Update on HUD Reporting Forms & Your Comments

Note: This information pertains to HUD licensed manufactured home installers and manufactured home retailers that are located in, or sell homes into states where HUD administers the Manufactured Housing Installation Program.  

If you recall, on May 2, 2018, I posted about the expiration date of the HUD forms that retailers and installers use to comply with the HUD installation program requirements.

HUD Form clip

While it is important that you continue to use these forms and submit the information as in the past, I have recently been made aware that the Office of Management & Budget (OMB) is now reviewing these forms and is seeking input from you.

The OMB is seeking comments on whether the information that you provide HUD on these reporting forms is necessary, and if the reporting forms can be improved for HUD to properly operate the program.

I am attaching the comments that I already provided for your review if interested. Comments on MH Installation Program Reporting Requirements

Also, I am attaching the Federal Register notice with the particulars needed to submit your thoughts. Click here to see the Federal Register Notice

The deadline for comments is August 13, 2018.

Finally, if submitting via email, the email address provided in the notice appears to be in error. Try sending it to:

OIRA_Submission@omb.eop.gov

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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.