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! 

    

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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!