Federal Government Shutdown and Manufactured Home Installers

I have received a few emails recently asking how the shutdown of the federal government (most notably HUD) impacts the roles and responsibilities of manufactured home installers and retailers operating in states where HUD oversees the installation program.

I think it is important to know that the daily activities required by the Manufactured Housing Installation Program (24 CFR 3285 & 3286) are carried out by SEBA who is under contract with HUD. So, we can assume that SEBA is still at work processing HUD 305, 306, 307 and 309 forms and performing other related activities.

Currently the biggest impact is the issuing of installer licenses. While SEBA continues to process the forms for installer license applications, the folks at HUD issue the actual license. So, don’t expect your license to be renewed or any new licensees issued until the shutdown impasse is resolved.  

Until the federal government reopens, installer licenses are not being issued.

Regarding the reporting that is required for new manufactured homes sold and installed, (forms 305, 306 & 309) my advice is that retailers and installers should continue to conduct business just as before. Keep submitting the forms within the required time frames and keep good records! The processing of these forms is conducted by SEBA, who is currently working as usual.

Eventually, all federal government contractors will want to be paid and there could be further impact should things drag on much longer. 

It is important to remember that regardless of the when the government reopens, the requirements are still in place. A lack of enforcement or oversite doesn’t change the law. So be certain to complete the needed forms in a timely manner and submit them as usual. 

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Manufactured Homes and Attached Structures-Part 3

In this post let’s talk about some of the other structures commonly attached to many manufactured homes, starting with garages:

Home being prepared for a garage attachment in a factory.

A few years ago, HUD started taking a hard look at garage attachments and they were very clear in stating their requirements. Simply put, HUD requires that if a manufactured home with an after-market garage attachment must be designed for such attachment and that the manufacturer should request a letter of “Alternative Construction” (click here for more on Alternative Construction). This Alternative Construction (AC) letter is required to establish a process to assure that these manufactured homes (with an attached garage) will meet all applicable codes and still provide safe, durable and high-quality housing as expected under the program. Here are a few of the code requirements that must be considered by the manufacturer when designing a home for garage attachment:

  • That neither of the required 2 egress doors enter into the garage.
  • That no windows are located in the garage attachment wall.
  • That there is a fire rated wall assembly (and door) separating the garage from the living space of the home.
  • That there is a separate GFCI protected circuit to serve the garage.
  • That the addition of the garage does not impact any exhaust fans (such as range hood) air intakes (such as furnace or fireplace), plumbing venting or roof venting.
  • That the manufactured home is designed for the added weight of the garage. 

    This garage attachment was the cause of several safety related code violations.

HUD does NOT address the need for a carbon monoxide detector which is generally required under state and local building codes when any home has a garage attached. Even though the HUD Code does not provide for CO detectors, I strongly recommend one be added to every home with a garage.

 

This addition led to several code violations.

If you are considering adding a Florida room, three-season room or similar addition to a manufactured home, with the exception of the fire rated wall assembly and door, every other point raised above regarding garages must be considered. Bottom line, have the manufacturer design the home for the three-season room before you proceed!

This added roof didn’t account for the penetration in the valley! The potential for a leak is great!

 

Solar panels add unintended weight to the home!

Lately I have been seeing a lot of manufactured homes with solar panels installed on the roof. I am a big fan of alternative energy solutions, but again, we need to ask ourselves if the home is designed for the added weight. My research shows that a typical solar panel adds about four lbs. per square foot onto the roof of the home. A typical manufactured home roof truss is designed for a dead load of eight (8) PSF. That eight pounds dead load is so the roof truss can support the weight of the ceiling board, insulation, roof decking, underlayment and roof shingles. While four extra pounds may not seem like much, it exceeds the allowable dead load of the roof by 50%.

Again, make sure the home is designed by the manufacturer for the additional weight of roof mounted solar panels.

On a positive note, I have been seeing some DAPIA approved designs from a few manufacturers that are a little more flexible then previous designs when it comes to certain added structures (primarily extended or attached dormers). Be sure you read the fine print on these designs, and keep good records of the construction. Remember, the devil is in the details!

This might be a topic for a future post!