Updated HUD Installation Program Forms

Note: This information pertains to HUD licensed manufactured home installers and manufactured home retailers that are located in, or sell new manufactured homes into states where HUD administers the Manufactured Housing Installation Program.  

Friends,

The HUD Office of Manufactured Housing has just received updated forms from the Office of Management & Budget.

With the exception of a privacy statement added to the 309 form, the only other change I noted was these forms have a new expiration date of July 31, 2022.

I encourage you to start using these forms as early as practical. I have attached them to this post for your convenience.

HUD-309 Installation Certification-Verification

HUD-307 Installer License Application

HUD-306 Retailer Report on Installer & Inspector

HUD-305 Retailer Report on Home & Home Purchaser

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Getting Involved With a Storm Damaged Manufactured Home.

Early this spring in western Pennsylvania, a severe thunderstorm  blew over a huge oak tree which landed directly on top of a two-section manufactured home. Even though the homeowners were inside the home when the tree fell, thankfully nobody was injured. However, the home was significantly damaged.

Blue tarp placed over the hole in the roof to protect the damaged manufactured home.

The homeowners did exactly what every homeowner should do who finds themselves in this situation. Once the storm had passed, they did what they could to secure their home, moved to a safe location and contacted their insurance provider.

As expected, the insurance carrier sent out their adjuster who quickly determined that the home was easily repairable and offered the homeowners a modest check to supposedly cover the cost of needed repairs. In his opinion, the home didn’t even need to be re-installed even though there was now a 2” gap in the marriage line from the impact of the tree!

At the marriage line, showing how the home separated.

In the meantime, the homeowners contacted a very reputable manufactured home business in their area who immediately recognized that the home was beyond repair. But how to convince the insurance company that their suggested repairs were inadequate? The proposed repairs might have made the home look better, but did they follow the industry practices needed to comply with the Manufactured Home Construction and Safety Standards?

Working with this retailer, we conducted our own assessment of the home and provided a written report that outlined the construction steps that are critical to maintain the structural integrity of the manufactured home. Primarily, we describe how the home must be separated to properly reconstruct the roof/ceiling assembly and close the gap. As you know, gaps between home sections would prevent the home from performing as an integrated structure as required by the HUD Code.

For example, we explained that the ceiling board must be fastened to the top plates of the side wall, marriage wall and the end wall of the home. We also laid out how the gypsum panels must be glued and fastened to the roof trusses. And that the gypsum must be treated with a vapor barrier primer type paint to replicate the original construction.

We discussed the importance of the ridge beams, roof rails and fascia boards to tie the roof trusses together. We also pointed out that the connection of the roof trusses to the laminated ridge-beam requires disassembly of the home, and that the entire ridge beam must be inspected for damage. Also, the reconstructed roof must be strapped to the marriage and side walls to withstand uplift forces.

Damaged roof trusses along ridge-beam.

After outlining these and several other problem areas, such as marriage, partition and sidewall reconstruction, we then pointed out that the home should be inspected by an independent inspection agency to review the repairs. And that when the home was repositioned onto the foundation, that the original installation instructions should be followed and a licensed installer should be utilized for the installation.

Close-up of how the roof trusses pulled away from the ridge-beam,

The local retailer was able take this report and generate a cost estimate to be included along with the estimate provided by the adjuster. Including the price of proper repairs that recognized the construction processes specific to manufactured housing, is allowing the homeowners to replace, instead of just quick-fix repairs to their home.

Should a customer of yours find themselves fighting with an insurance company when their home is damaged, maybe you can point out the construction features unique to the Manufactured Home Construction & Safety Standards. After all, a properly trained and licensed professional manufactured home installer certainly is in position to be more knowledgeable about manufactured homes than an insurance adjuster!

By the way, these folks have just ordered their new manufactured home!

Encouraging Feedback From Manufacturers

Have you ever had to tell a friend that their fly was down? Or maybe they had some broccoli stuck between their teeth? While it may be a little awkward to point out someone’s simple mistake, you know that ultimately your friend appreciated your honesty and candor. This leads me to ask installers “does the home manufacturer ever point out any mistakes or issues that you may have gotten wrong during the installation process?”. Since the installations of all new homes must be in accordance with their installation instructions, it seems to me that the manufacturer is in the best position to point out when something is overlooked or simply done incorrectly, even if that discussion may be a little awkward.

However, I continue to see too many cases where installation mistakes are routinely ignored by the home manufacturer. As a result, little problems become big problems which are far more difficult and costly to correct, and in some cases, correction is impossible.

For example: there are countless communities across the country where manufactured homes have had garages attached to the home. While an attached garage is a great feature to offer the consumer, few manufactured homes are designed to accommodate this add-on. Multiple structural and life-safety concerns can result from a garage attachment if not a part of the original design. Problems such as: improper fire separation between the garage and the living area (including windows opening into the garage space), overloading the roof, walls and foundation of the manufactured home due to the weight of the garage and potential snow on the garage roof, failure to provide an electrical branch circuit to provide power to the garage, failure to provide a carbon monoxide alarm as required by most state building codes for homes with attached garages, and possibly having egress doors leading into the garage space, to name a few.

Example of a “garage ready” home. Designed specifically to accept the on-site constructed garage.

When called upon to investigate problems in communities like this, I often wonder why the manufacturer(s) of these homes never mentioned that the homes weren’t designed for attached garages. Wouldn’t you think a good friend or partner would point that out and maybe suggest that they could design and construct homes specifically for garage attachments? But instead, too often not a word is said until the situation gets out of control.

In all fairness, there are now several manufacturers offering garage ready homes, but this is a fairly recent development.

I am sure you all have seen similar issues. Maybe you have seen manufactured homes in communities that have carports or patio covers attached directly to, and being supported by the home. Or maybe the homes have recessed porches or decks which allow rain water to flow between the decking boards and directly into the homes’ crawl space. Or maybe the homes are set in pits which collect water, instead of atop a slightly elevated site that will shed water away. I could go on, but I think you get the point.

Rain water falling onto this recessed porch has no where to go except into the crawl space. If enclosed by skirting, it must be fully vented and allow for the free flow of water from under the porch area.

I would hope that any business partner of mine would be just like that friend who lets me know when I am wearing my shirt inside out. But in the manufactured housing industry, that is not always the case.

A “pit set” and recessed porch. How will water ever escape this crawl space?

So, just who is in the best position to tell you when you missed a button, belt loop or maybe a tie-down strap? First off, I think the factory sales representative could be one of the first ones to let you know that there could be a problem. Next would be the factory’s service department. Anyone from the factory that visits your sites should be able to provide some feedback to improve the overall installation.

Too many factory representatives choose to overlook these issues or maybe they don’t know anything is wrong. I have long advocated for the training of service personnel, and with a few exceptions, they operate outside of the building code or regulations or even the manufacturer’s quality control process. While I have met quite a few really sharp sales people, many are a little weak when it comes to understanding code requirements.

So maybe it is time to start expecting more from our friends at the factory. It is not always easy to tell someone they are messing up, but that is what a good friend would do.

Installation Inspection Findings

I recently had the opportunity to inspect 20 new manufactured home installations, and I thought it might be helpful to share my observations.

The individual installers were invited to participate in the inspections and for the most part, they all did. Having the installers present to answer questions and being able to show their processes and procedures proved very beneficial. Several installers brought along their installation files which were very helpful. These documents helped to illustrate how they determined footing size and spacing, anchoring, and their self-inspection of the job through their use of the installation check list.

The most common finding (as usual) were problems with site grading. Many of the homes would have benefitted from a few lifts of fill dirt to elevate the home site. Keep in mind, the area under the home must be higher than the surrounding lot.

One installer had some issues with the installation of the alternative anchoring system, which they will need to correct. The first problem was that the long transverse arm (from the footing to the opposite side frame), was attached to the bottom of the frame (I-beam). These alternative anchoring systems are designed and tested with the transverse arm attached to the top of the frame. The top of the frame is lagged to every floor joist and as a result is stiffer and more able to handle the forces generated in a wind storm.

The transverse (long) arm must be attached to the top of the frame.

Also, when anchoring single section homes, the required ground anchor straps at each corner of the home were installed vertically. The straps were straight up from the footing to the frame as opposed to diagonally from the skirting line to the frame as generally required. Note: Xi2 will allow for vertical anchor straps if the footings are of sufficient size to support the loads, see the specific instructions for the system you are using for more details.

Only 2 wraps around the slotted bolt.

A few of the anchor straps were not wrapped sufficiently around the slotted bolt at the anchor head. In general, you need 4 to 5 wraps around the slotted bolt. None of the anchor straps had protection from the edges of the frame as needed. Check the anchoring and manufacturer’s instructions, and make sure you are properly installing whatever system you are using.

Missing strap protection at the corners of the frame.

Another concern at a few of the homes were undersized footings. The piers were placed on 18” diameter footings spaced 8’ apart. Since no determination of soil bearing capacity was made and/or documented, there was no choice but to default to a 1,500 PSF soil which would require a 24” diameter footing for 8’ pier spacing per the manufacturer’s instructions. Be certain that you can justify your foundation decisions based on soil conditions and the manufacturer’s installation instructions.

Since we are talking about foundations, I ran across a few marriage line support piers that were incorrectly positioned as they were parallel with the marriage line. These piers should be perpendicular to the marriage line.

Support pier not perpendicular to the marriage line.

I saw one home with a gas fired water heater that was drawing combustion air from the crawl space under the home. In general, all combustion air intake ducts must be extended to draw air from outside of the skirted crawl space.

The vinyl siding on the end walls of a few two section homes were installed in a manner that could restrict the movement of the siding. The siding seams were overlapped over 3”, when the instructions only allow 1/2” to 1 ½” overlap.

Look closely to see the water heater combustion air intake. Should be drawing air from outside of the crawl space.

 

Finally, one installer was having trouble with the flash rings installed in the exterior light fixtures. It is important to remember that any combustible material exposed to the canopy of the light fixture must be protected with the non-combustible flash ring provided by the manufacturer. This is important for “jelly jar”, “carriage” or other fancy light fixtures installed on vinyl, wood or other combustible siding materials. Generally, unless the light fixture canopy is the same shape and size as the junction box to which it is being installed, a flash ring is required.

Flash ring for carriage light.

Ultimately, I am thankful for opportunity to work with some great professional manufactured home installers. I was impressed with their level of knowledge and pride in their work, and hope to work with them again in the future.

As always, be sure to follow the manufacturer’s approved installation instructions for all of your installations!

HUD Manufactured Home Installer License On-Line Training Available

I am happy to announce that both my 12-hour initial training and the 8-hour continuing education training are available on-line for professional installers in HUD installation states:

Alaska, Connecticut, Hawaii, Illinois, Maryland, Massachusetts,     Michigan, Montana, Nebraska, New Jersey, Rhode Island,
South Dakota, Vermont and Wyoming
Questions? Email me at: markconte3@yahoo.com

 

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.

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.

Let’s Talk About Vinyl Siding, Part 2

In our previous post we looked at some of the common requirements regarding vinyl siding installation. Today we’ll talk about a few of the more obscure details that we need to understand to assure the vinyl siding will perform properly.

Generally, manufactured homes do not have a house wrap or weather barrier (such as Tyvek®) installed under the vinyl siding. This “house wrap” helps prevent water and air infiltration and is required in most other types of residential construction. However, it is not required by the Manufactured Home Construction & Safety Standards. A few manufacturers may offer “house wrap” as an option.

All manufacturers should be providing flashing at the corners of windows and doors to prevent any water that penetrated the siding along the frame of the window from seeping into the walls.

Window flashing intended to channel water away from the wall.

 

Most of the flashings I have seen is felt paper installed at each corner of the windows/doors that runs to the bottom of the floor. Installers should be paying attention to ensure that the flashing on the end walls is in place and intact. If the flashing does not extend to the bottom of the floor, it may be designed to channel water into the weep holes of the siding just below the window. You will have to place the flashing to overlap the nail flange to direct any water away from the wall.

Fit J channel at corners to prevent water infiltration.

Speaking of water infiltration, be sure when installing “J Channel” around windows or doors to avoid “butt joints”. “J Channel” should be trimmed, fitted and over-lapped at joints and corners (see above illustrations) to keep water away from the wall.

As we have discussed in previous posts, make certain that the installation of the skirting material does not damage the vinyl siding or restrict the ability of the siding to expand and contract with changing temperatures. In my opinion, under no circumstances should the bottom course of siding be cut off for skirting installation. Keep in mind, the home must remain transportable and if the siding is no longer attached to the starter strip, it will blow off in transit.

Do NOT cut the bottom course of siding for skirting installation.

Should you come across any damaged vinyl siding, it must be replaced. There are no repair methods to fix broken vinyl. This would also include any siding with a broken nailing flange. If the siding cannot be secured as required, it must be replaced.

Broken nailing flange, siding should be replaced.

 

As you know, vinyl siding is combustible. So, when installing exterior light fixtures on vinyl siding (or a vinyl mounting block), there should be no vinyl exposed inside the fixture that could offer fuel to any electrical fire. Unless the fixture canopy is the same size and shape as the junction box, you will need to install a non-combustible “flash ring” to isolate the vinyl from the wiring. For new homes, that manufacturer should have provided any needed flash rings.

Typical Flash Ring for a carriage light.

For more information on vinyl siding installation, check out the instructions that are provided from the manufacturer, or if not available, visit the website from the Vinyl Siding Institute at: https://www.vinylsiding.org/installation/installation-manual/

Let’s Talk About Vinyl Siding, Part 1

While a variety of materials are used as exterior wall coverings for manufactured housing, vinyl siding might be the most common. So, let’s look at some of the issues that are often overlooked regarding vinyl siding installation.

Everybody knows that vinyl siding expands and contracts with changing weather conditions, Experts say a single 12’ long piece of siding can be expected to grow or shrink up to 5/8” in length. You must allow for this movement as you install the siding on the home. Here are some key points to consider:

Siding box instructions, leave 1/32″ under nail head or staple crown to allow the siding to expand/contract.

Vinyl siding should be “hung” on the side/end walls of the home. When installing nails or staples, be sure to leave at least 1/32” (thickness of a dime) between the nail flange and the nail head or staple crown.

For horizontal panels and accessories, start installing fasteners in the center of the panel and work towards the ends. Install the nails/stapes in the middle on the nail slot. Don’t angle the fastener or use it to pull on the panel.

For vertical applications (including corner posts and “J” channels) along the sides of windows and doors, apply the first nail or staple at the top of the top most nail slot (to keep it from slipping down) and the remainder of fasteners in the center of the nail slot.

Fastener spacing is generally 16” apart for siding panels, and 12” apart for channels and accessories. If the slots and framing studs don’t align to allow you to center the fastener, use a slot punch tool to enlarge the slot,

When installing a new manufactured home, the manufacturer will be providing you with the proper nails or staples to install the siding. But, for a relocated manufactured home it will be up to you to determine that you have the right fastener for the job. In all cases, the fasteners must be corrosive resistant, such as aluminum nails, galvanized roofing nails, or galvanized staples.

Look closely, these staples are galvanized to resist corrosion.

Also, be sure the fasteners are the proper length, about 1 ¼” of penetration into the framing of the home. If the home is sheathed with OSB (oriented strand board) or some other nail-able sheathing, you can generally install some fasteners in the sheathing, but be sure to make an effort to hit every framing studs. If you are installing siding over a foam insulation, you will need longer fasteners in order to achieve the 1 ¼” penetration needed.

The thing that I believe is most overlooked in regards to vinyl siding installation is the need for utility trim. Also called finish trim or under-sill trim, it’s needed to secure the siding wherever the nailing flange has been removed, most notably under windows or doors. The utility trim should be cut about ¼” shorter than the section of nail flange that has been removed, and fastened directly to the wall, under the window, door, etc. Using a snap lock punch, punch lugs every 6” along the cut edge. When installing the panel, slip the cut edge into the utility trim to secure it in place. If your manufacturer is not providing or using utility trim, start requesting it!

Siding panels should be cut and installed allowing for about ¼” gap between the panel and the inside of the receiving “J” channel, corner post, backer block, etc.

 

Siding panels should overlap each other by 1” to 1 ½”. If you have to cut off the factory pre-cut edge, be sure to notch both the nail flange and the bottom lock to allow for lateral movement of the siding.

If the factory end is cut off, be sure to re-notch the bottom of the siding panel as well as the top!

Be sure to stagger the joints by about 12” unless separated by three courses. Don’t use short pieces that cannot be fastened to two studs. This is particularly true along the gable end, under the overhang on the end walls. The very last piece of siding at the gable can be fastened with an aluminum trim nail. Drill an 1/8” hole and don’t drive the nail tight. Snug will do it! This should be the only exposed fastener needed for siding application.

Be sure to leave enough nail flange to allow attachment at 2 studs!

Ok, that is enough for now. As always, be sure to follow the actual siding installation manual and product instructions! We will discuss this topic further in our next post!

Proposed Changes to the Formaldehyde Rule!

HUD has recently published a proposed rule in the Federal Register which would adopt new formaldehyde standards for composite wood products used in the production of manufactured homes AND eliminate the requirement for the health notice that is found in the kitchen of every new home shipped from the manufacturer.

You can read and comment on the proposal by CLICKING HERE.