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.
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.
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.