Update on HUD Reporting Forms & Your Comments

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

If you recall, on May 2, 2018, I posted about the expiration date of the HUD forms that retailers and installers use to comply with the HUD installation program requirements.

HUD Form clip

While it is important that you continue to use these forms and submit the information as in the past, I have recently been made aware that the Office of Management & Budget (OMB) is now reviewing these forms and is seeking input from you.

The OMB is seeking comments on whether the information that you provide HUD on these reporting forms is necessary, and if the reporting forms can be improved for HUD to properly operate the program.

I am attaching the comments that I already provided for your review if interested. Comments on MH Installation Program Reporting Requirements

Also, I am attaching the Federal Register notice with the particulars needed to submit your thoughts. Click here to see the Federal Register Notice

The deadline for comments is August 13, 2018.

Finally, if submitting via email, the email address provided in the notice appears to be in error. Try sending it to:

OIRA_Submission@omb.eop.gov

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Do Manufactured Homes Really Need Two Exit Doors?

Every time I talk with a group of building code officials, the issue of exit doors comes up. Most code officials are familiar with the requirements of the International Residential Code (IRC), which only requires one egress (exit) door per home. Many code officials mistakenly think that as long as the manufactured home has one landing and/or stairs that provide a single way of escape from the home, the code has been satisfied. The problem is, when it comes to the design of a manufactured home, the IRC is the wrong code! Instead, The Manufactured Housing Construction and Safety Standards (HUD Code) requirements must be followed – and are different from the IRC. Every professional installer needs to understand the differences. Manufactured homes are designed with two egress doors to allow occupants to escape the home in the event of fire, an intruder, a violent situation, or any other emergency.  

To make the situation worse, installers often permanently disable any exit doors where they didn’t install a landing or stairs. This is an extremely dangerous and risky practice that impedes the ability to escape the home. I know professional installers worry about increased liability, and blocking emergency escape paths puts installers at the greatest risk of all!  So, let’s examine this issue and try to better understand.

 

blocked door 1

How can someone escape through this door?

The HUD code at 3280.105 requires that every manufactured home:

  •   Have two exterior doors, remote from each other
  •   Establish a maximum 35’ path of travel from each bedroom to reach an exit door.
  •   In single section homes, the doors must be at least 12’ apart, in multi-section homes, at least 20’    apart.
  •   Must not be in the same room or group of rooms.
  •    May not open into a garage or other similar structure.
  •   May not be located where a lockable interior door must be used in order to exit.

(see 24 CFR 3280.105 for the exact requirements)

Even though the IRC (or other state or local code) is preempted from the design of the home, professional installers must reconcile the HUD requirement with the state code. The IRC-R-311.3 says that each door must have a landing or floor on each side, not less then the door width. Also, the stair geometry (rise and run of the stairs) must also comply with the IRC or whatever code the local authority has adopted.

 

blocked door 2

A landing and stairs are needed here!

Basically, every manufactured home is designed with an exit or egress system that assures that there is a continuous and unobstructed path to the outside of the home. The system relies on a minimum of two exit doors that allow occupants to escape from the home in any given situation. There are no exceptions to this important safety feature. No one, including the code official, may authorize anything less then the code requirement.  

If you are an industry professional that sells/installs manufactured homes, be certain that you fully understand the code requirements for emergency escape doors. Be certain that every home is completed in a manner to offer the occupants each and every safety feature that the code requires. And finally, if your local building code official does not understand the Manufactured Home Construction and Safety Standards, share a copy of 24 CFR 3280.105. This issue is too important to ignore.

We will explore more on this issue in our next post.

 

What’s In Your Tool Box?

If you’re like me, you can never have too many tools. But to properly and safely install a manufactured home, there are some special tools that you need to use. I though it might be helpful to put together a list of the top 11 things that every professional installer should have at every job site.  

 Angle finder with a magnetic base.

                We all know that when installing ground anchors, the angle of the straps cannot exceed 60°.  Be sure you have a tool to measure the strap angle to be certain your strap angle is correct. If you don’t have one, purchase an angle finder and  start checking the straps angle. By the way, it is always smart to snap a picture for your installer file!

 

A continuity tester.

                You know that ever installation manual requires that you perform a continuity test on all metal parts in the home that could possibility become energized. Metal parts like the chassis, heat ducts, metal light fixtures, gas lines, water heaters and furnaces, metal siding or metal roofs, range hoods, etc… A continuous path to ground must be present and you need to perform this test to verify all of these metal parts are grounded.

A continuity tester is a must!

 Continuity testerTester

A circuit tester with a GFCI trip button.

                This allows you perform the required operation test throughout the home as well as test GFCI  outlets, and assure that any slave receptacles (receptacles downstream of the actual device) are protected as well. This is also an easy way to check the operation of any switched receptacles.

Grainger tester

An apparatus to perform a water supply line pressure test.

                This device is probably going to have to be fabricated from plumbing parts. It must include a gauge that can measure pressure, and inlets with shut off valves to allow you to introduce water and air pressure into the water piping. Remember to remove the source of air when conducting the test. 

 H2O testing

A manometer (or other testing gauges that measure in increments not greater than 1/10 lbs.) to conduct gas line testing.

                By now you should know about the two required gas line tests; the high-pressure test (3 psi) that checks the piping and the low-pressure test (6-8 oz or 3/8 to 1/2 psi or 10” to 14” of water column) that checks the entire system as well as the connections to the appliance.  Again, this may be an apparatus  you assemble yourself, or maybe purchase an electronic, digital version. If someone else (like the fuel provider), performs this test for you, make certain to provide them with a copy of the proper test procedures from the installation manual, and get receipt or other written proof that the test was conducted for your files.  

 DSC02976

GFCI protected extension cords.

Working in often damp or wet conditions, with a great possibility of cords being stepped on, frayed or otherwise damaged, you want to reduce the risk of electric shock hazzard. All extension cords must be equipped with Ground Fault protection.gfci-power-extensions-tower-manufacturing

A thermometer to check the water temperature at each of the bath tubs, bath tubs/showers or showers.

                Run the water in each tub or shower fixture for 1 minute at the hottest setting and use a thermometer to assure that the water temperature is not greater than 120°. While the fixtures are generally pre-set, I have seen defects that allowed the water temperature to exceed 120°. Don’t take the risk, test the fixtures.

H2O thermometer

A glue bottle.

                In the event that you ever need to replace a wall panel, section of the ceiling, or a section of the floor decking, it is critical for you to glue the panel or decking to the framing members. A ¼” bead of PVA glue (white glue) is generally sufficient.

wood glue

Go/No Go Gauges for water supply lines.

                If you ever have to install a crimp ring on a water supply line, you need to assure that the crimp is done properly and Go/No Go gauge is the only way to do that!

 go No Go

Safety Glasses

                Everyone working at the job site must wear safety glasses. Having a few extra pairs handy is a great idea.  If your crew likes to wear sunglasses on the job site, make sure that they are equipped with shatter resistant lenses and side shields. 


safety glasses

First Aid Kit.

                Every good set crew has a fully equipped first aid kit available. If you don’t have one, a basic kit runs only about $30.

 first aid kit

I am sure that there are some other important tools that I am forgetting. Feel free to drop me a message if you can add to this list.

Embedment Factors? Cohesive Soils? Let’s talk about it!

Looking over a recently revised manufactured home installation manual, (DAPIA approved in Feb. 2018),  I ran across something that I thought was worth a closer look.

In the section of the manual that talks about footings, I found a chart titled “Foundation Embedment Factors for Cohesive Soils” (there is also a chart for Non-Cohesive Soils).

In case you are wondering, cohesive soils are described as clay, or soil with a high clay content, which has cohesive strength. Cohesive soil does not crumble, can be excavated with vertical sides, and is like plastic when wet. Cohesive soil is hard to break up when dry and sticks together when submerged. Cohesive soils include clayey silt, sandy clay, silty clay, clay. 

main-qimg-f089365f7a3cf3c9d2f0a1e78f6c0c53-c

Cohesive Soil

 

On the other hand, non-cohesive soils are loose soils like sand, or sandy soils.

Ultimately, by using these charts and directions, you can increase the maximum load per footing based on the depth that the footing is embedded in the soil.

Let’s try to work through the process.  This manufacturer tells me that a 14’ wide home, in the south (20 psf) roof load zone, with piers spaced 8’ apart, has a pier load of 5640 pounds (per pier).

Image (54)

Since I like to auger round footings, the chart for circular shape footings says that I need a 28” round footing at a soil bearing capacity of 1,500 PSF. But my auger is only 24” diameter! Well, this is where the “Foundation Embedment Factors for Cohesive Soils” chart might come in handy!


Image (55)

Since I can only dig 24″ round footings, I need to start there. The chart for circular footings tells me that a 24” round footing can carry 4710 pounds (again 1,500 Soil bearing capacity). I know my 24” round footing will be 36” deep (for example, to get below the frost line) in a clay (cohesive) soil, so I can multiply the 24” footing capacity by the 1.56 as indicated in the cohesive soils chart and my 24” footing works! (4710 pounds x 1.56=7347 pounds, well beyond the 5640 pound load needed to support the home).

Image (56)

 

It is not as confusing as it seems. You just need to know if your soil is cohesive (clay) or non-cohesive and know the footing size and depth. Use the chart to determine the embedment factor and multiply the footing capacity by the factor from the chart.

A few important things to consider before you start reducing footing sizes. Currently, this is specific to only a few manufacturers. You need to check with the Quality Control Manager at your factories to see if they allow you to utilize embedment factors. One manufacturer told me that they provide these designs only upon request.

Next, you need to have a very thorough understanding of the soil at the job site. You need to have all of your documents in order and make certain that the building code official (and possibly the purchaser) understand how you are calculating these footings sizes/loads. As always, keep good records for your installation files, including copies of these charts.

While I am not an engineer, I do think that the embedment factor is to be applied only to poured in place concrete footings. But you can verify that with the factory. 

Finally, on the one manual I reviewed, there is a big typographical error, labeling the chart for non-cohesive soils, so be cautious. Stay in touch with Quality Control folks and watch for further changes to the manuals.