New Installer Resource & Upcoming Training Available

I was just made aware of a new installer resource from Clayton Homes, and according to their introduction it is “intended to increase awareness of the importance of site construction in the manufactured housing industry”. I found a lot of very good information at the website, and I appreciated the illustrations and drawings. Be sure to check out the topics found under the “BLOG” tag and take a few minutes to watch the short videos. Good Stuff! Make sure you sign up for their quarterly newsletter. Click Here for the link.

Also, I wanted to make you aware of some upcoming training dates:

Continuing Education for HUD Licensed Installers is being held in Novi, Michigan on October 9, 2019. Contact Scott at the Michigan Manufactured Housing Association at 517-999-6877 or swalsh@mmhrvca.org

Three initial (or pre-licensure) trainings for installers wishing to receive their HUD Manufactured Home Installer License are being held over the next few months:

October 28 & 29, 2019, in Okemos, Michigan HUD Installer Training Registration-Oct 2019- Michigan

November 7 & 8, 2019 in Camp Hill, Pennsylvania HUD Installer Training Registration-Nov 2019, PA

November 14 & 15, 2019 in Clarion, Pennsylvania HUD Installer Training Reg Clarion PA -Nov 14 15, 2019

And as always, both initial and continuing education trainings are available online at HERE

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Pennsylvania Suspending Installation Program

As predicted, the Pennsylvania Department of Community & Economic Development (DCED) is suspending their manufactured housing installation program. As a result, there are several important considerations for both installers and retailers.

While everything is subject to change, currently the effective date for this suspension is set for October 1, 2020. However, the transition will begin almost immediately.

As of October 1, 2019, Pennsylvania will no longer issue installer “certifications”. However, installers can continue to operate under their current PA Installer Certification until it expires. Upon expiration, installers will need to acquire a HUD Manufactured Home Installer License. With that said, installers need to know that the HUD Manufactured Home Installer License is valid for three (3) years and there is no cost for the actual license.

Sample HUD Installer License

 

Over this transition period (Oct. 1, 2019 to Oct. 1, 2020) the Pennsylvania Certificate of Compliance will continue to be utilized and can be signed by either a PA Certified Installer or a HUD Licensed Installer. Starting October 1, 2020, installers will need to complete and submit the HUD 309 form for new manufactured homes that they install.

The Pennsylvania Certificate of Compliance form will be modified and will continue to be utilized for relocated manufactured homes.

Retailers selling new manufactured homes for placement in Pennsylvania will need to begin completing the HUD 305 and 306 forms as of October 1, 2020.

In order for installers to qualify for a HUD issued license, they must complete a 12-hour HUD approved training course. There are a few options available: two on-line HUD approved trainings (Certified Training Institute Click Here and MHEI), and there are 3 approved classroom trainers.

I have already begun scheduling HUD approved training classes in Cumberland, Clarion, Centre and Lehigh Counties. The first course is set for November 7 & 8, 2019 in Camp Hill (Harrisburg area). Click Here HUD Installer Training Registration-Nov 2019, PA. The dates and exact locations of the other trainings will be announced in the very near future. Additional classes will be added as needed.

I encourage all Pennsylvania installers and retailers to visit the HUD Installation Program website (click here) for additional information, and for forms needed for the HUD Installation Program.

Feel free to email me with questions.

This is an unofficial explanation of the situation based on information at hand. Please refer to the Pennsylvania Bulletin (Sept 7, 2019) for the official announcement. 

Also, if you are currently registered for a Pennsylvania Installer Training Course, I will be contacting you soon to discuss the available options. 

Is Everyone Playing By the Rules?

Not a week goes by when I don’t hear from an installer or retailer that is upset because they are losing jobs, and as a result money to competitors that aren’t playing by the rules. Maybe unlicensed installers are working in the area. Maybe the footings they are digging are too small or too shallow. Maybe they are cutting corners on the anchoring of the homes they install. Maybe they are not performing the required testing. Maybe they aren’t doing all of the required paperwork. Maybe they aren’t having their installations inspected, or maybe they are forging the signatures on the installation forms.

How can you compete and still do a quality job?

Let me tell you, it is tough, very tough! Just as sure as there will always be speeders on the highway, there will always be a few dirty dogs in the manufactured housing industry. The end result is the reputation of the entire industry suffers, and opportunities and profits are lost!

Now, I will admit that I don’t have a perfect plan to stop cheaters from stealing your business, but I do have a few thoughts that I would like to share with you.

I contend it all starts with educating the consumer. One of the best ways to educate potential customers is by handing every person that walks into your sales lot a well-designed, easy to read, consumer disclosure brochure. You all should know that this consumer brochure is a national requirement, but far too many retailers/installers underestimate how powerful a tool these brochures can be. You can make these brochures serve a dual purpose: a regulatory requirement as well as an educational/marketing tool!

The brochure that I have made available is a good place to start, (see the blog post from November 13, 2017 or click: Consumer brochure). You will need to customize it for your own use. This installation brochure is step one to getting the customer to understand that you are a professional installer and/or retailer and that you are worth the extra cost.

Next, if you are lucky enough to have a working relationship with a building code official (yes, lucky enough), then educate them! A well-educated code official can stop the corner cutters right at the building permit application process! For years I have encouraged good installers and retailers to start showing code officials what documents should be expected for the permit application process. For decades, the manufactured housing industry has been reluctant to engage code officials and as a result, little has changed. We actually have a good product and a good program that protects the interests of everyone. It is time to start showing it to the code enforcement community. If the code official starts expecting every other manufactured home installer to come up to your quality of work, that will mean trouble for the competition. Remember, a rising tide lifts all boats!

What about enforcement? I know nobody likes being inspected or monitored, but just like going to the dentist for your regular visit, enforcement is a necessary evil. Start demanding that the folks that placed these costly requirements on your business take steps to assure that everyone complies. That can happen several different ways, but it needs to happen and it doesn’t have to be just inspections. It can begin with regular, on-going communication. Maybe regional meetings between regulators and installers. Quarterly newsletters on enforcement actions with maybe some input from home and product manufacturers on recent changes. How about a few installers working together to form peer review groups? Sounds crazy, but why not? Doing nothing, changes nothing.

A lot of requirements have been placed squarely on the shoulders of the installers and retailers, without much input or feedback. I can tell you there will only be more to come, and as professional manufactured home installers we need to get involved and have our concerns heard and start thinking outside of the box.

There is a Manufactured Home Consensus Committee (MHCC) meeting scheduled for October in Washington DC. I don’t know if any installers are invited, but I sure hope so. If you are interested in attending and speaking at this meeting, or just learning more and possibly become a member of the MHCC, CLICK HERE .

As I have said before, you’re either at the table or you are on the menu!

New Jersey Ends Manufactured Housing Program & Why This Should Concern You!

In case you haven’t heard, as of today (August 5, 2019), the state of New Jersey is ending its partnership with HUD as a “State Administrative Agency” or SAA. One of the results of this action, NJ code officials no longer have authority to issue permits and perform inspections of manufactured housing installations. A summary of the new rule states that “the Federal government will be responsible for oversight of the installation of manufactured homes in the State of New Jersey”.

When I read over the NJ rule, they seemed to tie the entire issue to HUD not accepting their existing installation program. I truthfully don’t understand how failure to meet the installation requirements led to this, but regardless, the rule is now in effect.

Read the Rule Here.

You may be thinking, unless you are doing business in the Garden State, that this change in New Jersey doesn’t have anything to do with you. Maybe you are right…but maybe this is a sign of things to come. New Jersey isn’t the first state to drop out recently, and I doubt it will be the last. I can’t help but believe that the manufactured housing industry needs more state (and as a result) local government involvement, not less. So, lets talk a little bit about this current relationship between the states, HUD and the Manufactured Housing industry and see if we can identify some problem areas.

As is the case with most relationships, a lot of problems start with money. I vividly recall that 25 years ago, when I first met the NJ Program Manager (Paul S., long since retired), he had two major concerns. The first was the “Alternative Construction” process and how it was never properly implemented, and the second was lack of adequate funding to run the program. Since NJ is not a production state (there are no factories), the funding that NJ received from HUD was not sufficient to pay his wages. In fact, Paul had to split duties between running the NJ Manufactured Housing Program and overseeing the safety of amusement park rides. Even states with a number of production plants have a hard time supporting their SAA staff with their share of the label fees that HUD collects from the plants. So maybe HUD needs to provide more financial support to their state partners. To be fair, I know that there has been some effort recently to increase state funding, so keep your fingers crossed that it comes about sooner than later.

Next issue to examine is the perceived value. Do the state legislators and the government policy offices see a value in maintaining a Manufactured Housing Office? You know, the Federal Manufactured Home Procedural & Enforcement Regulation is clear that if a state decides not to perform the functions of a SAA, that HUD MUST do it (24 CFR 3282.502)! State governments are always looking for ways to reduce the number of employees. So why not get out of the Manufactured Housing Industry and let HUD handle things? Generally, the job of the SAA is not sexy, doesn’t get a lot of press coverage and does very little to help get any votes for elected officials. So, unless someone can convince the folks at the top state level that SAA’s have an important function, they are at risk of becoming extinct.

What about the limitations of the Manufactured Housing Program? Specifically, that this entire program excludes relocated homes! If you sit down and talk to most building code officials and similar government regulators and tell them that HUD has this wonderful oversight program, but the program ends with the completion of the sale to the first purchaser, they would be shocked! There are a few states that have specific requirements for relocated manufactured homes, but most do not.

What about the states and local governments that just don’t understand the Manufactured Housing Standards? If you read over the NJ rule, it is obvious that they are assuming that certain things will be covered under the HUD Installation Program, but that in reality several issues will not addressed. Issues such as the connection to utilities, set back requirements, soil issues, add-ons, and not to mention the obvious issues like carbon monoxide alarms.

I think it is time that the folks at HUD and the Manufactured Housing Consensus Committee start thinking outside the box. Maybe establishing guidance for handling relocated manufactured homes! And while we are stepping outside of the box, how about some guidance for local code enforcers and zoning officers? I know things like this are not required under the current regulations, but they aren’t prohibited either. I guess it boils down to who the program is intended to benefit? Is it the residents of new and relocated manufactured homes or is it the manufactured home industry.

If this program is intended to solely benefit the industry, then I can’t blame New Jersey for ending their program. But if the program intends to protect the residents of all manufactured homes, both new and relocated, maybe we should be looking at new ways to improve the state/federal relationship.

Sharing More Inspection Findings

I spent the best part of last week looking at a bunch of manufactured homes in a very large community. Unfortunately, they had some very large problems.

Granted, every home I looked at was out of warranty, and some were 10 years old. But how long should a foundation last?  The homeowners had been reporting problems since day one. I can’t help but think of all the missed opportunities to identify these problems early on in the process. For unknown reasons, everyone dropped the ball starting with the installer, developer, local code official and the manufacturer. Now the situation is completely out of hand.

Below are some pictures I took to illustrate the problems. I offer these so you can examine your own practices and make any needed improvements sooner than later.

Front elevation of a typical home. Too bad the added porch roof rests on the roof of the home. Not independently supported.

 

Another after market addition adding weight to the home. Also, check out the site grading!

 

Inside the crawl space of every home…water! Also, who cut the crossmember?

 

 

 

 

 

 

This is a different home, the rust on the frame is out of hand!

 

More water, more bent crossmembers!

 

 

 

 

 

 

Typical anchor head severely rusted & the straps are not wrapped around the slotted bolt! BTW…Wind Zone 2!

 

Typical anchor/strap attachment to the home. Must be attached to the top of the beam and wrapped completely around.

 

The source of the water? Every home is placed on a concrete slab about 12″ below grade. The skirting enclosure does not keep out the water.

 

 

 

 

 

 

 

The skirting sits on a wood sill (below grade), which wicks water directly into the crawl space

 

There are many other issues with the installations at this community, but the “pit sets” are the most critical. I will share some of the other issues in future posts.

 

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

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