Let’s Talk About Installer Record Keeping

When the Manufactured Housing Improvement Act of 2000 established both an Installation Program and a Dispute Resolution Program, the responsibilities and liabilities for installers increased significantly. One of the added responsibilities was the requirement for installers to maintain records for any new manufactured homes they’ve installed. So, let’s take a look at the issue of installer record keeping as more than a regulatory obligation, but also from the standpoint of being a good business practice.

If you are an manufactured home installer in one of the 14 states where HUD operates the Installation Program, or the 24 states where HUD runs the Dispute Resolution Program, you are required to maintain records of the homes you install for a minimum of three years. If you are in a state that operates their own programs, it is likely that your state has a similar requirement.

So what type of records should an installer keep? The Manufactured Home Installation Program regulations (24 CFR 3286.314) clearly lays out what records the installer must maintain where HUD oversees the installation. Below is a summary of the requirements:

(1) The name and address of the person with whom the installer contracted for the installation work and the address of the home installed;

(2) The contract to which the installer performed the installation;

(3) Any notice from an inspector disapproving the installation work;

(4) The qualified inspector’s verification of the installation work;

(5) The installer’s certification of completion of installation;

(6) Foundation designs used to install the home

While maybe a good start, this would be the minimum that should be kept. Should you ever have to defend your installation job, you will need better records.  So, let’s make a new list of documents that every installer should have in their files:

The Building Permit Cover Sheet. I am a big fan of organizing the installation documents to provide to the building code official, and to better aid the installer in pre-planning the job. Click here for A Tool to Improve the Building Permit Application Process (from the blog on March 26, 2018).

The Complete Installation Checklist which is found towards the back of every installation manual. Or even better, the Expanded Installation Checklist (from the blog on Oct. 16, 2017) that is more detailed and covers most issues that you should be checking before driving away from the home. These checklists are going to be your best friend should you ever find yourself in the middle of a dispute.

 

 

Pictures are critically important. If you are digging footings below the frost line, how about a picture of the excavation along with a tape measure so you can show the depth? Also take pictures of the completed job. We all know that homeowners often change the landscaping around the home, or add decks, patios, etc. You want to be able to show the situation of the site grading when you certified the installation.

As a trained and licensed manufactured home installer, you know how important it is to report any problems or defects to the retailer or manufacturer. It is equally important for you to keep notes of all problems that you observed and reported.

Crossovers don’t line up? Report to the manufacturer!

Speaking of problems that you’ve reported, if the manufacturer authorized you to make repairs on their behalf, be sure to have a note to that effect in your file and a copy of the detailed invoice you submitted.

Did the fuel provider conduct the gas line testing? Make sure you give them with a copy of the required test procedures (from the installation manual), and get a written receipt from them proving the testing was successful for your file.

If you used an alternative anchoring system to stabilize the home, that is great. But be certain you have a DAPIA detail from the manufacturer showing their approval of the system.

 

It goes without saying that you will keep the designs taken from the installation manual illustrating the foundation construction, but make sure those details include notes specific to the home site. Such as soil bearing capacity, or depth of frost penetration. Indicate how you obtained this information.

I think by now you get the picture. I know that very few installers are keeping records of the manufactured homes they install. But that needs to change. We all need to take a more business minded approach to installation. When the day comes that you will need to defend your installation, you will be glad you started keeping records!

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Carbon Monoxide Alarms in Manufactured Homes

Being in the middle of the heating season, I think it is a good time to look at carbon monoxide alarms installed in manufactured homes.

It might seem logical to grab a copy of the Manufactured Home Construction and Safety Standards (AKA the HUD Code) and see what it says about carbon monoxide alarms. But don’t waste too much time flipping through the pages as the HUD Code is silent on this topic.

Since carbon monoxide alarms are not addressed in the HUD code, manufacturers are not required to provide them and the IPIA (inspecting) agencies will not be inspecting new manufactured homes to see if they are provided. But keep in mind, the HUD Code (like all building codes) only establish the minimum requirements and we can always exceed that minimum. For around $20 you can go beyond this minimum code requirement and install a carbon monoxide alarm in every manufactured home you sell or install. Let me explain.

Carbon Monoxide (CO) is a colorless, odorless gas that is produced by any appliance (or engine) that uses fossil fuels (natural gas, propane, oil, kerosene, petroleum, coal) or wood to produce heat.  If you don’t think this is a big deal, you should know that according to the Centers for Disease Control, over 10,000 people are poisoned by carbon monoxide each year, and more than 438 people in the U.S. die annually from carbon monoxide poisoning. To make things worse, a CO leak is not likely to wake someone without an alarm.

Since the HUD Code does not address carbon monoxide alarms, you would only be required to provide them in a manufactured home if your state or local government has laws or codes that require them in dwellings.  At last count, 38 states (and the District of Columbia) require carbon monoxide alarms in private dwellings either by building code or separate state law. However, this is too great a risk no matter what the codes or laws require.

Regardless of what the building codes may or not establish as a minimum, all manufactured housing professionals should want to provide the highest level of safety for the occupants of our homes. Any loss of life from carbon monoxide poisoning is tragic, but it’s a tragedy that can be easily prevented by the proper installation of a CO alarm.

 

I contend that every manufactured home with fuel burning appliances or an attached garage be provided with CO alarms. You can purchase battery powered alarms at your local home center, or ask the manufacturer to provide combination smoke/carbon monoxide alarms in their homes.

Either way, I think this is too important of an issue to overlook.

Let’s Talk About Addendums to the Installation Manuals

I have had several professional installers reach out to me lately regarding some recently issued addendums (documents or designs) to the manufacturer’s installation manuals.  So, I thought we should talk about these addendums to help installers take advantage of these alternative approaches to the installation, and possibly sound a warning on some steps that might be overlooked.

Should you receive any designs or documents from the manufacturer (or any other source) that are not a part of the installation manual that was shipped with the home, I suggest you consider the following:

These addendums, designs, or documents MUST be stamped by the manufacturers DAPIA (design approval primary inspection agency), and the particular manufacturer must be identifiable on the documents. Without these elements, these documents should not be used. Remember, only use DAPIA approved designs!!!

Samples of DAPIA stamps of approval.

Even with the DAPIA stamps and the manufacturers identification on these addendums, it is important to be certain that they are current. DAPIA approvals are always changing to keep pace with changing construction structure methods and evolving building codes. If you are hanging onto details and designs that are more than a few years old, double check with the manufacturers Quality Assurance Manager to be determine if the documents that you are using are current.

Read the fine print! Take the time to read and re-read every note on any addendum you use and be prepared to defend every step you have taken. There are often limitations that may restrict the use of certain designs. For example, many foundation addendums require a minimum soil bearing capacity of 2,000 PFS, so be certain you haven’t overlooked such limits to these addendums.

Obtain all needed support documents! For example, if the addendum is limited for use on non-frost susceptible soils, you will need to have documents in your installation file to show the soil meets these requirements. Maybe you are using designs that require you to determine the “air-freeze index, so you’ll need to gather this information before construction begins!

Don’t forget the local building code official! Most addendums require acceptance by the local authority having jurisdiction (AKA code official), so discuss the addendum with him/her during the building permit application process. Get his approval in writing (if possible). Keep in mind, you are the primary source of information for the code official. Make certain that you are both on the same page before the construction starts!

Keep good records of every home you install!

Finally, as we have talked about in the past, you are required to maintain records of every home you install for at least 3 years. Be certain to keep copies of these addendums along with your other records.