Shipped Loose Plumbing-What You Should Expect

It seems that at every installation training or seminar I present, installers and retailers complain that the home manufacturer is not providing the materials needed to complete the drain lines under the manufactured home. So I decided to take a look at this issue and see what we can learn.

The first thing we need to do is see exactly what the Manufactured Home Construction & Safety Standards (HUD Code) says about this.

Check out 24 CFR 3280.610(c)(1)-Drainage systems:

Each manufactured home shall have only one drain outlet.

Ok, now check out 24 CFR 3280.610(c)(5) Preassembly of Drain Lines:

Sections of the drainage system, designed to be located underneath the home, are not required to be factory installed when the manufacturer designs the system for site assembly and also provides all materials and components, including piping, fittings, cement, supports and instructions necessary for proper site installation.

So, when you look at both sections together, it should be pretty clear.  The manufacturer is going to design the drainage system so that all of the individual drain line drops through the floor can be connected to one point AND they must provide all the materials needed for the installer to complete the drainage system according to the provided design.

To know that you are getting all the plumbing parts you are required to receive, you need to look at the design supplied with each new manufactured home shipped from the factory. Generally, this DAPIA approved design is included with the box of other shipped loose parts needed to complete the home. Following this design, you should be able to connect all of the drain line drops to that required “one drain outlet” with materials provided by the manufacturer. 

The materials needed to complete the plumbing in the circled area would be shipped loose inside the home.

 

There is another reason it is important that the manufacturers supply installers with the needed parts and designs to complete the drain line, and it is called “preemption”. HUD has ruled (in a letter dated 12-4-1996) that state or local code enforcement may not require licensed plumbers to assemble shipped loose plumbing. But if you are not installing the drainage system according to the Manufactured Home Construction and Safety Standard, (by not following the DAPIA approved design, or using your own materials) then the local code requirements could apply. 

It is important to note that where the drain lines from the home connect to the main sewage connection the local authority has control, and at that connection, a licensed plumber can be required. 

If you are installing manufactured homes in an area that requires licensed plumbers to assemble the drain system, you should consider working with the manufacturers, your state officials, and possibly HUD to end this unnecessary requirement.

If your manufacturer is not shipping these required drain line parts with the home, you should show him 24 CFR 3280.610(c)(5). This is just one more reason why it is important for professional installers to know the HUD Code!

I hope this information is helpful.

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Let’s Talk About Spacers and Shims

A few weeks ago, we looked at pier cap blocks, so now it makes sense to talk about spacers and shims.

Just so we are on the same page, a spacer can be used to fill in the space between the cap block and the frame (chassis) if that space is more than can be shimmed (1″). Sounds simple enough, right??? Well think again.

Double block pier, concrete footing under the ground vapor barrier, double 4″ solid masonry cap blocks, 2″ hardwood spacers and hardwood shims. Nice job!

The Model Manufactured Home Installation Standards describe a spacer as “Hardwood plates no thicker than 2” nominal in thickness or 2” of 4” nominal concrete block…”. (3285.304(c)(3)). But the individual manufacturers’ installation instructions often provide more options, and sometimes confusing details.

Most manufacturers allow 2” x 6” hardwood spacers. One spacer for single stack block pier, two spacers for a double stack block pier (one per cap block). If you stick with this, you will be in good shape.

 A recently revised instruction manual now defines a spacer as “hardwood, southern pine, or Douglas fir larch dimensional lumber 1x or 2x (2 layers maximum)”.  This is the first time I have seen pine in the same category as hardwood, not to mention allowing the spacer to be 1” thick. So, for those of you that like to use 5/4 pressure treated decking boards as spacers this appears to be one of the first DAPIA approvals for this method.

2″ hardwood spacer on a 4″ solid masonry cap block. Too bad the strap is loose.

When checking your installation manual, look at both the table and the text. Many instructions will specify “Nominal 2” thick boards” in the Pier Minimum Specification Table. BUT, if you turn to the text at “Install Shims” generally on the next page, they allow hardwood or concrete, not just 2” thick boards.

spacer text

Pressure treated hardwood dimension lumber is mentioned in a few manuals, but I have yet to see pressure treated hardwood. Maybe it’s a regional thing, but where I come from, hardwood is not pressure treated.

I even saw a few manufacturers’ installation instructions that don’t mention spacers. Just be sure to double check with your manufacturer to be certain that you are following their instructions.

When it comes to the overall size of the spacer, most pier illustrations show a 2” x 6” spacer board. While the installation instructions don’t specify the length of the spacer, the illustrations appear to show them the full length of the pier cap (16”). 

While there appears to be variation in the materials prescribed by different manufacturers, make sure to stay away from plywood or OSB! These materials will delaminate rather quickly and will certainly cause problems.

When it comes to shims, the installation instructions are more straight forward.

Use proper size spacers and hardwood shims! Not cedar shims like this!

Hardwood shims, 4” x 6” x 1” thick, must be used in pairs, and cannot occupy more than 1” total between the cap block (or spacer) and frame (I-beam). And like the spacers and cap blocks, a double block pier would require two sets of shims, one set atop each cap block.

Plastic Shims

Most manufacturers allow for plastic shims of sufficient capacity. I believe that plastic shims are a great choice for piers in porch areas, where water can pass between the decking boards and lead to premature decay of wooden shims. Also, the plastic shims are grooved so that they cannot slip apart. Again, I did see one manufacturer allows southern pine or Douglas fir shims in addition to hardwood. But generally plastic is the only exception to hardwood shims.

Hopefully, this post will encourage you to examine your current practices regarding spacers and shims, and to be certain you are following the manufacturers’ installation instructions. If you have questions, call the manufactuer’s Quality Assurance Manager and ask him to clarify their requirements.

Information Regarding the HUD Forms 305, 306, 307 & 308

Note: this information only pertains to HUD licensed manufactured home installers and manufactured home retailers that are located, or are selling new manufactured homes into states where HUD administers the Manufactured Housing Installation Program.

I have received a few questions lately regarding the continued use of the HUD Manufactured Housing Reporting Forms listed above, as they have reached the White House Office of Management and Budget (OMB) expiration date of April 30, 2018.

Notice the date at the top right.

 

Please understand that reaching the expiration date does NOT make the forms invalid. Manufactured home installers and retailers should continue to use the forms as in the past.

The OMB performs a periodic review of all forms issued by federal government agencies to assure that they are current and applicable to the rules and regulations of each particular program. The program staff at HUD have assured me that the forms are in the review process, and that they should be approved at some point in the future.

So, don’t worry or change your current practice as a result of the expiration date. Continue to complete and process the required forms as in the past!

As they say in England,  Keep Calm and Carry On!

Let’s Talk About Pier Caps

After some recent inspections I thought we should talk a little bit about properly capping concrete block piers.

The function of the pier cap is to evenly distribute the weight of the manufactured home, its contents and the added weight of any potential snow on the roof into the concrete block pier. Ultimately, taking approximately 5,000 to 6,000 pounds from the chassis beam and spreading it out over the top of each concrete block pier in a manner so that the pier will not crack, break, or otherwise fail under the weight.

Properly constructed pier with 4″ solid masonry cap blocks

The first thing to remember is that the cap MUST be the same size as the pier.  A pier constructed of single stacked (8” x 16”) concrete blocks, must have a cap that measures 8” x 16”. If the cap does not fully cover the block, the weight will not be applied evenly over the top surface of the block, and the result will likely be a failure of the pier blocks.

Don’t do this! Cap blocks must cover the entire pier to properly transfer the load!

The biggest problem I see with cap blocks are that installers often use improper materials to cap concrete block piers.  DO NOT USE plywood, OSB, 1” thick lumber, or decking boards! Decking boards would include 5/4” x 6” pressure treated lumber or any composite type of decking.

I checked nine different manufacturers installation manuals, and found that six of the nine specify the same materials for pier caps:

Solid precast masonry 4” thick-8” x 16”, pressure treated lumber 2” x 8” x 16” or ½” thick x 8” x 16” painted steel. I must admit, I never saw anyone use ½” steel, so if you do, please send me a picture!

Check the Pier Material Minimum Specification chart in the current installation manual to be certain you are providing proper pier caps.

 

Two manufacturers don’t mention pressure treated lumber, and only specify 2” thick hardwood as an option to 4” masonry or steel. One manufacturer simply says solid masonry or hardwood with no mention of thickness!

2″ x 8″ x 16″ pressure treated lumber pier cap

 Now is a great time to double check that you are using proper materials as pier caps. As installation manuals are prone to change, make certain that you are using the current manuals for the homes you are receiving. I know that some folks are using ABS (plastic) pier caps. If that is you, be sure to get a DAPIA approved design from the manufacturer for your installer file.

A Tool to Improve the Building Permit Application Process

Having just wrapped up a week of talking to building code officials in three different states, I was reminded of the importance of the building permit application process and how professional installers need to improve the flow of information between themselves and the building code officials. 

Far too many installers continue to pretend that the entire installation process for a manufactured home can be boiled down to a one-page pier print. Then complain if the code official doesn’t uniformly enforce installation requirements on other installers. The problem is that it is very difficult to organize the documents needed into a manageable sized packet of information. The typical installation manual is far too cumbersome and code officials are not going to spend time flipping through these 100+ page manuals for each permit application. Nor should they!

I thought if we could create a tool to help assemble a packet of designs, extracted from the manufacturer’s  installation instructions, it could streamline the process, focus on the important issues of support and stabilization and help eliminate bad actors from the business of manufactured home installation. This post is intended to help installers assemble just such an informational packet through the use of a cover-sheet to pull everything together! 

I know you don’t think you have the time to organize all the documents needed for a complete building permit application, or that the code official doesn’t want anymore then the one page pier print. But if we are ever going to move the manufactured housing industry and careers as professional installers forward, we need to look at the bigger picture when it comes to working with building code officials. 

Here are a few things to consider:

 Manufactured homes have gotten significantly more sophisticated over the years, yet our approach to working with the building code officials remains unchanged! If we want to improve the image of manufactured housing and attract a larger segment of the home buying public, we need to earn the confidence of the code officials.    

Getting familiar with charts like this is step #1 to a more professional installation

 As a trained and licensed professional installer, you should take charge of your installations by being in control of all of the documents needed to properly install the home. The way we have always done things in the past is probably wrong, out dated, and a waste of money and time. Housing designs have changed rapidly over the years, both installers and code officials must be on top of these changes. The only way to keep up with the changes is to make sure we are submitting and following current and pertinent installation documents with every permit application. We just lacked a tool to help installers organize the designs they need for a building permit. 

 Are there unlicensed installers stealing work from you? Once building code officials start seeing exactly what is to be expected for every building permit and subsequent installation, unlicensed installers will not be able to keep the pace.

 Most importantly, a properly applied for building permit eliminates variables and unknowns from the process and goes a long way in increasing profits and reducing liability.

Ok…here is a breakdown on what should be included at permit application as a minimum:

Identify the licensed installer! Show the code official your license so that they come to expect a licensed installer for every new manufactured home installation.

Identify the home by manufacturer as well as home width, side wall height, roof pitch, foundation type and for a few manufacturers, the size of the eaves along the sidewall.

A copy of the manufacturer’s DAPIA approved installation instructions that highlight the appropriate charts and tables needed to construct the foundation. If not submitting the entire installation manual and only the table of contents page shows the DAPIA stamp, provide a copy of that page as well.

Provide DAPIA approved documents from the manufacturer that show approval for any alternate installation methods you might be using (such as alternative anchoring system or shallow frost protected foundation).

Include the Complete Installation Checklist from the installation manual or a Expanded Installation Checklist (from October 16, 2017 post) to better address the installation.

Provide notes on the soil bearing capacity, frost depth and other site-specific considerations that are needed to assure a proper installation.

Typical Pier Print-an installation tool, but must be used with several other design details.

 

And finally, prepare a plan of the home where you can layout the proper location of piers. CAUTION! Pier prints from the manufacturer are not to be trusted. Every pier print refers the installer to the actual installation instructions.  You may want to use the pier print as a tool to help you determine pier locations, but never trust these pier prints without first reviewing it yourself! 

A sample of the permit application cover sheet.

The link below will take you to my attempt at developing a tool to help professional installers organize the documents needed for the building permit application. Feel free to modify it for your particular use.  Click Here for Manufactured Home Building Permit Application Cover Sheet

You will likely need to add some additional documents for the code official (plot plan, sewer tap permits, etc.), but the cover sheet in the above link, will help you get the home specific details in order. Consider making this a part of your typical building permit procedure. I promise, if you try it one time you will quickly see the benefit! 

    

Let’s talk about: On-Site Completion

In our previous post we talked about Alternative Construction (click here to view it). This is a special authorization from HUD to allow manufacturers to construct specific homes that do not meet a certain aspect of the Manufactured Home Construction & Safety Standards (MHCSS or HUD Code). Tankless water heaters, accessible showers, garage ready, or two-story homes exceeding the allowable path of travel to an exit door are a few examples. These homes may not meet the letter of the code, but will perform just as well or even better than the MHCSS.

On-Site Completion (SC) is different as the manufactured home (after all site work is done) will meet all aspects of the MHCSS. However, there are certain elements of construction that cannot be completed in the factory, so they will need to be completed at the installation site. For example, a home designed for a stucco or brick exterior may be shipped to the installation location where the stucco or brick can then be applied. Maybe a home was designed for roof dormers or roof extensions, again, these would be added at the installation site. Tile and glass shower enclosures, and completion or installation of a fireplace are a few other examples. These homes would all comply with the MHCSS, but the work can’t be completed until after it is transported to the site.

Tiled Shower enclosures are often completed under On-Site Completion.

 

If you are like me, you might be thinking, why isn’t this addressed as a part of installation? Well, one of the big things that occurred when the manufactured housing law was amended in 2000 was that installation work was somehow separated from construction. So, we ended up with two classifications of work: construction (in the factory) and installation or close- up (occurs on site). However, the line that separates construction and installation is often blurry.

Fireplace and hearth extension along marriage line finished at the site, under On-Site Completion.

 

Even though the federal law was amended almost 18 years ago, the On-Site Completion rule only recently took effect (March 7, 2016), so it is still very new. Through time, many things that are addressed under Alternative Construction may be shifting to On-Site Completion. So keep your eyes open.

Here are the things that installers and retailers should know regarding On-Site Completion (with references to the Manufactured Home Procedural and Enforcement Regulation in the event you want more information than I provide here).

  • The letters “SC” will be included in the serial number of the home. Keep in mind, a manufactured home can have both SC and AC (Alternative Construction) features. 3282.605(a)
  • A Consumer Information Notice must be developed by the manufacturer that explains the process and identifies the work to be completed on site. 3282.603(d)(10)
  • The manufacturer must provide a “Consumer Information Notice” and have it prominently on display in the home (often by the Health Notice in the kitchen). 3282.606(b)

Typical Consumer Notice

  • The retailer (or manufacturer) must provide a copy of the Consumer Information Notice to perspective purchasers before they enter into the sales agreement.  3282.606(c).
  • The manufacturer is required to provide all of the designs to be followed and materials necessary to complete the construction outlined under the On-Site Completion provisions. 3282.608
  • If the manufacturer expects their retailer or installer to perform this work at the job site, the manufacturer is to provide authorization before the work begins. “However, the manufacturer is responsible for the adequacy of all On-Site Completion work regardless of who does the work…” 3282.602(b)
  • Prior to occupancy, the manufacturer must assure that the On-Site Completion work is inspected. This may require inspections by the manufacturer and IPIA (2 separate inspections) or the IPIA can accept the manufacturers inspection (which appears to be the most common approach). 3282.605(c).
  • The homeowner and retailer are to receive a final site inspection report and certification of completion after all inspections have been conducted. 3282.608(m)

I hope that both the professional installer and the retailer understand that this means additional paper work and record keeping.

If you are the professional installer and are expected to perform this work, make certain you have been given the written authority from the manufacturer before you start the work. Maintain this paperwork in your file for the home along with copies of the documentation provided by the manufacturer.

As the retailer, have a record that you provided the Consumer Information Notice to the purchaser before the sale. Have them sign and date the notice, and keep a copy in your home file.

If a retailer or installer is going to accept responsibility for any part of the inspection process, they should assure the authorization to conduct the inspection is received from the manufacturer in writing. Also, keep copies of the construction designs and the “On-Site Inspection Report”.

Finally, always keep in mind that the entire On-Site Completion process is the responsibility of the manufacturer. If you ever are unsure or have questions on the SC process, talk to the manufacturer’s Quality Assurance Manager. He is the one with all the answers!

Let’s talk about: Alternative Construction

Last week during a discussion in an installation training class, it became obvious that too many installers and retailers aren’t being informed about Alternative Construction (AC) and On-Site Completion (SC) and what this means for the manufactured homes that they install and/or sell.

So, lets take a look and see if we can shed some light on these issues, starting with Alternative Construction.

When a manufacturer intends to produce a manufactured home with a construction aspect that does not meet the Manufactured Home Construction & Safety Standards (MHCSS), but will perform at least equal to the MHCSS, they can request HUD allow such construction.

Let me give an example:

Say you want the manufacturer to construct a home for your customer that has tankless water heaters instead of the typical storage type water heater.  Since the MHCSS doesn’t provide for a tankless water heater, the manufacturer needs a special approval from HUD to omit the storage type water heater and replace it with the tankless type. That approval is called a Letter of Alternative Construction (or an AC letter).

Here is another example: your customer needs a shower that is designed for wheelchair access. The MHCSS requires a minimum 2” dam (or threshold) to keep the water from running onto the floor, making it impossible to access the shower with a wheelchair. The manufacturer can request an Alternative Construction authorization from HUD to provide a shower without a 2” dam, designed to facilitate wheelchairs.

Accessible Shower

 In both of these cases, the home will not meet a specific requirement of the Manufactured Home Construction and Safety Standards, however they both will perform equal or better than the actual code requirement.

DAPIA approved floor plan for a home with garage attachment.

 Currently, one of the biggest requests for AC letters is when a manufactured home is designed for the attachment of a site-built garage. There are many issues of code compliance that must be examined when designing a home for garage attachment.  Issues such as the path of egress (exit) from the bedrooms, impact on lighting and ventilation in the area where the garage is attached, additional loads on the structure of the home, and electrical considerations, to name a few. But the omission of the exterior covering (siding) for the application of gypsum to provide the needed fire separation is where you will find the need for the AC letter.  On a side note…the MHCSS still does not address carbon monoxide alarms! If you are selling/installing a home with a garage attachment, talk to the manufacturer about a combination smoke/CO alarm or an added electrical outlet where you can provide this important safety consideration.

Through the years, the most common use for an AC letter has been a home with a hinged roof, usually a 5/12 roof pitch or greater (this never made sense to me, but that is how they handled hinged roofs). Today most manufactured homes with a hinged roof are being constructed under the new On-Site Completion Process, which we will discuss in a our next post.

 Here are a few “take aways” for retailers and installers when it comes to Alternative Construction.

  •  A manufactured home covered by an AC letter is determined to perform equal to or greater than the MHCSS requirements.

Typical notice to consumer of Alternative Construction.

  • Every manufactured home under an AC letter requires a notice to the perspective purchaser. This notice, as well as an appropriate checklist, and other information related to the AC process is provided by the manufacturer.
  • You can identify a manufactured home constructed under a letter of Alternative Construction by the letters “AC” which will be included in the serial number.
  • Often the home will require a special inspection.   
  • Both the retailer and installer should maintain records of compliance with the AC requirements, and a copy of any needed inspection of the completed home.

 Ok…I hope this helps. If you have anything to add, submit a comment.

In our next post we will talk about On-Site Completion.

Our Comments to HUD!

On my February 6, 2018 post I shared information from HUD that they want to hear from the manufactured housing industry regarding the impact of their regulations. As of February 21, there are almost 300 people that have taken the time to share their opinion. I was encouraged to see how many installers weighed in!

Comments are being accepted until February 26, 2018, so there is still time! Click Here to access the previous post with directions on submitting comments.

For your information, below is a copy of my comments to HUD that were submitted this morning:

Docket Number: FR–6075–N–01 – Regulatory Review of Manufactured Housing Regulations

Thank you for the opportunity to comment on current and upcoming manufactured housing regulations. It is extremely important that HUD conduct on-going reviews and analysis on the impact of all regulations. Having made my career in the manufactured housing industry, I provide the following comments:

·         Since the adoption of the Manufactured Housing Improvement Act, manufactured home installers have been the most significantly impacted segment of the manufactured housing industry. However, manufactured home installers have never been represented on the Manufactured Housing Consensus Committee. The vast majority of home installers do not belong to trade groups, and as a result have been excluded from the rule-making process.  I encourage you to seek input from all affected parties, and particularly manufactured home installers as you review installation related regulations.

·         I know that many have commented on broadening HUD’s enforcement of preemption as it relates to manufactured housing. Please keep in mind that to successfully preempt manufactured housing from state and local building codes, the Manufactured Housing Constructions and Safety Standards must be kept current. I encourage you to provide your Office of Manufactured Housing Programs with sufficient staff and resources to effectively and efficiently operate the program and work towards continual updating the construction standards, just as every other construction code is kept current.

·         In regards to HUD providing guidance on frost protected foundations for manufactured housing installation, I agree with most commenters that this issue is better left to state or local building code enforcement. However, regardless of the which governmental agency has authority over the issue of frost protection for manufactured home foundations, I believe that HUD has a role in working with local code enforcers so that they can properly and effectively understand their role in manufactured housing. A HUD sponsored outreach program that provides training to municipal building code officials regarding proper handling of manufactured housing would be a very effective tool in broadening preemption.  Additionally, in a situation similar to installers, local code enforcement has not been properly represented on the Manufactured Housing Consensus Committee.

 I appreciate the opportunity to provide comments regarding overly burdensome regulations and requirements. As you and your staff wade through this and the other comments, I encourage you to keep in mind that there are four equal tenants to the manufactured housing program. Manufactured homes must be safe, high quality, durable and affordable. All four tenants must be preserved to support this program as it moves toward the future.

 

Mark Conte

 

Alternative Foundations

This concrete slab on grade is one example of an alternate foundation.

I know that through the years a lot of community owners have hired professional engineers to design foundations for homes installed in their parks. Many times, these foundations are elaborate, well designed, and constructed beyond the minimum requirements of the installation standards.

 In some places, these foundation designs were also reviewed and approved by the state, county or local code official.  With approval from engineers and building code enforcers, what could be the problem???

 Well grab your “Model Manufactured Home Installation Standard” and open to section 3285.2(c)(1). It says that BEFORE an installer provides support or anchorage that are different then the installation instructions, or if the installer encounters site conditions that prevent the use of the installation instructions, the installer MUST:

  •  Try to get DAPIA approved designs or instructions from the manufacturer; or
  •  If the designs are not available, have designs prepared and stamped by a professional engineer (or architect), and submit these designs to the manufacturer for their approval, and approval by the DAPIA!

After a few modifications, this foundation was manufacturer and DAPIA approved!

 Basically, any foundation system that is not addressed in the manufacturer’s installation instructions would be considered an “Alternative Foundation System”. It would need to be approved by the manufacturer and their DAPIA before you can use it to support/stabilize a new manufactured home. Ultimately, the manufacturer needs to agree that any alternate foundation will properly support and stabilize their homes.   

 So, if you are placing new manufactured homes on anything other than a typical concrete block pier with individual footings that extend below the frost line, and a ground anchor tie down system, you have a little paper work to do.

 First off, do you follow an actual design plan for the foundation you are constructing? I know far too many installers follow  the “way we have always done it” plan. If it is a concrete slab or a purchased system from a supplier, or something entirely different, make sure there is a design to be followed and make sure you follow that design.

 Next, check through the manufacturer’s installation manual for the home. Some installation manuals provide the installer supplements that address a wide verity of alternative foundations. For example, certain manufacturers provide DAPIA approved designs on placing their homes on steel crossbeams in masonry crawl spaces and basements, and others have DAPIA approved designs for concrete slabs. Most have DAPIA approvals for alternative anchoring systems. Grab the most current manual from the manufacturer and see if your foundation is addressed. If it is, make sure you read all of the little notes and disclaimers so that you are in full compliance.

 If you can’t find any designs for the alternative foundation you utilize, call the factory’s Quality Assurance Manager and ask him to help. It is possible that the manufacturer already has designs that can help you.  Don’t ask the sales department, service department or supplier about design or code related issues. The Quality Assurance Department is your best bet.

 A word of caution, I have seen foundation products from supply houses that appear to be approved by a DAPIA, but the specific manufacturers approval is needed as well.

 So, before you get too deep into your busy season, take some time and make sure you:

1.       Have a manufacturer and DAPIA approved design that clearly addresses the foundations you construct for new manufactured home installations.

2.       Make sure you read all of the fine print, notes, instructions, and limitations of the designs you are using.

3.       Make sure you follow the designs!

4.       Make sure you have copies of these designs for your records.

5.       Take a few pictures through the process.

Bottom line, make sure you have a design from the manufacturer that has a stamp showing it is DAPIA approved for every foundation type you construct!

HUD wants to hear from YOU!

Last week the U.S. Department of Housing & Urban Development announced that they are reviewing existing and planned manufactured housing regulations. This is to better look at the cost of compliance to try and reduce the regulatory burden on anyone impacted by their regulations.

HUD is looking for comments from installers and retailers (and others)  to assist in identifying regulations that may be outmoded, ineffective, or excessively burdensome and should be modified, streamlined, replaced, or repealed.

Comments are due by February 26, 2018 and can be mailed or submitted electronically. All comments must include the following docket number and title:

Docket No. FR-6075-N-01      Regulatory Review of Manufactured Housing Rules                                                 

It is pretty easy to send comments electronically. Just go to www.regulations.gov

In the big blue search box, type in 6075-N-01. From there you can read the notice published by HUD, and when you click on “comment now” you can type in your concerns.

Should you want to mail written comments to HUD, send them to:

Regulations Division, Office of General Counsel     

Department of Housing & Urban Development    

451 7TH Street SW, Room 10276

Washington, DC 20410-0550

 

Don’t forget to include the docket number and title in your letter.

I strongly suggest that you reference each of your comments to a specific requirement under the federal regulations. For example, if you feel the requirement for the Surety Bond/Insurance (in HUD administered states) is too burdensome, make sure you reference 3286.205(d). If you think the requirements for pier construction are confusing and need simplified, reference 3285.304.

I know many installers object to the requirements for testing water supply lines 3285.603(e), drain lines 3285.604(d), and fuel supply piping 3285.605, especially since the manufacturer performed this testing at the factory. Just include the reference in your comment. You can access the HUD regulations for installation at their website or just CLICK HERE

HUD is also interested in your thoughts on placing homes on foundations in freezing climates. I know that many of you have some strong feelings on this issue.

But regardless of the specific issue, now is your chance to be heard. Keep in mind the deadline is February 26, 2018.