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 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!