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.

 

Overlooked Support Piers

I recently came across another situation where the “pier print” provided by the manufacturer was in error and resulted in a pretty significant problem along the marriage line of the home.

Those of you that I have worked with in the past know that I am not a fan of pier prints. This is primarily because they are not reviewed by the design approval agencies-DAPIA’s. As a result, they often miss some important marriage line and side wall supports for the home. One thing every pier print does contain is a little note telling the installer to always refer to the installation manual. That way, if a problem pops up, it is the installer who takes the blame.

Typical pier print-where is the DAPIA stamp of approval?

 

So, let’s look at a few problem areas that are often overlooked and should be checked against the specific DAPIA approved installation manual. Remember, while installation manuals look alike, there are variations that can lead to big problems if overlooked.

An excerpt from a typical installation manual. But, there are variations that you need to know!

 

Almost every manufacturer’s installation manual requires support piers (with footings) for manufactured homes with fireplaces installed along the side wall or marriage wall. Rarely are these shown on any pier print, and I have not seen them on any actual installations. However, every manual I have checked requires them. Installers would be wise to start including a support pier under the rim joist for homes with fireplaces at the marriage wall or side wall. Maybe an adjustable outrigger? While I have not seen this in the installation manuals, it would be worth asking the manufacturers to approve.

Watch for unusual window configurations!

Everyone knows that openings in the side wall or marriage wall wider than four feet require supports, but often overlooked are multiple windows that are ganged together with mullions. If there are not studs separating each window, it is likely that pier supports will be needed. Be alert for other unusual window configurations that may be 4’ wide, often over a kitchen sink.  These need support as well.

Kitchen window that needs support!

 

Certain manufacturers want you to provide “intermediate supports” at any marriage line span greater than 10’. I have seen these shown on a few pier prints, but not consistently. So double check the manual to see if you need to provide intermediate supports along the marriage line.

Speaking of marriage lines, when it comes to piers and footings under marriage line openings, a good number of manufacturer’s installation manuals have a little note that is overlooked by many installers. The note says that “if the support is shared by spans on both sections of the manufactured home, add the loads together”. In essence, the load shown in the chart is only for one of the two home sections. Therefore, you may need to double the load from the chart when the marriage line opening is on both the A & B sections. This is a manufacturer specific issue.

Another often overlooked area is where the “through-the-rim” crossover ducts penetrate the rim joist at the marriage line (except perimeter frame homes). Quite a few manufacturers call out for these supports in the installation manual, but rarely do they show up on any pier print or even marked under the home as a needed pier location.

Improperly installed G strap and pier.

 

G straps (shear wall straps), are not utilized by many manufacturers, but I see them enough to warrant mention. I don’t recall ever seeing them with the proper pier/footing. Even if you are using an alternative anchoring system, if the home is designed with these G straps, they must be provided with an anchor, strap and often a pier. These G straps have more to do with the transfer of wind load through the structure than anchoring the home to the ground.

Watch for G straps!

 

Ok, I know this can become a little confusing, but it is definitely worth a harder look. As always, refer to the specific installation instructions for the home you are installing. Read all of the notes, and if you are unsure, call the Quality Assurance Manager at the factory.

Let’s Talk About Installer Record Keeping

When the Manufactured Housing Improvement Act of 2000 established both an Installation Program and a Dispute Resolution Program, the responsibilities and liabilities for installers increased significantly. One of the added responsibilities was the requirement for installers to maintain records for any new manufactured homes they’ve installed. So, let’s take a look at the issue of installer record keeping as more than a regulatory obligation, but also from the standpoint of being a good business practice.

If you are an manufactured home installer in one of the 14 states where HUD operates the Installation Program, or the 24 states where HUD runs the Dispute Resolution Program, you are required to maintain records of the homes you install for a minimum of three years. If you are in a state that operates their own programs, it is likely that your state has a similar requirement.

So what type of records should an installer keep? The Manufactured Home Installation Program regulations (24 CFR 3286.314) clearly lays out what records the installer must maintain where HUD oversees the installation. Below is a summary of the requirements:

(1) The name and address of the person with whom the installer contracted for the installation work and the address of the home installed;

(2) The contract to which the installer performed the installation;

(3) Any notice from an inspector disapproving the installation work;

(4) The qualified inspector’s verification of the installation work;

(5) The installer’s certification of completion of installation;

(6) Foundation designs used to install the home

While maybe a good start, this would be the minimum that should be kept. Should you ever have to defend your installation job, you will need better records.  So, let’s make a new list of documents that every installer should have in their files:

The Building Permit Cover Sheet. I am a big fan of organizing the installation documents to provide to the building code official, and to better aid the installer in pre-planning the job. Click here for A Tool to Improve the Building Permit Application Process (from the blog on March 26, 2018).

The Complete Installation Checklist which is found towards the back of every installation manual. Or even better, the Expanded Installation Checklist (from the blog on Oct. 16, 2017) that is more detailed and covers most issues that you should be checking before driving away from the home. These checklists are going to be your best friend should you ever find yourself in the middle of a dispute.

 

 

Pictures are critically important. If you are digging footings below the frost line, how about a picture of the excavation along with a tape measure so you can show the depth? Also take pictures of the completed job. We all know that homeowners often change the landscaping around the home, or add decks, patios, etc. You want to be able to show the situation of the site grading when you certified the installation.

As a trained and licensed manufactured home installer, you know how important it is to report any problems or defects to the retailer or manufacturer. It is equally important for you to keep notes of all problems that you observed and reported.

Crossovers don’t line up? Report to the manufacturer!

Speaking of problems that you’ve reported, if the manufacturer authorized you to make repairs on their behalf, be sure to have a note to that effect in your file and a copy of the detailed invoice you submitted.

Did the fuel provider conduct the gas line testing? Make sure you give them with a copy of the required test procedures (from the installation manual), and get a written receipt from them proving the testing was successful for your file.

If you used an alternative anchoring system to stabilize the home, that is great. But be certain you have a DAPIA detail from the manufacturer showing their approval of the system.

 

It goes without saying that you will keep the designs taken from the installation manual illustrating the foundation construction, but make sure those details include notes specific to the home site. Such as soil bearing capacity, or depth of frost penetration. Indicate how you obtained this information.

I think by now you get the picture. I know that very few installers are keeping records of the manufactured homes they install. But that needs to change. We all need to take a more business minded approach to installation. When the day comes that you will need to defend your installation, you will be glad you started keeping records!

Carbon Monoxide Alarms in Manufactured Homes

Being in the middle of the heating season, I think it is a good time to look at carbon monoxide alarms installed in manufactured homes.

It might seem logical to grab a copy of the Manufactured Home Construction and Safety Standards (AKA the HUD Code) and see what it says about carbon monoxide alarms. But don’t waste too much time flipping through the pages as the HUD Code is silent on this topic.

Since carbon monoxide alarms are not addressed in the HUD code, manufacturers are not required to provide them and the IPIA (inspecting) agencies will not be inspecting new manufactured homes to see if they are provided. But keep in mind, the HUD Code (like all building codes) only establish the minimum requirements and we can always exceed that minimum. For around $20 you can go beyond this minimum code requirement and install a carbon monoxide alarm in every manufactured home you sell or install. Let me explain.

Carbon Monoxide (CO) is a colorless, odorless gas that is produced by any appliance (or engine) that uses fossil fuels (natural gas, propane, oil, kerosene, petroleum, coal) or wood to produce heat.  If you don’t think this is a big deal, you should know that according to the Centers for Disease Control, over 10,000 people are poisoned by carbon monoxide each year, and more than 438 people in the U.S. die annually from carbon monoxide poisoning. To make things worse, a CO leak is not likely to wake someone without an alarm.

Since the HUD Code does not address carbon monoxide alarms, you would only be required to provide them in a manufactured home if your state or local government has laws or codes that require them in dwellings.  At last count, 38 states (and the District of Columbia) require carbon monoxide alarms in private dwellings either by building code or separate state law. However, this is too great a risk no matter what the codes or laws require.

Regardless of what the building codes may or not establish as a minimum, all manufactured housing professionals should want to provide the highest level of safety for the occupants of our homes. Any loss of life from carbon monoxide poisoning is tragic, but it’s a tragedy that can be easily prevented by the proper installation of a CO alarm.

 

I contend that every manufactured home with fuel burning appliances or an attached garage be provided with CO alarms. You can purchase battery powered alarms at your local home center, or ask the manufacturer to provide combination smoke/carbon monoxide alarms in their homes.

Either way, I think this is too important of an issue to overlook.

Let’s Talk About Addendums to the Installation Manuals

I have had several professional installers reach out to me lately regarding some recently issued addendums (documents or designs) to the manufacturer’s installation manuals.  So, I thought we should talk about these addendums to help installers take advantage of these alternative approaches to the installation, and possibly sound a warning on some steps that might be overlooked.

Should you receive any designs or documents from the manufacturer (or any other source) that are not a part of the installation manual that was shipped with the home, I suggest you consider the following:

These addendums, designs, or documents MUST be stamped by the manufacturers DAPIA (design approval primary inspection agency), and the particular manufacturer must be identifiable on the documents. Without these elements, these documents should not be used. Remember, only use DAPIA approved designs!!!

Samples of DAPIA stamps of approval.

Even with the DAPIA stamps and the manufacturers identification on these addendums, it is important to be certain that they are current. DAPIA approvals are always changing to keep pace with changing construction structure methods and evolving building codes. If you are hanging onto details and designs that are more than a few years old, double check with the manufacturers Quality Assurance Manager to be determine if the documents that you are using are current.

Read the fine print! Take the time to read and re-read every note on any addendum you use and be prepared to defend every step you have taken. There are often limitations that may restrict the use of certain designs. For example, many foundation addendums require a minimum soil bearing capacity of 2,000 PFS, so be certain you haven’t overlooked such limits to these addendums.

Obtain all needed support documents! For example, if the addendum is limited for use on non-frost susceptible soils, you will need to have documents in your installation file to show the soil meets these requirements. Maybe you are using designs that require you to determine the “air-freeze index, so you’ll need to gather this information before construction begins!

Don’t forget the local building code official! Most addendums require acceptance by the local authority having jurisdiction (AKA code official), so discuss the addendum with him/her during the building permit application process. Get his approval in writing (if possible). Keep in mind, you are the primary source of information for the code official. Make certain that you are both on the same page before the construction starts!

Keep good records of every home you install!

Finally, as we have talked about in the past, you are required to maintain records of every home you install for at least 3 years. Be certain to keep copies of these addendums along with your other records.

Federal Government Shutdown and Manufactured Home Installers

I have received a few emails recently asking how the shutdown of the federal government (most notably HUD) impacts the roles and responsibilities of manufactured home installers and retailers operating in states where HUD oversees the installation program.

I think it is important to know that the daily activities required by the Manufactured Housing Installation Program (24 CFR 3285 & 3286) are carried out by SEBA who is under contract with HUD. So, we can assume that SEBA is still at work processing HUD 305, 306, 307 and 309 forms and performing other related activities.

Currently the biggest impact is the issuing of installer licenses. While SEBA continues to process the forms for installer license applications, the folks at HUD issue the actual license. So, don’t expect your license to be renewed or any new licensees issued until the shutdown impasse is resolved.  

Until the federal government reopens, installer licenses are not being issued.

Regarding the reporting that is required for new manufactured homes sold and installed, (forms 305, 306 & 309) my advice is that retailers and installers should continue to conduct business just as before. Keep submitting the forms within the required time frames and keep good records! The processing of these forms is conducted by SEBA, who is currently working as usual.

Eventually, all federal government contractors will want to be paid and there could be further impact should things drag on much longer. 

It is important to remember that regardless of the when the government reopens, the requirements are still in place. A lack of enforcement or oversite doesn’t change the law. So be certain to complete the needed forms in a timely manner and submit them as usual. 

Manufactured Homes and Attached Structures-Part 3

In this post let’s talk about some of the other structures commonly attached to many manufactured homes, starting with garages:

Home being prepared for a garage attachment in a factory.

A few years ago, HUD started taking a hard look at garage attachments and they were very clear in stating their requirements. Simply put, HUD requires that if a manufactured home with an after-market garage attachment must be designed for such attachment and that the manufacturer should request a letter of “Alternative Construction” (click here for more on Alternative Construction). This Alternative Construction (AC) letter is required to establish a process to assure that these manufactured homes (with an attached garage) will meet all applicable codes and still provide safe, durable and high-quality housing as expected under the program. Here are a few of the code requirements that must be considered by the manufacturer when designing a home for garage attachment:

  • That neither of the required 2 egress doors enter into the garage.
  • That no windows are located in the garage attachment wall.
  • That there is a fire rated wall assembly (and door) separating the garage from the living space of the home.
  • That there is a separate GFCI protected circuit to serve the garage.
  • That the addition of the garage does not impact any exhaust fans (such as range hood) air intakes (such as furnace or fireplace), plumbing venting or roof venting.
  • That the manufactured home is designed for the added weight of the garage. 

    This garage attachment was the cause of several safety related code violations.

HUD does NOT address the need for a carbon monoxide detector which is generally required under state and local building codes when any home has a garage attached. Even though the HUD Code does not provide for CO detectors, I strongly recommend one be added to every home with a garage.

 

This addition led to several code violations.

If you are considering adding a Florida room, three-season room or similar addition to a manufactured home, with the exception of the fire rated wall assembly and door, every other point raised above regarding garages must be considered. Bottom line, have the manufacturer design the home for the three-season room before you proceed!

This added roof didn’t account for the penetration in the valley! The potential for a leak is great!

 

Solar panels add unintended weight to the home!

Lately I have been seeing a lot of manufactured homes with solar panels installed on the roof. I am a big fan of alternative energy solutions, but again, we need to ask ourselves if the home is designed for the added weight. My research shows that a typical solar panel adds about four lbs. per square foot onto the roof of the home. A typical manufactured home roof truss is designed for a dead load of eight (8) PSF. That eight pounds dead load is so the roof truss can support the weight of the ceiling board, insulation, roof decking, underlayment and roof shingles. While four extra pounds may not seem like much, it exceeds the allowable dead load of the roof by 50%.

Again, make sure the home is designed by the manufacturer for the additional weight of roof mounted solar panels.

On a positive note, I have been seeing some DAPIA approved designs from a few manufacturers that are a little more flexible then previous designs when it comes to certain added structures (primarily extended or attached dormers). Be sure you read the fine print on these designs, and keep good records of the construction. Remember, the devil is in the details!

This might be a topic for a future post!