How to Train Your Code Official

The one thing that all manufactured home installers and retailers have in common, is that they are all impacted by the state or local building code officials and their approach to manufactured housing. Whether a code official oversteps his authority by requiring unnecessary code provisions, minimizes his role by simply issuing permits and occupancy certificates without any oversight, or if they don’t issue building permits for manufactured homes at all, our work is impacted and far too often, negatively.

Code officials that do not understand the manufactured housing program, ultimately add unnecessary costs to the home and limits our ability to provide high quality, durable, safe and affordable housing.

Today, I want to talk a little about what installers and retailers can do to educate code officials and as a result, better position the manufactured housing industry for the future.

The first thing to remember is that the vast majority of code officials receive no formal training in regards to the manufactured housing program(s). Except for the few states that specifically require code officials to receive training on manufactured homes, very few code officials understand manufactured homes. The industry does a poor job explaining how the manufactured housing program works on behalf of the state/local code enforcers. As a result, we are left with a patchwork of requirements which often result in inferior installations, and also undermine the overall affordability of manufactured housing.

To compound matters, installers, retailers, and manufacturers are reluctant to have business-like discussions with code enforcers and as a result, nothing changes. The industry folks I talk with generally adopt one of two extremes when it comes to this relationship (neither of which is correct). Either they object to the code official simply entering a manufactured home, or they are of the opinion that it is easier, cheaper, or faster to just do everything the building code official asks.  No matter which approach you take, it ultimately supports the notion that either we have something to hide, or that the construction and/or installation of manufactured homes is substandard and needs the code enforcer to improve on the homes design.

Here are a few things that installers and retailers must do to start to get code enforcers to view manufactured housing for what it is: sophisticated, code compliant, safe, high quality, durable and yet affordable housing.

Stop using the term “mobile home”. If it was built before June, 1976, fine, call it a “mobile home”. But today we produce and install “manufactured homes” and the differences are significant. If you want state and local code officials and the home buying public to think that the industry of today is producing and installing the same product that we did over 40+ years ago, then keep using outdated terms. But if we ever have hopes of getting people to understand that the manufactured home of today compares favorably to every other housing product on the market, then we must use proper terminology. 

Accept that you as the installer are the primary source of information for the code official. If you start to improve the building permit application process, you can begin to drive your code official to better understand our program. For example:

  • Provide a copy of your installer license with every installation. The code official is the first line of defense in stopping unlicensed installers. Presenting your license with every permit application, supports the notion that only trained professionals should be installing manufactured homes.      
  • Provide DAPIA approved details (from the installation manuals) to the code official to used to conduct the inspections.  Single page, unapproved pier (or footer) prints do not illustrate that the real installation drawings and details have already been reviewed and approved. Far too many code officials don’t understand that the plan review has already been performed for them!
  • On the other extreme, it seems that too many people just give the code official the entire installation manual and expect them to make sense of it. We should organize the DAPIA approved designs needed for the installation so that they are easily followed. Utilizing a cover sheet is one way to do that. This not only educates the code officials, it is a great tool for installers as well. Click here for a sample that you can use: MH Building Permit Coversheet
  • Be present at the inspections. There is no better time to provide training than this. Bring the DAPIA approved designs (and maybe your copy of the Manufactured Home Construction & Safety Standards) with you and whenever a question is asked, refer to the designs or standards.

 At this point, I know many of you are thinking that you would rather not make waves, and that the code official won’t listen, and a ton of other reasons as to why you prefer the status quo. But, like it or not, the industry is changing and what worked for us in 1976 is not going to work tomorrow.

I was encouraged to learn folks from HUD and SEBA are speaking at a national meeting of code officials in September to discuss installation.  I have been conducting code official training for the past several years, and I can tell you, they are receptive to the message when we present it properly.

Bottom line is that either we start driving the state/local code officials to understand and respect our program, or manufactured housing will go the way of typewriters, telephone booths, and record albums.

 

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Education of Code Officials!

Whether we like it or not, state or local building code enforcement impacts every home we install. Sometimes it takes a big issue to make us feel the impact. For example, when HUD cracked down on attaching garages on manufactured homes, a lot of folks were upset and there was a lot of finger pointing trying to place the blame. The installers, community owners, retailers, and manufacturers that got caught up in the crack-down were potentially subject to penalties that could have cost them their livelihood. But from the very start, the local building code officials who permitted (and in many cases still do permit) garage attachment without giving a second thought, were in the best position to question or even stop this practice.

I recall a very heated exchange with a code official and trying to get him to understand that even though the manufactured home was exempt from the state building code, unauthorized alterations and additions to a manufactured home (especially ones as significant as attaching a garage) are not exempt. He maintained the position that he had no authority over anything regarding manufactured homes beyond issuing building permits.

Even today I still run across far too many code officials that believe that just entering a manufactured home exceeds their authority.

A local building code official taking the opposite approach can be just as problematic. A code official that imposes his own requirements with no regard for the manufacturers installation instructions can cause huge problems. Folks may think that as long you don’t “make him mad” that is all well and good. That is until a new sheriff comes to town and puts a stop to everything!  How do you convince the local code official that his long-held approach to anchoring, foundations, utility testing (just to name a few) not only violates the building code, but can actually harm the overall performance and durability of the home?

And there are still places areas in the country without any code enforcement. The problem with no code enforcement is that your competition will continue cutting corners and costs through non-compliant installations, additions, and so on. Nobody wants to lose sales to shoddy installation, but concrete costs money!

If you are in one of the 14 states where HUD oversees the installation of new manufactured homes, your relationship with the local code will take on more importance. You’ll likely struggle to explain to the code official the differences between new and relocated manufactured homes. You may be hard pressed to find a local code official that is willing to sign off on HUD forms. And most importantly, you can only hope that your code official accepts the same installation methods as the professional engineer, DAPIA, or whomever else you hire to sign the HUD form. How do satisfy them all! Next will come someone to monitor the installation! Fingers crossed!

So, what should we do? Is this a legitimate problem that we should start discussing, or do we let sleeping dogs lie??

I contend that if we can get all the local building code enforcers on the same page, here is what we can expect in return:

  • A level (ok…a slightly more level) playing field. It is hard to compete when you are digging footings to frost depth and your competition is barely removing the top soil! But if the code official knows the installation standard, and that he has the authority to oversee the foundation construction, it won’t take too long until the “dirt sets” are a thing of the past
  • Better installations and reduced liability. If we can get code officials to expect the proper documents to properly install the home, instead of just the “pier print”, then as installers we will not only be forced to improve our record keeping (which is the most important thing an installer can do to reduce liability), but also improve the overall installation.
  • Predictable costs and expectations. Just think how much more efficient we could be if you could install every home the same, regardless of which township, county, borough, or burg the home was being sited. It is extremely frustrating to hear how this township requires anchors be wet set in the concrete footings and that township requires insulated drain lines. There should be very minimal variations as a result of local code influence. But until such time as the code officials are taught that there is a comprehensive installation design to be followed for each and every installation, we will be at the whim of each and every code official
  • Greater market share. Did you ever ask an auto mechanic for advice before buying a car? Or ask a bartender for recommendations on a good drink. If you don’t think home buyers ask code officials about which housing product to buy, you are mistaken. If a code official knew that there are mechanisms to address problems, there are instructions and checklists that will assure proper installations, and when properly installed a manufactured home will deliver, safe, durable, high quality affordable housing, just think how many new customers we will find

Ok, I think I made my point. It is time to start educating code officials on the proper handling of manufactured housing. Let make it happen!

Working With Code Officials-Part 2 Permitting Process

Last week we talked about why manufactured homes are preempt from local and state building codes. If you haven’t read that post, see my March 13th post “Working with Code Officials-Part 1” before going on.

Today we will begin to talk about the process of getting a building permit and how important it is to a successful project. I know many installers let others (customers, retailers or community owners) take sole responsibility for the building permit, but that needs to change. Your involvement in the permitting process helps assure the project gets off on the right foot. At the very least, make sure you get copies of the documents submitted for the building permit. Then you can know what the code official expects from you!

The first thing to understand is that the vast majority of code officials are only familiar with their particular building code (in most cases the International Residential Code (IRC) or some variation). The problem is that the IRC says very little about manufactured housing (Appendix E), and what it does say is not very useful. Rarely are building code officials trained in the Manufactured Home Installation Standard (24 CFR 3285) or Program (24 CFR 3286). So, it is up to you to get them on the right track. Here are a few steps to follow:

1.       Installer License. As of June 1, 2016, all manufactured home installers must be licensed or certified by their state or HUD everywhere in the country. It is a fair bet that a lot of code officials don’t know this or don’t care. You as a professional installer have invested time and money for your right to install manufactured homes. Make sure you present your credentials as a professional installer along with every permit application. Once the code official starts expecting to see installer licenses with every permit, it will start to weed out the impostors who steal business away from you!

2.       Manufacturer’s Installation Instructions. I generally see one of two scenarios: A one page pier print that has very little usable information; or an entire installation manual containing tons of charts and details that do not apply to the job you are doing. Keep in mind the code official should be inspecting to the designs presented with the application. Highlight the actual charts you need to determine things like pier spacing, footing size, anchor system, fastening charts for multi-section, etc. If you have a design that includes a statement like “If acceptable to the local authority having jurisdiction” that means the issue in question is not addressed in the HUD code and does not preempt the local code.

3.       Understand Local Requirements. If the local code official requires three copies of the permit application, have those three copies ready. If they require a plot plan for every job, have one ready. If they require special forms for manufactured housing, have them completed and ready to hand in! If you don’t know the local requirements, most municipalities have everything you need on their web site.

4.       HUD Requirements. If you are in one of the 13 states where HUD oversees new manufactured home installations (that number is subject to change), your code official may need to sign off on HUD Form 309 (HUD Manufactured Home Installation Certification and Verification Report). Don’t surprise him with this form and expect a signature. Make sure this form is part of the permit application. Also, for more information on HUD requirements, visit: www.maufacturedhousinginstallation.com

Last week, as a few of you pointed out, changing the attitudes of building code officials is not easy. I completely agree, but it has to start sometime and there is no better time than right now.

Stay tuned, next week we will take a look at the inspection process.

Working With Code Officials-Part 1

Every time I thought about posting on the topic of working with code officials, I would get bogged down in the sheer number of issues that need to be discussed. Is the code official allowed inside the home? What can they inspect? Why is code enforcement so inconsistent? Why are we afraid of upsetting the code official? Shouldn’t the code officials know installation better than me?

There is a tremendous amount of misunderstanding, misinformation, failed communication, and worst of all, mistrust between the code enforcers and our industry.  With all of that in mind, I felt the best approach was to start with a series of short posts that hopefully will all come together and make sense.

So, to quote the Wizard of Oz, it is best to start at the beginning. For manufactured housing the beginning starts at PREEMPTION. If you are not familiar with this term, this is your lucky day!

The word “preemption” simply means that one thing takes the place of another. Think about how a breaking news story “preempts” your favorite TV show! So, the National Manufactured Housing Construction and Safety Standards (HUD Code) takes the place of (preempts) the state and local building code.

 

So, what do you think this means to the code official?  Basically, he is being asked to issue a building permit for a manufactured home without doing the things he would normally do for any other house. But the typical code official has a lot of questions. Has anyone properly reviewed the building plans? Has anyone conducted any inspections during the construction process? Is this HUD code any good? Has anyone done the things he would have done if the home was being built on site?

The code official needs education! However, we do a very poor job explaining the manufactured housing program and how manufactured homes are likely more highly scrutinized and inspected than any conventional constructed home. Because of the strength of manufactured housing program, the code officials can have confidence in homes we install.

A Manufactured home has earned the right of preemption from local building code!

Not taking full advantage of the preemptive nature of the HUD Code adds unnecessary costs to the installation of the home and does nothing to improve the image of manufactured housing industry.  If we earn the confidence of the local code enforcers, we will earn the confidence of the home buying public. And it all starts with knowing how to answer all of the code official’s questions. Explain how the plans were reviewed and stamped as proof of compliance. Explain the in-plant inspection processes, and the accountability that is in place to assure that the manufactured house is not just affordable, but safe, durable and high quality. Explain to the code officials that the manufactured housing program works on behalf of the building code official.

We need all code officials to understand that they don’t need to worry about the rough framing, plumbing, electrical and other construction inspections. All of these inspections were already conducted on their behalf.  While they can’t review all of the building plans, the plans were reviewed on their behalf. If something were to go wrong, there are mechanisms in place to get things corrected.  As a result, the code official can have confidence in every new manufactured home that comes into their town. The problem is that a lot of code officials don’t know how the program works! They need training, and the installers are in the best position to start training them!

Here are just a few of the things to consider:

·         Installers must know the installation manual! Stop saying “we always did it that way” and start following the manual, making positive changes to our installation procedures.

·         Get involved with the building permit application process. Submit details, designs or instructions that have been plan reviewed and stamped. That means a stamp from one of the agencies that does plan review for the manufactured housing program; RADCO, PFS, HWC, TRA, NTA, NEB (whoever is listed on the data plate).

·         Know the HUD code. Be able to explain why the drain lines under the home do not need insulated. Be able to explain why ARC Fault protection is not required. Be able to explain flash rings, bonding wires, closed combustion appliances, limited combustible materials at the cooking range area …just to name a few.

Ok, that is enough for now. But stayed tuned, Part 2 on this topic will post next week!