Important Notices from HUD-Part 2 of 2

In the previous post we looked at the final rule issued by HUD regarding the Formaldehyde/Health Notice requirements. Now we need to look at the second notice from HUD that lays out several proposed rule changes to the manufactured housing program.

After you review these proposed rules, please take a few moments and share your thoughts with HUD while there is still time to make changes. HUD will accept your comments on these proposed rules until March 31, 2020.

You can read the proposed rule for yourself HERE and see how you can submit your comments. I am listing below only the proposed rule changes that I believe will impact installers and retailers. I have added my thoughts in [brackets] below each proposal.

3280.2, 3280.802, 3282.7 & 3285.5           HUD is adding the following definition of an “attached accessory building or structure” to the construction standards, regulations and the model installation standards.

“Attached accessory building or structure means any awning, cabana, deck, ramada, storage cabinet, carport, fence, windbreak, garage or porch for which the attachment of such is designed by the home manufacturer to be structurally supported by the basic manufactured home.”

[While I support the concept, I don’t like the attempt to list every type of attached building or structure. Differences in terminology can led to arguments, disagreements and lead to loop holes that undermine the intent of the rule. For example, stairways and landings are not included in the list. I think it is preferable to simply state that an attached accessory building or structure is anything that is attached to the manufactured home and utilizes the manufactured home for support. I will object to this proposal as written.]

3280.5          The home manufacturer would be required to add a statement on the data plate if the home is (or is not) designed for accessory structure attachment.

[While I like the concept, there is no requirement for the manufacturer to state on the data plate what type of attachment may be added. Again, it opens the door for varied interpretation. I will object to this proposal as written.]

3280.114        This proposed rule establishes requirements for stairs, landings, handrails, guards, etc. for stairways both inside the home and I assume on the exterior of the home.

The reason I assume on the exterior is at 3280.114 (d) and (e), there are requirements that specifically address exterior porches and exterior stairway lights.

[Since these requirements are more stringent than the requirements of some states (Pennsylvania for example), I think these requirements will cause confusion. I would suggest that the rule be changed to only address stairways inside the home and let the state govern exterior and basement stairs. I will object to this proposal as written.]

3280.211          HUD is finally proposing that carbon monoxide alarms be provided in homes that are equipped with fuel burning appliances or for a home that was designed for an attached garage.

[I fully support this proposal.]

3280.212 & 213 and 3282.14       Manufactured homes designed by the manufacturer to accept the attachment of a site constructed garage or carport will no longer require the HUD issued letter of “Alternative Construction”. Also, the manufacturer will be required to provide designs for the attachment of these structures in the installation instructions.

[I fully support this proposal.]

3280.609(c)(1)(iii)            This section requires that installers extend the water heater temperature/pressure relief valve discharge piping to the exterior (not under) the manufactured home.

[This proposed requirement is concerning as super-heated water being discharged outside of the skirting of the home could pose a risk to people or pets in the vicinity of the pipe termination. This is another example of additional burdens being placed on manufactured home installers without being included in the rule making process. I will object to this proposal as written.]

3280.612              With this proposal, HUD is looking to lower the pressure required to perform the water supply piping pressure test from 100 psi to 80 psi (± 5psi). Since this requirement is referenced in the Installation Standards, this would also change the requirement for installers.

[While I support this change, I am concerned that the manufacturers installation instructions will be slow to reflect this change.]

 

Again, this is my unofficial take on the proposed changes to the program. I encourage you to look them over, formulate your own opinions and comment to HUD while there is still time to make an impact.

Manufactured Homes & Attached Structures, Part 2

In our last post we talked about how added structures, such as carports, patio covers and the like, add unintended vertical loads to a manufactured home. Today, let’s talk about how added structures subject the manufactured home to increased horizontal (wind) loads, and the possible damage that can occur as a result.

Another example of a patio cover improperly attached to a manufactured home.

The biggest problem that I have seen is when an awning, carport or patio cover is attached directly to the fascia board of the manufactured home. Typically, the fascia board on a manufactured home is attached to the roof trusses without anticipation of a large attachment. Studies has shown that the manufactured home can easily withstand the required wind loads when the home is anchored according to the manufacturer’s installation instructions. But when a carport or patio cover is attached to the fascia board, it can subject the home to significantly higher loads than the home is designed for.

This warning is found in every typical manufactured home installation manual

A quick review of the installation instructions for a few different awnings, carports or patio covers (common in the manufactured housing industry), shows that they agree that the awning should not be attached to the fascia board. However, there remains a concern as they suggest their products can be attached to the actual roof rafter or wall stud of the home (no mention of type of home, manufactured home or otherwise). I found no mention of fastening the mounting rail to a roof truss as opposed to a roof rafter. Nonetheless,  I feel very safe in stating that the home manufacturer did not design the roof truss to support an awning, carport, porch canopy, or similar accessory.

Most critical is when the wind gets under these structures an they start to tear away from the home. As they break free, they create openings that allows the wind to get into the roof cavity, which can lead to catastrophic failure. Take a few minutes and watch these two videos. I think they make a pretty convincing case.

Click Here for American Modern Manufactured Home Wind Test

Click Here for The Today Show, Homes vs Hurricane Winds

There are a few more things to discuss in regards adding structures to manufactured homes, but lets save those topics for yet one final post on this topic.

Manufactured Homes & Attached Structures Part 1

It is pretty hard to drive through any manufactured home community and find a home that doesn’t have some type of attached patio cover, carport, deck, Florida room or door canopy. In fact, it is so common that it is almost expected by homeowners and routinely overlooked by installers, retailers, community owners and building code officials. I think we should talk about this common practice to be certain we are doing the right thing.

Typical patio cover improperly attached, adds over 1 ton of weight to the manufactured home.

 

A typical manufactured home installation manuals will say something like this:

Install site-built structures such as steps, landings, garages, awnings, carports, breezeways, porches, decks, railings, sheds and utility rooms to the manufacturer’s instructions and according to the following:

  • Construct site-built structures to be structurally independent unless provided for in the design of the home

 (there are additional bullet points in the home installation instructions that we will explore in future posts).

A properly supported door canopy!

 

So why must these common awnings, landings, steps and the like, have to be “structurally independent” of the manufactured home?

It all starts with the Manufactured Home Construction & Safety Standards (HUD Code) and the Model Installation Standards. The HUD Code is no different from other building codes as they all establish the minimum building code requirements.  Building codes cannot anticipate aftermarket construction or additions, and neither can the home producers. So, when we are thinking about attaching patio covers or carports to a manufactured home, we need to focus on the potential impact these added structures can have on the home and the foundation.

Unauthorized site-built additions to a home can impose unintended vertical and horizontal loads beyond what the building code minimum requires. Let‘s start with a look at the vertical load, and save the horizontal (wind) load for the next post.

Most manufactured homes are designed to handle a roof snow load of 20 to 40 pounds per square foot (psf) based on where the home is to be installed. In addition to this snow load, manufacturers must include the actual weight of the home itself (somewhere around 20-25 psf) and the assumed weight of the contents inside of the home (for furnishing, people, pets, etc.). The HUD Code requires that the manufacturers calculate this as an additional 40 psf. Ultimately, a typical manufactured home must be designed to support between 80 and 105 psf with limited deflection of the structure. The foundations are then designed to transfer all of this weight into the ground to assure a stable, plumb and level home.

This improperly supported deck can easily pull free from the home and collapse!

 

Now let’s assume you attach a 20’ x 12’ (240 sq. ft.) patio cover to fascia board of the home.  For a home located in the south roof load zone, that would add 4,800 lbs. (240 sq. ft x 20 psf of snow) of potential snow load beyond what was intended by the manufacturer of the home (not to mention the weight of the patio cover!). About half of that load would be transferred to the columns supporting the front of the patio cover, but the remaining weight (2,400 lbs.) is being transferred back to the fascia board, into the roof trusses and into the structure and foundation of the manufactured home itself.

You have just added over a ton of weight to the home that was not accounted for by the building code or the design of the home.

Carport pulled fascia from the roof trusses

 

I have seen first hand where this added weight has led to ceiling cracks, inoperative windows and doors, floors bowing, and piers cracking, breaking or sinking into the ground and other structural failures.

Broken ceiling panel, due to added structure.

 

There are some other issues to consider as well. The fascia board is not intended to resist the pull of an awning or patio cover. Fascia boards can easily pull free from the home and cause significant damage to the home. The same can be said for decks attached to the floor rim (or band) joist. You run the risk of deck collapse since the rim joist attachment to the floor joists in a manufactured home is not designed for attachment of a deck. The International Residential Code does not allow deck attachment to rim or band joists without a positive attachment such as a deck tension ties. Basically, a threaded rod and bracket that runs through the rim joist and screws to the floor joists.

Simpson Strong-tie deck bracket

See https://www.windsorlocksct.org/site/deck_lat_load.pdf for more details.

So that leaves the installer with two options:

  1. Install columns on both sides of an added structure so the home is not bearing any additional weight.
  2. Ask the home manufacturer to design the home to accept whatever loads will be added. In fact, a few manufacturers already have some designs, but typically they call for attachment to the side wall, not the fascia board.

Ok…we are just starting to explore this issue and there is much more to discuss!  Let’s talk about how added structures impact horizontal (wind) loads in our next post.