Working With Code Officials Part 3-Inspections

Today we will look at the last piece of the puzzle on local code officials: The Final Inspection. That last hurdle to get the much-anticipated “Certificate of Occupancy”.

The local code enforcers I work with typically require two inspections for manufactured housing:

  1. A footing/site grading inspection
  2. A final inspection.

Not to say that sometimes additional inspections aren’t needed, but for a typical pier set, two inspections should be sufficient. Here are four things for the professional installer to consider going into the inspection phase of an installation:

  1. Don’t cover your work before the inspection!

If you want a bad relationship with your code official, go ahead and pour your concrete before the footer inspection. Remember to schedule your work with the inspector in mind!

  1. Be present at every inspection.

This is extremely important. It is akin to being on trial without showing up in court! In fact, I suggest that the installer actually direct the inspection! Trust me, I have been audited, inspected, examined, and interrogated more times than I can remember, but in each and every case, I did my very best to set the tone and direction for whatever type of oversight or inspection is occurring.

You can set the tone of the inspection by simply showing off your work.  Explain how you determined the footing sizes. Explain how the home has pier savers and that you don’t need piers at the patio door, but that the triple ganged window needs pier support. Explain how the anchoring system you use takes care of the end wall anchors. Just start with keeping the inspector engaged, and soon he will start having confidence in you, and that will pay dividends on future projects.

BUT…you MUST be present at the inspection!

3.  Have the installation details and instructions at the job site to be used during the inspections.

In my opinion, a good inspector will inspect against the documents that were provided for the permit application. Not just walk around the job site and point out what he doesn’t like.  Having these instructions with you helps eliminate confusion, and as an installer who does the job right, it helps educate the local inspector in the proper way to install manufactured homes.

If the code enforcer points out what he feels is a problem, your first reaction should be to refer to the instructions to verify the issue one way or the other. Don’t just do something because the code official told you to, stick to the designs, charts, instructions, etc. If the code official is wrong, you need to tactfully and calmly show him why you believe you are correct. Keep in mind, this is a business and we need to have a business-like approach.

Remember, if there is a problem with the installation of a manufactured home, the installer bears the responsibility, not the code official!

  1. Utilize the “Complete Installation Checklist”.

If you have been following this blog, or attending my training courses, you know that I am a big advocate of the “Complete Installation Check List” (see “A Very Valuable Tool-Jan. 6, 2017).

Just imagine the reaction of the inspector when he arrives at the job site and you hand him a checklist that is completely filled out with notes and comments to indicate that you have followed the manufacturers installation instructions.  And he can keep a copy of this checklist for his records!

Trust me, that inspector will have gained more confidence and respect for you then you could ever imagine! Presenting the completed checklist as evidence of a properly installed home will help you set the tone for the inspection, and identify you as a true professional manufactured home installer.

In closing, I understand that many professional installers don’t have a warm and fuzzy relationship with local code enforcers. But if we ever hope to improve the image of manufactured housing, I think this relationship is the most logical place to start. It is up to us to start changing mindsets, attitudes and relationships. While a few code officials might be impossible to work with, most code officials are only looking to do their job. They would much rather avoid confrontation just like you!  They don’t need extra work, and honestly don’t take pleasure in failing an inspection.

Change starts with us! Let’s improve our understanding of this entire Manufactured Housing Program and be able to explain preemption and why it is deserved. The permitting process can make or break an installation. Let’s re-examine our approach and use the tools at our disposal. And finally, get involved in the inspection process and start taking charge of our projects! And there is no better time than right now! Spring is Here!

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Working With Code Officials-Part 2 Permitting Process

Last week we talked about why manufactured homes are preempt from local and state building codes. If you haven’t read that post, see my March 13th post “Working with Code Officials-Part 1” before going on.

Today we will begin to talk about the process of getting a building permit and how important it is to a successful project. I know many installers let others (customers, retailers or community owners) take sole responsibility for the building permit, but that needs to change. Your involvement in the permitting process helps assure the project gets off on the right foot. At the very least, make sure you get copies of the documents submitted for the building permit. Then you can know what the code official expects from you!

The first thing to understand is that the vast majority of code officials are only familiar with their particular building code (in most cases the International Residential Code (IRC) or some variation). The problem is that the IRC says very little about manufactured housing (Appendix E), and what it does say is not very useful. Rarely are building code officials trained in the Manufactured Home Installation Standard (24 CFR 3285) or Program (24 CFR 3286). So, it is up to you to get them on the right track. Here are a few steps to follow:

1.       Installer License. As of June 1, 2016, all manufactured home installers must be licensed or certified by their state or HUD everywhere in the country. It is a fair bet that a lot of code officials don’t know this or don’t care. You as a professional installer have invested time and money for your right to install manufactured homes. Make sure you present your credentials as a professional installer along with every permit application. Once the code official starts expecting to see installer licenses with every permit, it will start to weed out the impostors who steal business away from you!

2.       Manufacturer’s Installation Instructions. I generally see one of two scenarios: A one page pier print that has very little usable information; or an entire installation manual containing tons of charts and details that do not apply to the job you are doing. Keep in mind the code official should be inspecting to the designs presented with the application. Highlight the actual charts you need to determine things like pier spacing, footing size, anchor system, fastening charts for multi-section, etc. If you have a design that includes a statement like “If acceptable to the local authority having jurisdiction” that means the issue in question is not addressed in the HUD code and does not preempt the local code.

3.       Understand Local Requirements. If the local code official requires three copies of the permit application, have those three copies ready. If they require a plot plan for every job, have one ready. If they require special forms for manufactured housing, have them completed and ready to hand in! If you don’t know the local requirements, most municipalities have everything you need on their web site.

4.       HUD Requirements. If you are in one of the 13 states where HUD oversees new manufactured home installations (that number is subject to change), your code official may need to sign off on HUD Form 309 (HUD Manufactured Home Installation Certification and Verification Report). Don’t surprise him with this form and expect a signature. Make sure this form is part of the permit application. Also, for more information on HUD requirements, visit: www.maufacturedhousinginstallation.com

Last week, as a few of you pointed out, changing the attitudes of building code officials is not easy. I completely agree, but it has to start sometime and there is no better time than right now.

Stay tuned, next week we will take a look at the inspection process.

Working With Code Officials-Part 1

Every time I thought about posting on the topic of working with code officials, I would get bogged down in the sheer number of issues that need to be discussed. Is the code official allowed inside the home? What can they inspect? Why is code enforcement so inconsistent? Why are we afraid of upsetting the code official? Shouldn’t the code officials know installation better than me?

There is a tremendous amount of misunderstanding, misinformation, failed communication, and worst of all, mistrust between the code enforcers and our industry.  With all of that in mind, I felt the best approach was to start with a series of short posts that hopefully will all come together and make sense.

So, to quote the Wizard of Oz, it is best to start at the beginning. For manufactured housing the beginning starts at PREEMPTION. If you are not familiar with this term, this is your lucky day!

The word “preemption” simply means that one thing takes the place of another. Think about how a breaking news story “preempts” your favorite TV show! So, the National Manufactured Housing Construction and Safety Standards (HUD Code) takes the place of (preempts) the state and local building code.

 

So, what do you think this means to the code official?  Basically, he is being asked to issue a building permit for a manufactured home without doing the things he would normally do for any other house. But the typical code official has a lot of questions. Has anyone properly reviewed the building plans? Has anyone conducted any inspections during the construction process? Is this HUD code any good? Has anyone done the things he would have done if the home was being built on site?

The code official needs education! However, we do a very poor job explaining the manufactured housing program and how manufactured homes are likely more highly scrutinized and inspected than any conventional constructed home. Because of the strength of manufactured housing program, the code officials can have confidence in homes we install.

A Manufactured home has earned the right of preemption from local building code!

Not taking full advantage of the preemptive nature of the HUD Code adds unnecessary costs to the installation of the home and does nothing to improve the image of manufactured housing industry.  If we earn the confidence of the local code enforcers, we will earn the confidence of the home buying public. And it all starts with knowing how to answer all of the code official’s questions. Explain how the plans were reviewed and stamped as proof of compliance. Explain the in-plant inspection processes, and the accountability that is in place to assure that the manufactured house is not just affordable, but safe, durable and high quality. Explain to the code officials that the manufactured housing program works on behalf of the building code official.

We need all code officials to understand that they don’t need to worry about the rough framing, plumbing, electrical and other construction inspections. All of these inspections were already conducted on their behalf.  While they can’t review all of the building plans, the plans were reviewed on their behalf. If something were to go wrong, there are mechanisms in place to get things corrected.  As a result, the code official can have confidence in every new manufactured home that comes into their town. The problem is that a lot of code officials don’t know how the program works! They need training, and the installers are in the best position to start training them!

Here are just a few of the things to consider:

·         Installers must know the installation manual! Stop saying “we always did it that way” and start following the manual, making positive changes to our installation procedures.

·         Get involved with the building permit application process. Submit details, designs or instructions that have been plan reviewed and stamped. That means a stamp from one of the agencies that does plan review for the manufactured housing program; RADCO, PFS, HWC, TRA, NTA, NEB (whoever is listed on the data plate).

·         Know the HUD code. Be able to explain why the drain lines under the home do not need insulated. Be able to explain why ARC Fault protection is not required. Be able to explain flash rings, bonding wires, closed combustion appliances, limited combustible materials at the cooking range area …just to name a few.

Ok, that is enough for now. But stayed tuned, Part 2 on this topic will post next week!

March 2017 HUD Newsletter & Spring Installer Training Dates for Pennsylvania

Earlier today HUD has issued the latest edition of The FACTs: HUD’s Manufactured Housing Newsletter and I wanted to share it with you. Click on the link to access mh newsletter – 1-27-17 (1)

 Given all the changes regarding manufactured housing installation across the country, I believe all installers should be aware of what HUD is doing regarding installation in several states. If you don’t have time to read the entire newsletter, just check out pages 3 and 8 regarding the Installation Program and page 9 regarding the Dispute Resolution Program, as both of these programs potentially impact installers everywhere.

PA SPRING TRAINING DATES

Also, the dates for the next training courses for Pennsylvania Manufactured Home Installers have been set. They are:

May 4 & 5, 2017 “Initial Installer Training” for new installers

 There are two options available for current installers needing continuing education:

May 4, 2017 “Manufactured Home Installer Training for Relocated Manufactured Homes”

Or

May 5, 2017 “Pennsylvania Manufactured Housing New Home Installation”

Contact me at: markconte3@yahoo.com for information on how to register. Class size is limited, so register early!

Clothes Dryers-What Every Installer Must Know!

Recently a friend and professional manufactured home installer purchased a new clothes dryer for his home. Looking over the installation instructions he uncovered a few very interesting requirements specific to installing clothes dryer in a manufactured home. Given that these are safety related issues, we felt we should share with all of you. In every case, review the installation instructions that are provided with the dryer being installed.

The manufactured home installation instructions and Complete Installation Checklist (see earlier post) speaks to dryer vent installation. So as the professional installer, we could be held responsible for improper dryer exhaust duct installation that occurred as a part of our installation of the home. Unfortunately, the Model Installation Standards (24 CFR 3285) don’t offer much guidance or information to follow, so we need to get familiar with the appliance producers instructions.  As always, make sure any appliance being installed is “listed” for use in a manufactured home.

I reviewed about six different dryer instructions and they all are pretty similar. Below I am listing some of the concerns that I suspect a lot of professional installers are not aware.

  1. Secure the exhaust vent to a non-combustible portion of the “mobile” home structure.

duct-instructions-2dryer-instructions-general

So, I would read that as attachment of the exhaust vent to vinyl skirting is not permitted.  I cannot think of a “noncombustible” potion of any home so I am not sure of any other options here. But a few of the instructions were slightly different and only stated that the vent be attached to the structure of the home. That is fine if the duct goes through the wall, but pretty tough if the duct goes through the floor.

  1. Metal exhaust duct system

In most cases, the dryer manufacturer requires 4” ridged metal ducts. Flexible metal ducts are only permitted if ridged ducts can’t be used. Flexible metal is NOT Mylar-foil type vents!!! Make sure the vent piping is UL listed for Clothes Dryer Exhaust Ducts.

Sheet metal screws are not permitted to be used to join the duct piping together. The screws penetrating into the duct will catch lint and create a very hazardous situation.

The dryer exhaust may NEVER terminate under the home. Always run the exhaust outside of the crawlspace.

dryer-duct-11dryer-duct-1

Ducts that are crushed or misshapen should never be used. Minimize the number of elbows and keep the ductwork as short as possible. The dryer instructions provide charts limiting the length and elbows for safe, proper operation.

dryer-duct-2

  1. Electrical Connections

A four-wire connection is required for manufactured homes. Always remember to remove the ground strap and toss it away.  Keep in mind, in a manufactured home, the ground and neutral circuits are separated. Removal of the ground (or bonding) strap, keeps them that way.

dryer-instructions-wiring

  1. Make up air

When I first read this requirement, I assumed that make up air was only for to gas dryers. Nope! In order for the dryer to properly exhaust, the appliance producers are calling for a way to introduce air into the home to make up for the air being discharged through the ducts. Negative air pressure inside the home could result and make the dryer work harder than needed.

duct-instructions-1

I fully understand that this is well beyond the control of manufactured home installers, BUT…if you ever have interior air pressure or air quality issues inside a home, allowing for make-up air to the dryer might be part of your answer. Pilot lights going out, back-drafting of fireplaces and furnaces, mold, mildew or condensation are other symptoms.

 

Ok, that is enough for now….just be sure to take a few moments the next time you install a dryer exhaust duct and make sure you are familiar with all the requirements.