Using a Manufactured Home as a Sales Office

The longer I work in the manufactured housing industry, the more I run up against too many misunderstandings that place installers, retailers and homeowners in jeopardy. So, starting with this post, and over the next several weeks, we will attempt to look at some of these issues in hopes of providing some clarification.

So let’s start with this one:

Can we use a manufactured home as a sales office?

We all know that many retailers use a manufactured home, installed on their sales lot,  as their office. Often retailers use these homes to complete sales transactions and perform the day to day operations of their business. Maybe they made some modifications to appease the local building code official, such as replacing the front door with an out-swing door, sometimes adding a ramp, maybe hanging an exit sign, or modifying the bathrooms.  But does that really transform a manufactured home into a commercial structure?

Four years ago, HUD issued a memo on this topic and they were very clear from their prospective. The memo reminds us that a manufactured home by definition is designed to be used as a dwelling and to be used by a single family. And when you think about it, aren’t manufactured homes governed by the Department of HOUSING & Urban Development?

Click Here for the HUD Memo on proper use of Manufactured Housing

That seems pretty straight forward. But that is only one-half of the discussion.

Since a manufactured home is pre-empt from state and local building codes only when it is to be used for residential purposes, you could say that the Manufactured Home Construction and Safety Standards (HUD Code) only pre-empts or replaces the state or locally adopted Residential Code.  The HUD code does NOT pre-empt the building code for commercial buildings. And certainly, a sales center/office is classified as a commercial building.  

Chapter 3 of the International Building Code, titled “Use and Occupancy Classification” describes various building uses and assigns a specific classification. Some contend that a structure used as a sales center would fall under the “Business Group” as it meets the definition of a professional services office. Others could argue that a manufactured home sales center should be addressed in the “Mercantile Group” as it is used as a “Sales Room”. Ultimately, your building code official would make the final determination. But regardless of the classification, a structure designed for the entry of the public to conduct business, (such as a home sales center) is definitely not classified as a single-family dwelling under any building code. Click on the link below to view “Use & Occupancy Classifications”. 

International Building Code, Chapter 3

So, what does this mean? It means a building intended to be used for commercial purposes, must be designed as outlined by the Building Code, not the Residential Code. The differences are significant; exit door sizes with panic style hardware, accessible bathrooms with grab bars and wheel chair accessible sinks and fixtures within reach, fire sprinklers, electrical and plumbing designs, floor and roof load demands, to name a few (while many states do not require fire sprinklers for residential occupancy, most do for commercial use).

Likewise, please don’t suggest to a potential customer that they can use a manufactured home for anything other than a dwelling. That would be misleading, and could easily get you into hot water.

Now, this is not to say that a manufacturer could not design and construct a commercial building. In fact, the commercial modular building industry is well-established, and is fully capable of designing and constructing buildings that comply with all of the code requirements for this particular building classification. Those manufacturers operate in coordination with state and/or local code enforcement and third-party inspection and design agencies that are approved for constructing commercial modular buildings.  

Bottom line, a manufactured home may only be used as a dwelling, and not for commercial purposes.  

While I have a list of a few more sensitive topics to raise over the next several weeks, feel free to send me a message if there is a particular issue that you think we should explore.

As always, feel free to comment on this or any other posts!

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