How to Run an Appliance Audit Before AB 628 Enforcement

Why Audit Now

California's AB 628 is live. The law adds stoves and refrigerators to the state's habitability code. and with it comes a 30-day clock that starts running the moment the CPSC publishes a recall. If you don't remediate within that window, your tenants gain new legal remedies: rent withholding, repair-and-deduct, and in some cases lease termination.

Here's the problem: you can't respond to a recall if you don't know what's in your units. If a CPSC bulletin drops tomorrow for a specific Frigidaire range model, can you tell. within hours, not weeks. which of your units have that exact model?

For most PMs, the honest answer is no. Appliance records live in lease files, maintenance logs, purchase orders, and the memories of maintenance staff who installed them. That's not a system. It's a liability.

An appliance audit is the fix. and it's something you can start Monday morning. This guide walks you through the entire process, step by step. No theory. Just the exact playbook to build a defensible appliance inventory and know your recall exposure.

What You're Auditing For

Before you send anyone into the field, be clear on what data you need. For every landlord-provided appliance, you want to capture:

Step 1: Build Your Master List

Start at your desk, not in the field. You already have more appliance data than you think. it's just scattered across multiple systems.

Pull from existing records

• Lease files: Move-in condition reports often list appliances. Some leases include make/model as part of the property description.
• Maintenance records: Work orders for appliance repairs frequently reference the manufacturer and model. Search your PM software for keywords like "stove," "range," "refrigerator," "fridge," "dishwasher."
• Purchase orders / invoices: If you bought the appliances, the PO has the exact model and serial. Check with your accounting team or vendor records.
• Property management software: Platforms like your existing property management software have asset tracking modules. Even if you haven't used them, check whether prior staff entered appliance data.

Create your spreadsheet

Set up a centralized tracking sheet with these columns:

Don't worry if your existing records fill in less than half the spreadsheet. That's normal. The physical walk-through (next step) will fill in the rest.

Step 2: Physical Walk-Through

This is the core of your appliance audit. Send your maintenance team (or a dedicated audit crew) into every unit to capture data directly from each appliance's data plate.

Where to find data plates

Every appliance has a manufacturer data plate with the model number, serial number, and manufacturing date. But they're not always obvious:

• Refrigerators: Inside the fridge compartment on the side wall near the top, or behind the toe kick at the bottom.
• Stoves/Ranges: Behind the burner grates on the frame, or on the door frame when you open the oven door.
• Dishwashers: Inside the door along the top or left edge of the door frame.
• Washers: Under the lid (top-loaders) or around the door frame (front-loaders).
• Dryers: Inside the door frame or on the back panel.
• Microwaves: Inside the door frame or the cavity interior.

The golden rule: photograph everything

Do not try to write down serial numbers on-site. Data plates are often faded, poorly lit, or crammed into tight spaces. A single transcription error means your recall cross-reference won't match.

Have your team photograph every data plate. Use a phone camera with the flash on. Take two shots: one close-up for the text, one wider for context. That's it. Move to the next appliance.

A practiced maintenance tech can photograph all appliance data plates in a unit in under 5 minutes. For a 100-unit property, that's roughly two days of field work. less if you batch it with other maintenance rounds.

Step 3: AI-Assisted Capture

Photographing data plates is a big improvement over handwritten notes. But for a 200-unit portfolio with 3-5 appliances per unit, that's 600-1,000 photos to manually transcribe. AI-assisted capture changes the game.

How it works

Modern OCR tools. including RecallProof's scanner. read a photo of a data plate and automatically extract the manufacturer, model number, and serial number. The structured data goes straight into your inventory. No manual transcription. The benefits:

• Speed: What takes 30 seconds to manually squint at and type becomes a 2-second scan.
• Accuracy: AI doesn't confuse O's with 0's or I's with 1's. the most common transcription errors for model numbers.
• Consistency: Every entry is formatted the same way. No variations in how "GE Appliances" vs. "G.E." vs. "General Electric" gets recorded.
• Direct import: The extracted data flows directly into your inventory database, eliminating the spreadsheet-entry step entirely.

Step 4: Cross-Reference Against CPSC

You have your inventory. Now comes the question that matters: are any of these appliances recalled?

The manual approach

Go to cpsc.gov/recalls and search for each manufacturer + model combination. It's free and public. But if you have 500 appliances, you're looking at hours of careful manual searching. and a missed match means a missed recall.

The automated approach

Tools like RecallProof match your entire inventory against the CPSC database in seconds. Upload your spreadsheet (or connect your PM software), and every appliance is automatically checked against every active recall. Matches are flagged instantly with the recall details, affected serial ranges, and recommended remediation steps.

The difference isn't just speed. it's completeness. Manual searching misses edge cases: recalls under a parent company name (Haier recalls affecting GE-branded appliances), recalls with multiple model number formats, and products sold under different brand names.

Step 5: Flag and Remediate

If your audit turns up recalled appliances. and statistically, it will. you now have a 30-day remediation clock under AB 628. Here's exactly how to handle it.

For each recalled appliance, document:

1. Date of discovery. When you identified the recall match. This is the start of your 30-day window.
2. Recall details. CPSC recall number, hazard description, manufacturer's recommended remedy.
3. Tenant notification. Notify the tenant in writing. Include the recall details, the hazard, and your planned remediation timeline. Keep a copy.
4. Remediation action. Schedule the repair, replacement, or OEM recall remedy. Contact the manufacturer for their recall program (many offer free repairs or replacement units).
5. Completion confirmation. Date the remediation was completed, what was done (repair, replace, etc.), and who performed the work. Get a sign-off if possible.

For more on the full compliance process and your legal obligations, see our Complete AB 628 Compliance Guide.

Step 6: Set Up Ongoing Monitoring

An audit is a snapshot, not a solution. The CPSC publishes approximately 80 appliance-related recalls per year. roughly one every 4-5 days. The appliance that was clean in October could be recalled in November. Without continuous monitoring, you're right back to square one.

Your monitoring options

• Manual quarterly checks: Set a calendar reminder to re-run your inventory against the CPSC database every quarter. Low cost, but gaps between checks mean you could have 90 days of undetected recall exposure. And it depends on someone actually doing it every quarter, forever.
• CPSC email alerts: Sign up for CPSC recall notifications at cpsc.gov. You'll get every recall notice. but you're responsible for manually matching each one against your inventory. At 80+ per year, this gets old fast.
• Automated real-time monitoring: Services like RecallProof continuously watch the CPSC database and automatically match new recalls against your inventory. When a match is found, you get an alert with the affected units, recall details, and remediation steps. typically within hours of CPSC publication. No manual checking required.

For a handful of rentals, quarterly manual checks may suffice. For portfolios over 50 units, the math is straightforward: one tenant claim under AB 628 costs more than years of monitoring fees.

Common Audit Mistakes

These are the mistakes we see repeatedly in first-time appliance inventory audits:

1. Skipping serial numbers. "We got the model, that's enough." It's not. Many recalls affect only specific serial number ranges within a model. Without serial numbers, you either over-remediate (wasting money replacing non-affected units) or under-remediate (missing affected units and staying exposed). Go back for the serial numbers.
2. Only auditing stoves and refrigerators. Yes, AB 628 specifically covers stoves and fridges. But recalled dishwashers, microwaves, washers, and dryers create the same fire and injury liability under general tort law. You're already in the unit. spend the extra two minutes to capture everything.
3. Not documenting the audit itself. If you can't prove you conducted a systematic audit, it doesn't help your legal defense. Record when the audit was performed, who performed it, which units were covered, and what was found. A documented compliance process is what separates "good faith effort" from "negligence."
4. Doing a one-time audit without follow-up monitoring. The most dangerous moment is six months after your audit, when you feel compliant but new recalls have been published that you haven't checked against your inventory. An audit without ongoing monitoring is a false sense of security.
5. Relying on tenant reporting. Some PMs assume tenants will notice recall announcements and report them. They won't. Tenants don't know their refrigerator's model number, don't follow CPSC publications, and. under AB 628. they're not required to. Recall monitoring is the landlord's responsibility.

Free Audit Tools

You don't need to buy anything to start your audit today:

• CPSC Recall Search Search the full CPSC recall database for free at cpsc.gov/recalls. Filter by product type, brand, and date. This is the authoritative source. every other tool pulls from this database.
• RecallProof Free Scan Upload your appliance inventory and get an instant recall match report. no credit card, no commitment. See exactly which appliances in your portfolio have active recalls. Try the free scan →
• AB 628 Compliance Checklist Our downloadable guide covers the full audit process. from data collection through remediation tracking. Print it, hand it to your maintenance team, and go. Get the free guide →
• CPSC Email Alerts Sign up for free recall notifications directly from the CPSC. You'll get email alerts when new recalls are published. Good for awareness, but you'll need to manually match each alert against your inventory.