Almost 20 years ago the Manufactured Housing Improvement Act (MHIA) was signed into law establishing (among other things) requirements for the installation of all new manufactured homes.
It took roughly eight years for regulations to be written, and another eight years for the installation program to take effect across the entire country. Let’s take a look at some of the changes brought about by the “Improvement Act” to determine if things actually improved. Here are my top three issues:
Manufacturer’s Installation Instructions (24 CFR 3285)
The MHIA required that HUD, along with the Manufactured Housing Consensus Committee (MHCC) establish a “model installation standard” that serves as the basis for the manufacturer’s installation manual. As a result, every manufacturer began to adjust their installation manuals to reflect the new model.
So how did that work?
I think that most would agree that the current installation manuals are confusing, extremely complicated, overly burdensome and don’t reflect typical installation processes. As a result, I contend that the installation manuals are generally ignored by both the manufactured home installers and installation inspectors.
If you start leafing through any of the current manuals and you’ll see what I mean. For example, why can’t I use a 2” solid concrete cap block but I can use 2” hardwood? Is pressure treated lumber allowed? What size spacer is permitted? I know I can use a single block pier up to 36” high, unless it is at the corners of the home, then it must be shorter, or at the marriage line where it can be higher! Don’t get me started on footing charts, longitudinal (end-wall) anchoring, pocket penetrometers, frost protection, torque probes, loads on point, shear wall straps and floating slabs! Also, why aren’t the newer anchoring systems listed in every installation manual?
I suggest that the current installation standards be scrapped. The Consensus Committee should write an installation standard that is “performance” based (just like HUD Code). But this time, installers must be involved with the MHCC for all discussions dealing with installation. Maybe think about separate installation instructions for each type of home. Like a separate manual for two section (double wide) homes. Separate manuals with homes that require perimeter blocking or manufactured homes installed in wind zone 2 or 3. Providing only one manual with every possible scenario in the country is ridiculous! Just tell us what we need to know to properly install the actual home at hand!
And while we are at it, remove systems testing from the installation instructions. Installers should not be expected to perform the same systems testing that the manufacturer should have performed before the home left the factory. Keep in mind, the manufacturer must design and construct a home that will withstand the stresses of transportation (3280.903(a)). So, if a pipe breaks while the home is being shipped from the factory, it is the manufacturer’s responsibility.
Inspections (24 CFR 3286.511)
HUD requires that 100% of new manufactured home installations be inspected by a qualified inspector. However, no training specific to manufactured housing is required to become a “qualified inspector”. Just because a person works for a building codes department, IPIA or has an engineer’s stamp doesn’t mean they are qualified, able or willing to inspect the home installation against the installation instructions. To be fair, there are some states that do require training for code officials that inspect manufactured housing installations. However, HUD and most states do not require any such training.
In my opinion, there are far too many people inspecting manufactured home installations that lack the basic knowledge to effectively perform these critical inspections. There are too many inspectors demanding that you “Do It My Way”, while too many others take the exact opposite approach and conduct “Drive-By” inspections. Since the process has become a money-making endeavor for some inspectors, many are afraid of biting the hand that feeds them. And yes, there are plenty of really good inspectors, but it is obvious that the inspection process is certainly not uniform and does not assure that the home was installed according to the manufacturer’s installation instructions.
We could go on about problems with the inspection process, but I will stop right here. Maybe more work should be done to provide training to interested inspectors. Providing on-line resources for installation inspectors could be helpful. How about a checklist for inspectors? What about regional workshops for inspectors, and maybe HUD should be monitoring the performance of both the installers and inspectors alike? Ultimately, HUD should consider working with the International Codes Council to develop and recognize manufactured housing installation training for anyone inspecting manufactured housing installation.
Consumer Education & Installation Consumer Disclosure (24 CFR 3286.7(b)).
As a result of the MHIA, ALL retailers must provide the purchaser with a disclosure that outlines the installation requirements for their state or HUD as the case may be. Educating the consumer sounds like a great idea to me!
EXCEPT very few retailers are aware of this requirement, and even fewer retailers actually provide this disclosure. This disclosure is an opportunity to educate our customers and simultaneously market ourselves to the public. However, it is an opportunity lost.
I know that a few state manufactured housing associations inform their retailer members of this requirement, but I think that most do not. Additionally, I have not found any follow-up efforts to determine which retailers are not providing this important information.
I have always believed that the best enforcement starts with communication, and issues like this could easily be addressed by simple and on-going communication with the retailers, installers, community owners, etc. It appears that the current method of expecting the national trade groups to disseminate information to the retailers does not work.
If you want to learn more on the consumer disclosure, see my post from November 2017 (Four Things Every Retailer Must Know!) and you can actually download a sample disclosure form.
What can be done?
Understand that while it is very difficult to change the actual law (MHIA), it is not that difficult to change the regulations. But first installers and retailers will have to request that the Manufactured Housing Consensus Committee look into these issues. You can submit proposed changes via email to: http://mhcc.homeinnovation.com/
To learn more about the MHCC and see their membership roster, visit the HUD website at: https://www.hud.gov/program_offices/housing/rmra/mhs/cc1