HUD Extends Installer Licenses Needing Renewal

As a result of the impact that Covid-19 has had on installer training, HUD has issued the guidance to extend the HUD installer license renewal period.

If your HUD Installer license expires between March 31, 2020 and November 30, 2020, your license is automatically extended through December 31, 2020.

Click the link to read the announcement. Also, you may need  to show this letter to code officials and inspectors as proof that your license remains valid. InstallerWaiverAnnouncement_May2020

Be sure to keep your insurance/bond current, and also keep your reporting up to date.

DHS Advisory on Manufactured Housing Workers as Essential

I wanted to share with you the following guidance that was issued by the US Department of Homeland Security on May 19 on identifying essential workers during the Covid-19 pandemic.

According to DHS, manufactured housing workers involved in the “sale, transportation and installation of manufactured homes”, are specifically listed as essential workers. Also, workers responsible for the leasing of residential properties to provide access to affordable housing are also listed as essential.

It is important to note that this information is NOT a directive or standard, but rather only to be considered by state or local jurisdictions when determining their own list of essential workers. Consult with your state and/or local authorities before moving forward.

When reviewing this document, please pay attention to the BOLD TEXT on the cover page to better explain the limitations of this document. Scroll to the last page (Page 20) to see specifically where manufactured home retailers, transporters and installers are listed (Residential/Shelter Facilities Housing and Real Estate and Related Services).

Click below to access the document:

Dept of Homeland Security Advisory on Essential Workers

Pennsylvania Guidance for Construction Industry to Resume May 1

Wolf Administration Issues Guidance as Construction Industry Prepares to Resume Work May 1

From the Official Pennsylvania Government Website:

As the construction industry prepares to resume work, the Wolf Administration today issued guidance for all construction businesses and employees to mitigate the spread of COVID-19.

All businesses in the construction industry in the commonwealth are permitted to resume in-person operations starting Friday, May 1 – one week earlier than previously announced.

Previously, Governor Tom Wolf and Secretary of Health Dr. Rachel Levine ordered most construction projects to cease unless they were supporting life-sustaining businesses or activities or were granted an exemption to perform or support life-sustaining activities.

“My administration has taken measured, aggressive steps to protect public health and safety, including strictly limiting the types of businesses and projects that may continue to operate during this unprecedented time,” Wolf said. “Thankfully, these actions are working, and we are flattening the curve. As we start to take steps to reopen the state, we recognize that the construction industry is vital to Pennsylvania’s economy and may operate safely with stringent guidance in place that will protect employees and the public.”

The guidance, developed from guidance created by the General Contractors Association of Pennsylvania, provides universal protocols for all construction activity, as well as specific additional guidance for residential, commercial and public construction projects.

All business and employees in the construction industry must adhere to the Secretary of Health’s order providing for business safety measures, which requires that every person present at a work site wear masks/face coverings unless they are unable for medical or safety reasons and requires that businesses establish protocols upon discovery that the business has been exposed to a person who is a probable or confirmed case of COVID-19.

All construction projects must maintain proper social distancing and provide hand washing and sanitizing stations for workers, as well as cleaning and sanitizing protocols for high risk transmission areas. Businesses must identify a “pandemic safety officer” for each project or work site, or, for large scale construction projects, for each contractor at the site.

Residential construction projects may not permit more than four individuals on the job site at any time, not including individuals who require temporary access to the site and are not directly engaged in the construction activity.

For non-residential or commercial projects, the number of individuals permitted on enclosed portions of a project varies depending on the size of the enclosed site. Commercial construction firms should also strongly consider establishing a written safety plan for each work location containing site specific details for the implementation of this guidance to be shared with all employees and implemented and enforced by the pandemic safety officer.

Contractors performing work at the direction of the commonwealth, municipalities or school districts should defer to those public entities to determine what projects may continue.

Local governments may elect to impose more stringent requirements than those contained in the guidance and in such instances, businesses must adhere to those more stringent requirements.

Local officials have been tasked with ensuring that construction businesses are aware that this guidance exists and notifying businesses that a complaint of noncompliance was received.

Businesses that have questions about whether this guidance applies to them may email the Department of Labor and Industry at RA-LIBOIS-BUILDINGS@pa.gov.

View this information in Spanish.

Nationwide “AC” Regarding Manufactured Housing Window Shortage

I have been made aware of a recent action by HUD regarding the manufactured housing program that is worth sharing with installers and retailers.

Evidently, manufacturers are having problems purchasing windows that meet the older standards referenced in the Manufactured Housing Construction and Safety Standards (HUD Code). As a result, HUD has issued a blanket letter of Alternative Construction (AC Letter) that allows for the use of windows that meet the more recent standards generally accepted in other building codes.

As you know, AC letters require that the letters “AC” be included in the serial number of the home and that a notice be provided to any perspective purchaser explaining the issue. The blanket AC Letter requires that the manufacturer post the required purchaser notice “in the kitchen area of the home”. No action is required on the part of retailers and installers. For more information on Alternative Construction, see my post on that topic Let’s talk about: Alternative Construction (2-26-2018)

It is important that retailers and installers understand this situation so that they can accurately answer any questions posed by their customers who happen to see this notice. It is possible that you may run across a new manufactured home that utilizes multiple AC letters, like one for windows as well as other construction features. Make certain you check in the homeowners’ packet for any other AC approvals that may require your action.

Finally, while this is a blanket, nationwide AC Letter, I am sure that not every manufacturer will need to utilize this waiver. I suggest you talk with your manufacturer’s Quality Assurance Manager and ask them to keep you up-to-date on this issue.

Below is the link to the HUD website where you can access the AC letter and the notice:

Coronavirus Suggestions for Installers & Retailers

We are all looking forward to getting the Coronavirus under control and things getting back to normal. While it appears that the country will get back to work someday, this event will have a lasting impact in every part of our personal and professional lives. Right now, we should be preparing for what will become the “new” normal.

Smart manufactured home installers and retailers will take advantage the next several weeks to examine their daily routine and practices. Now is the time to begin taking steps to better protect themselves, co-workers, customers and families.

I have tried to come up with a list of ideas that our industry could use in helping to reduce the spread of Covid-19 or any future public health epidemic. So, here are my suggestions for some simple steps we all should be taking:

  1. Disinfectant wipes should be added to every tool box, truck, car, office, shop and work area. Start frequently wiping down any tools that are shared such as nail guns, saw handles, jacks, come-a-longs, etc. Don’t forget keys, steering wheels, door handles, keyboards, thermostats, control knobs and every other common use item. Cleaning should occur daily, and certainly each time a new user or operator touches a particular tool or piece of equipment. Avoid sharing tools with others!
  2. Hand sanitizer for everyone! Just be sure that any sanitizer you use is at least 60% alcohol.
  3. When you are on the job site, it is important to know that hand sanitizers are not as effective on dirty covered hands. Hands must be clean for the sanitizer to be effective. If soap and water is not available, consider using water-less hand cleaner (such as GoJo®) to remove the dirt. Be sure everyone understands the need to sanitize once their hands are clean.
  4. Trash, especially food wrappers and containers, should be removed frequently, and at a minimum once a day. At job sites as well as the office!
  5. Disposable latex gloves might seem crazy for the job site, but I believe smart installers will all be wearing them in the near future. You can get a box of 100, industrial quality latex gloves for just about $15. For those that may have an allergy with latex, nitrile and vinyl are a great option.
  6. Eye protection is a must! We don’t want people touching their eyes, and safety glasses will help protect your eyes from irritants.
  7. In the sales centers, if you have a mug or cup filled with pens available for your customers, now is the time to get rid of them (and the mug as well)!
  8. Water coolers, coffee pots, candy dishes, boxes of donuts, bags of homemade deer jerky, and the like, need to be eliminated from offices, lunch rooms, etc., (yes, deer jerky!).
  9. Limit the amount of sales literature available in your sales centers. Consider passing out these materials when requested. Allowing folks to browse racks of brochures, and possibly contaminating them, should be discouraged. One retailer branded brochure is sufficient for most of your potential customers.
  10. Have a box of face masks available for customers, vendors, workers or anyone that might need one.
  11. Consider a staggered work schedule. Maybe you can schedule some work for the off hours to reduce the number of people at the job site.
  12. Incorporate a housekeeping routine into the work day. Make certain you build sufficient time to clean your work area, tools, keyboards, handles, etc., several times a day!

If you have any thoughts on how to better protect your workforce and customers, please share them with us! You can add a comment or email me directly (markconte3@yahoo.com).

The best information for the construction industry that I could find is from the web site for the National Association of Home Builders (nahb.org).

Click here to down load a copy of the coronavirus-jobsite-infection-prevention-measures

Stay Safe!

Protecting the Heat Duct Crossover Gasket

During last couple of training courses held earlier this year, we talked quite a bit about problems with the heat duct crossover gasket. We all agree that the “through the rim joist” heat duct crossover is preferable to the old flex duct, but keeping the gasket intact during installation is a common problem.

Heat duct crossover gasket before installation.

It has been my experience that the top reason for consumer complaints is generally the result of excessive heat loss which impacts the home owners comfort and leads to unreasonably high heating/cooling bills. If we can keep the gasket intact throughout the installation process, it can go a long way in fixing this problem.

An example of a gasket damaged during the installation process.

 

The HUD code requires that all heat ducts be “substantially air tight” so it is important that care is taken to assure that this gasket survives installation. To do that, But, how can we protect this gasket during installation?

Easy to see how these gaskets get torn apart.

 

For the past couple of years, I have been encouraging installers to fabricate and protect each “through the rim joist” heat duct crossover gasket with a temporary metal shield. Now, it doesn’t have to be anything fancy, just a simple “L-shaped” piece of aluminum coil stock at least 16” long. Bend the metal to make an “L” about 8” high with a 90° bend of about 2”.

A simple aluminum shield to protect the heat duct crossover gasket.

Place one of these shields over each crossover gasket and hold it in place with a screw through the bottom. Once the home is in its final position, remove the screws and pull out the shields.

Several installers have started doing this and they all agree that it works great. However, these installers have offered some feedback to improve on this idea:

  1. Remove the shield BEFORE lagging the floors together. Otherwise it can be difficult to remove.
  2. Hang tags or something similar from each shield to make them easier to spot and less likely to be forgotten.

Now, lets take this one step further, why not start telling the manufacturers to install heat duct crossover shields in the factory? Just think how much they would save in service! Hey, there is no harm in asking!

So, if you haven’t already tried this, give it a go! Maybe you have a better method to protect this gasket, if so, feel free to share it in the comments section!

Finally, be safe and wash your hands!

Still Time to Comment on the Proposed Rule Changes

As reported in the past, HUD is proposing changes to the manufactured housing program. Several of these changes affect the manufactured housing installers and retailers. You still have the opportunity to tell HUD your thoughts, but you must act before March 31, 2020.

I believe it is critical for installers/retailers to weigh in. My previous post on this topic provides links to the proposal and instructions on how to comment. I am re-posting that information below.

Here is a short summary of some of my main concerns:

  1. Many of the proposed changes rely on the manufacturer providing additional materials and documents with the home. As you are well aware, this is a problem in our industry. I am again requesting that HUD require the IPIA (inspecting agencies) start inspecting shipped loose materials and designs.
  2. Quite a few of the proposed changes impact the responsibility of the licensed installer. However, installers are still not represented on the Consensus Committee.
  3. The proposed rules include provisions for attaching structures to manufactured home. The proposed rule change does not include provisions for the attachment of stairs to enter the home. As many of you know, this is often an issue with local building code officials.
  4. HUD has proposed establishing the design criteria of stairs for entry into a manufactured home. This new design criteria (rise and run of the stair tread), exceeds many state and local requirements and could prohibit the use of existing, prefabricated stairs and landings.
  5.  I am very concerned that these purposed rules will require the home installer to extend the water heater T&P discharge pipe to beyond the skirting. While the proposed rule is very short on specifics, I am concerned that this would result in a serious safety related hazard. The unexpected discharge of super heated, pressurized water could lead to serious injury.

The following re-post contains the links and other information needed for you to comment on these changes.

As promised, I have provided my comments to HUD concerning the proposed changes to the Manufactured Home Construction & Safety Standards. While there are many concerns with the proposed changes, l limited my comments to those that I feel have a direct impact on manufactured home installers.

I encourage you to review the proposed changes to the HUD code and submit your thoughts before the deadline of March 31, 2020. If you haven’t reviewed the proposed changes, CLICK HERE.

Also, on the right side of that page, your will see (In GREEN) the link to “Submit a Formal Comment”. You can either provide comments in the text box or attach a separate document.

Also, I am providing you with a copy of my comments for review. Feel free to use my comments as you see fit. CLICK to read my comments.

Having read over this proposed rule a few times, I am now of the opinion that these changes are really an attempt to erase the line between modular and manufactured housing. Many of the code changes (most of which I did not comment on) are written to open the HUD code to include more traditional and modular housing features (multi-story, stair geometry, duplex homes, etc.) I am not sure how you may feel about that, but I wanted to point it out to make you aware.

However, there are still plenty of issues that impact installers and retailers that should make us concerned.

Anyway, please take a few minutes and tell HUD your thoughts on these possible code changes.

 

Let’s Talk About Steel Support Piers

Throughout much of my career, I have only run across a few manufactured homes that were placed on a steel pier foundation. In the Mid-Atlantic region, concrete blocks are typically used to construct piers and most installers stick with what they’re familiar with. About a year ago, while visiting some homes in Vermont, I first observed steel support piers being widely used. More recently, while traveling out west, I again was reminded that steel piers are a viable option to the typical concrete block pier. Maybe it is time to take a second look at steel piers, you might be surprised at what you find!

Typical Steel Support Pier.

First, steel piers are an acceptable foundation support, and I find them included in every installation manual as well as the model installation standards. However, you need to make sure that any steel pier used meets the minimum requirements.

First and most important, any steel pier must be labeled. The label should indicate the pier capacity, and that they have been evaluated by an independent third-party agency to assure that they are properly designed and constructed. If you purchase the piers from a manufactured home supplier, you can be pretty certain that they are providing you with the proper piers. But always check for the label!

Typical Label on a Steel Support Pier

 

Next, be sure to check the pier capacity. Most of the steel piers that I have seen are limited to a maximum capacity of 6,000 lbs. per pier. Your typical “load on frame” for a 14’ wide home, located in the south (20 Lbs.) roof load, at an 8’ spacing is around 5,500 lbs. Just be cautious and take steps to assure you don’t overload the pier. Most of the installations I have seen with steel piers, the installer reduced the spacing slightly for a bit of wiggle room.

Steel Support Pier with Listing Label

Steel Support Piers also come with adjustable risers which allow you to fit the pier head tight to the frame or floor of the home. Keep in mind that the adjustable riser may not extend more then 2” in the final position. And never use the adjustment screw to level the home!

No more than 2″ of threaded riser permitted above pier stand.

These steel support piers come in a variety of heights, are light-weight, and are certainly a huge time saver for the installers.

I know that some folks are concerned about durability, however these steel support piers must be coated to protect from corrosion. If the site is properly graded, and crawl space properly vented, I don’t think corrosion should be a problem.

Truth be told, none of the manufactured homes I inspected that used steel piers had any problems related to the support of the home and/or pier.

If you have followed this blog for a while, you know that I am a big proponent of giving people choices regarding the installation of their manufactured home. I encourage you to do a little research on this pier option. You just might be surprised at what you learn!

Important Notices from HUD-Part 2 of 2

In the previous post we looked at the final rule issued by HUD regarding the Formaldehyde/Health Notice requirements. Now we need to look at the second notice from HUD that lays out several proposed rule changes to the manufactured housing program.

After you review these proposed rules, please take a few moments and share your thoughts with HUD while there is still time to make changes. HUD will accept your comments on these proposed rules until March 31, 2020.

You can read the proposed rule for yourself HERE and see how you can submit your comments. I am listing below only the proposed rule changes that I believe will impact installers and retailers. I have added my thoughts in [brackets] below each proposal.

3280.2, 3280.802, 3282.7 & 3285.5           HUD is adding the following definition of an “attached accessory building or structure” to the construction standards, regulations and the model installation standards.

“Attached accessory building or structure means any awning, cabana, deck, ramada, storage cabinet, carport, fence, windbreak, garage or porch for which the attachment of such is designed by the home manufacturer to be structurally supported by the basic manufactured home.”

[While I support the concept, I don’t like the attempt to list every type of attached building or structure. Differences in terminology can led to arguments, disagreements and lead to loop holes that undermine the intent of the rule. For example, stairways and landings are not included in the list. I think it is preferable to simply state that an attached accessory building or structure is anything that is attached to the manufactured home and utilizes the manufactured home for support. I will object to this proposal as written.]

3280.5          The home manufacturer would be required to add a statement on the data plate if the home is (or is not) designed for accessory structure attachment.

[While I like the concept, there is no requirement for the manufacturer to state on the data plate what type of attachment may be added. Again, it opens the door for varied interpretation. I will object to this proposal as written.]

3280.114        This proposed rule establishes requirements for stairs, landings, handrails, guards, etc. for stairways both inside the home and I assume on the exterior of the home.

The reason I assume on the exterior is at 3280.114 (d) and (e), there are requirements that specifically address exterior porches and exterior stairway lights.

[Since these requirements are more stringent than the requirements of some states (Pennsylvania for example), I think these requirements will cause confusion. I would suggest that the rule be changed to only address stairways inside the home and let the state govern exterior and basement stairs. I will object to this proposal as written.]

3280.211          HUD is finally proposing that carbon monoxide alarms be provided in homes that are equipped with fuel burning appliances or for a home that was designed for an attached garage.

[I fully support this proposal.]

3280.212 & 213 and 3282.14       Manufactured homes designed by the manufacturer to accept the attachment of a site constructed garage or carport will no longer require the HUD issued letter of “Alternative Construction”. Also, the manufacturer will be required to provide designs for the attachment of these structures in the installation instructions.

[I fully support this proposal.]

3280.609(c)(1)(iii)            This section requires that installers extend the water heater temperature/pressure relief valve discharge piping to the exterior (not under) the manufactured home.

[This proposed requirement is concerning as super-heated water being discharged outside of the skirting of the home could pose a risk to people or pets in the vicinity of the pipe termination. This is another example of additional burdens being placed on manufactured home installers without being included in the rule making process. I will object to this proposal as written.]

3280.612              With this proposal, HUD is looking to lower the pressure required to perform the water supply piping pressure test from 100 psi to 80 psi (± 5psi). Since this requirement is referenced in the Installation Standards, this would also change the requirement for installers.

[While I support this change, I am concerned that the manufacturers installation instructions will be slow to reflect this change.]

 

Again, this is my unofficial take on the proposed changes to the program. I encourage you to look them over, formulate your own opinions and comment to HUD while there is still time to make an impact.

UPDATED-Important Notices from HUD, Part 1 of 2

Note: I have received clarification from HUD on the change to the Retailer and Distributor Responsibilites as a result of this new rule. See the highlighted text below.

 

The US Department of Housing & Urban Development (HUD) published two notices in the January 31, 2020 Federal Register. This post will provide a brief overview of one of these two notices; the final rule announcing changes to the Formaldehyde/Health Notice requirement.

While the final rule has several elements, I think there are two big takeaways for manufactured home installers and retailers:

  1. The data plate inside the home will start including a note that the manufactured home is compliant with the Title VI, Toxic Substances Control Act. Retailers should start receiving and retaining a copy of this revised data plate (or some other document that indicates compliance) for a minimum of 3 years! See 3282.257 below!
  2. Section 3280.309 of the Manufactured Home Construction and Safety Standards is being removed. This section required the home manufacturer to provide a notice on display in the kitchen which informed potential customers that the building materials inside of the home may irritate certain people. You may know this notice informally as the “Formaldehyde Notice”.

    This notice will not be required in new manufactured homes entering production on or after March 2, 2020.

These code changes will take effect in manufactured homes entering the first stage of production on March 2, 2020.

It is important to understand that you should not remove the notice in homes you currently have in stock or on display. This final rule is not retroactive for home produced prior to the effective date.

As always, you should review the actual rule yourself as I am only providing my unofficial take on what I have read. To access the Federal Register publication Click Here! 

Also, HUD has added a subsection to the Manufactured Home Procedural and Enforcement Regulations under Retailer and Distributors Responsibilites. Read it here for yourself:

TSCA Title VI requirements.

Retailers and distributors must maintain bills of lading, invoices, or comparable documents that include a written statement from the supplier that the component or finished goods are TSCA Title VI compliant for a minimum of 3 years from the date of import, purchase, or shipment, consistent with 40 CFR 770.30(c) and 770.40.

 

UPDATE: I have reached out to HUD for clarification on this and here is their response:

“Through these regulations, HUD is supporting EPA’s pre-existing requirements, not creating new requirements.   As you may be aware, EPA’s definition of a “finished good” under TSCA Title VI does not exclude manufactured homes the way it excludes site-built housing (ref 44 CFR 770.3).   So, in regards to the requirement for retailers to retain records promulgated at 24 CFR §3282.257; as a retailer of a “finished good,” manufactured home retailers are required to maintain a record that the finished goods they are selling, comply with TSCA Title VI.  This is the same requirement EPA had previously codified at 44 CFR 770.30 and 44 CFR 770.40.    So for finished goods the retailer sells, they need to have records that each product (or home in our case) are TSCA VI compliant and can be a copy of the Data Plate or some other document that indicates compliance.” (emphasis added).

Retailers will need to receive documentation from the manufacturer, such as a copy of the data plate or other document to indicate the home complies with the with the Toxic Substances Control Act. This document should then be retained for a minimum of 3 years.

 

HUD also published a group of proposed code changes in a separate notice. I will do my best to provide a summary on this in a few days under part 2 of this post.