Let’s Talk About the IPIA

In our last post we talked about the design approval process and the role of the DAPIA in the Manufactured Housing Program. Today we should talk about the inspection process, and the role of the IPIA.

The term “IPIA” stands for “Production Inspection Agency”. Simply put, the role of the IPIA is to determine if the manufacturer is capable of following their quality control procedures (which were approved by the DAPIA), and then to provide on-going surveillance of the production process.

There are currently 13 IPIAs authorized by HUD. Five private agencies: HWC, NTA, PFS, RADCO & TRA, and the eight states that operate as IPIAs for factories in their respective states. The state IPIA agencies are: Arizona, Florida, Georgia, Idaho, Nebraska, Oregon, Tennessee and Washington.

IPIA Inspector in the factory.

IPIA Inspector in the factory.

Before we start talking about the inspection of manufactured housing, we all need to understand that the primary responsibility to conduct inspections belongs to the manufacturer! It is the manufacturer that “certifies” that the homes they produce comply with all applicable standards. Their quality control process requires that every step along the production process be inspected by their own people, and they document these inspections on their quality checklist. At the last stage of production, the manufacturer performs electrical, plumbing and fuel line testing and attaches the certification label. Post production, the manufacturer must review all the information they received in order to evaluate if their homes are performing as required by the Manufactured Home Construction & Safety Standards.

Now, the IPIA is responsible for determining if the manufacturer is capable of following their quality control processes so they can build manufactured homes that meet the standards, and providing on-going production surveillance to assure they continue producing complaint homes. Basically, IPIAs are keeping watch to be sure the manufacturer carries out the inspections that are outlined in the quality process.

Typically, the IPIA inspector will inspect each manufactured home one time during its production process. So, depending on the size of the facility and the number of homes being produced, an IPIA inspector may only visit a plant once every few weeks, every couple of days, or if needed, every day.

Just as the manufacturer documents their internal inspections on the checklist, the IPIA maintains detailed records as well. They document every problem they find in every home being produced, as well as the steps the manufacturer takes to correct these problems, including the source of each breakdown in the quality process. If the IPIA finds too many problems in a particular area of the plant, they can increase inspections until things improve.

The IPIA also looks over the manufacturer’s service records to make sure the manufacturer is performing the proper analysis of information received from outside sources. Not just customers, but also installers and retailers as well! That is why it is so important that you report any problems you encounter back to the manufacturer for handling.

Just as they do with the DAPIA’s, HUD also evaluates the performance of the IPIA’s. Using a contractor, teams of auditors go into each factory to see if the IPIA is providing proper oversight. HUD then generates a performance review, and provides recommendations if the IPIA is under performing.

Anytime you want to know who the IPIA is at a particular factory, take a look at the label on the home. The first three letters stamped into the label are an abbreviation for the IPIA operating at that plant.

“PFS” on this label indicate the IPIA in the plant.

I personally believe that the manufactured housing inspection process is pretty good and just as effective as the inspection process for site-built housing. Most states require a very similar process for their state labeled modular homes.

But I do believe that there is one area in need of improvement that directly impacts manufactured home professional installers. HUD does not require that the IPIA inspect the materials and documents that are shipped loose in the home. In my opinion, this has made things more difficult for not only the retailers and installers, but ultimately for consumers. As you know, often missing materials or conflicting information can be supplied with the home. With that mind, you must be certain to report any and all problems you encounter with ship-loose materials and documents.

Ok…hopefully this post and the previous post can help you better understand how manufactured home production is regulated. There are processes in place for review of construction designs, quality procedures, and to oversee the inspection process on every manufactured home before being released from the factory.

But the most important steps to assure that every new manufactured home will be safe, durable, high quality and affordable must be taken by you! As the professional manufactured home installer, it is your responsibility to follow the installation instructions for every home being installed and provide feedback to the manufacturer for problems that you may find.

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Let’s Talk About the DAPIA

During most training classes, I provide a brief explanation of the inspections that are required for the production of manufactured housing. It occurred to me that most installers and retailers don’t really have a good understanding of these processes, so let’s take a closer look.

Just like any other type of residential construction, manufactured homes undergo both design / plan reviews as well as inspections of the actual construction of the home. To perform these two functions, the U.S. Department of Housing & Urban Development (HUD) utilizes “Primary Inspection Agencies” (PIA). These PIA’s perform surveillance of the production process in the factories and review designs and details to see if they meet the Manufactured Housing Construction and Safety Standards (HUD Code). A PIA can be either a part of state government or a private agency.

There are two types of PIAs, the DAPIA and the IPIA. Today we will try to give an brief overview of the role of the DAPIA.

The acronym DAPIA stands for Design Approval Primary Inspection Agency. There is only one state (Nebraska) that performs the DAPIA function. In the rest of the country, each manufacturer must contract with one of the 5 agencies that HUD approves for the task of design review and approval. You have seen their stamps of approval on installation manuals. A stamp of approval from any of these five private agencies; HWC, NTA, PFS, RADCO, TRA, and the state of Nebraska, is equivalent to an engineer’s stamp used in other construction types.

The main premise of the DAPIA process is that the home manufacturer must document all of their construction drawings, floor plans, calculations, installation details and in-house “Quality Assurance” procedures and submit them for review. If determined to meet the Manufactured Housing Construction and Safety Standards, the DAPIA will stamp these documents as “approved”.

This process is similar to the plan review conducted by a local code official who reviews building prints to see if they meet the local or state code. When new manufactured home designs are stamped as “DAPIA Approved”, the local code official can be confident that when the home is constructed and installed according to these approved designs, it will meet the federal HUD code.

Each DAPIA had to go through an application process to show that they are qualified to perform this function prior to receiving their approval from HUD. After initial approval, each DAPIA undergoes a yearly performance review. HUD (through a contractor) collects information and checks samples of designs for errors or violations. HUD can then make recommendations for each DAPIA to improve their performance if they aren’t doing a good job. They can even disqualify a PIA if the recommendations and corrective action do not led to improvement. To the best of my knowledge, only one PIA has ever been disqualified since 1976 when the program began.

I personally feel that the DAPIA program works great for the construction in the factories, but not so much for installation. Below are my two main concerns of the DAPIA process as it relates to installation.

One area of the DAPIA program that does not work well for installation is the lack “Design Control”. Home manufacturers routinely modify, create and delete installation designs. Out dated designs are removed from the process. However, there is little or no procedure to provide notice to the installers or retailers of these changes. As a result, installers often work from obsolete designs. There is a mistaken assumption that installers wait for the latest installation manual to be delivered with the home when it arrives at the site. However, most installers plan their installations long before the home is ever delivered. As a result, too many installers are relying on installation designs that are no longer applicable for the home. If you have been using the same installation designs for a long time, it is a good idea to check with the factory Quality Assurance Manager to see if the designs you use are still current and ask him to let you know about all future changes to the installation manual.

Secondly, most agree that the current DAPIA approved installation instructions are not “user friendly”. It is very easy for the most experienced installer to get lost paging through the maze of charts, columns and rows of data and countless footnotes. As a result, many installers and building code officials reply on old, outdated methods, single page pier prints, or just “the way we have always done it”. I believe that the current “one-size fits all” installation manuals that are commonly used today are too complicated and cumbersome to be an effective tool for installers. Maybe someday both DAPIA’s and manufacturers will work with the folks that actually install manufactured homes to write a streamlined, easy to use installation manual. Until then, consider using a building permit cover sheet to help organize and make sense of the installation instructions. Click the link below for a sample you can use.

MH Building Permit Coversheet

You can learn more about the responsibilities of the DAPIA at 3282.361 of the Manufactured Home Procedural & Enforcement Regulations HERE.

Next time, lets talk about the inspection agencies, known as the IPIA.