Still Time to Comment on the Proposed Rule Changes

As reported in the past, HUD is proposing changes to the manufactured housing program. Several of these changes affect the manufactured housing installers and retailers. You still have the opportunity to tell HUD your thoughts, but you must act before March 31, 2020.

I believe it is critical for installers/retailers to weigh in. My previous post on this topic provides links to the proposal and instructions on how to comment. I am re-posting that information below.

Here is a short summary of some of my main concerns:

  1. Many of the proposed changes rely on the manufacturer providing additional materials and documents with the home. As you are well aware, this is a problem in our industry. I am again requesting that HUD require the IPIA (inspecting agencies) start inspecting shipped loose materials and designs.
  2. Quite a few of the proposed changes impact the responsibility of the licensed installer. However, installers are still not represented on the Consensus Committee.
  3. The proposed rules include provisions for attaching structures to manufactured home. The proposed rule change does not include provisions for the attachment of stairs to enter the home. As many of you know, this is often an issue with local building code officials.
  4. HUD has proposed establishing the design criteria of stairs for entry into a manufactured home. This new design criteria (rise and run of the stair tread), exceeds many state and local requirements and could prohibit the use of existing, prefabricated stairs and landings.
  5.  I am very concerned that these purposed rules will require the home installer to extend the water heater T&P discharge pipe to beyond the skirting. While the proposed rule is very short on specifics, I am concerned that this would result in a serious safety related hazard. The unexpected discharge of super heated, pressurized water could lead to serious injury.

The following re-post contains the links and other information needed for you to comment on these changes.

As promised, I have provided my comments to HUD concerning the proposed changes to the Manufactured Home Construction & Safety Standards. While there are many concerns with the proposed changes, l limited my comments to those that I feel have a direct impact on manufactured home installers.

I encourage you to review the proposed changes to the HUD code and submit your thoughts before the deadline of March 31, 2020. If you haven’t reviewed the proposed changes, CLICK HERE.

Also, on the right side of that page, your will see (In GREEN) the link to “Submit a Formal Comment”. You can either provide comments in the text box or attach a separate document.

Also, I am providing you with a copy of my comments for review. Feel free to use my comments as you see fit. CLICK to read my comments.

Having read over this proposed rule a few times, I am now of the opinion that these changes are really an attempt to erase the line between modular and manufactured housing. Many of the code changes (most of which I did not comment on) are written to open the HUD code to include more traditional and modular housing features (multi-story, stair geometry, duplex homes, etc.) I am not sure how you may feel about that, but I wanted to point it out to make you aware.

However, there are still plenty of issues that impact installers and retailers that should make us concerned.

Anyway, please take a few minutes and tell HUD your thoughts on these possible code changes.

 

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