construction). UFC 4-711-01 states that
DOD is to "provide CO detection in compliance with [the] International Residential Code (IRC), or UFC 3-600-01 as
applicable" for family housing.
Additionally, the Military Services often issue separate policy and guidance that reinforce the CO detector requirement
for service-owned real property, and, to a lesser degree for leased property. For example, Commander, Navy
Installations Command (CNIC) Instruction 11103.1 states that for military personnel who are authorized to live in
government-owned or leased quarters, Public Private Venture (PPV) or community housing, the minimum acceptability
criteria to meet military housing needs includes "fully operational smoke and carbon monoxide detectors and other
safety features as required by State, Federal and Local codes." This means that for Navy-built housing, UFC 4-711-01
would be in effect. However, for Navy privatized housing (otherwise PPV under the Military Housing Privatization
Initiative [MHPI]), UFC 4-711-01 would not generally apply, but state and local laws would. As discussed earlier, the
