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!