Do Manufactured Homes Really Need Two Exit Doors?

Every time I talk with a group of building code officials, the issue of exit doors comes up. Most code officials are familiar with the requirements of the International Residential Code (IRC), which only requires one egress (exit) door per home. Many code officials mistakenly think that as long as the manufactured home has one landing and/or stairs that provide a single way of escape from the home, the code has been satisfied. The problem is, when it comes to the design of a manufactured home, the IRC is the wrong code! Instead, The Manufactured Housing Construction and Safety Standards (HUD Code) requirements must be followed – and are different from the IRC. Every professional installer needs to understand the differences. Manufactured homes are designed with two egress doors to allow occupants to escape the home in the event of fire, an intruder, a violent situation, or any other emergency.  

To make the situation worse, installers often permanently disable any exit doors where they didn’t install a landing or stairs. This is an extremely dangerous and risky practice that impedes the ability to escape the home. I know professional installers worry about increased liability, and blocking emergency escape paths puts installers at the greatest risk of all!  So, let’s examine this issue and try to better understand.

 

blocked door 1

How can someone escape through this door?

The HUD code at 3280.105 requires that every manufactured home:

  •   Have two exterior doors, remote from each other
  •   Establish a maximum 35’ path of travel from each bedroom to reach an exit door.
  •   In single section homes, the doors must be at least 12’ apart, in multi-section homes, at least 20’    apart.
  •   Must not be in the same room or group of rooms.
  •    May not open into a garage or other similar structure.
  •   May not be located where a lockable interior door must be used in order to exit.

(see 24 CFR 3280.105 for the exact requirements)

Even though the IRC (or other state or local code) is preempted from the design of the home, professional installers must reconcile the HUD requirement with the state code. The IRC-R-311.3 says that each door must have a landing or floor on each side, not less then the door width. Also, the stair geometry (rise and run of the stairs) must also comply with the IRC or whatever code the local authority has adopted.

 

blocked door 2

A landing and stairs are needed here!

Basically, every manufactured home is designed with an exit or egress system that assures that there is a continuous and unobstructed path to the outside of the home. The system relies on a minimum of two exit doors that allow occupants to escape from the home in any given situation. There are no exceptions to this important safety feature. No one, including the code official, may authorize anything less then the code requirement.  

If you are an industry professional that sells/installs manufactured homes, be certain that you fully understand the code requirements for emergency escape doors. Be certain that every home is completed in a manner to offer the occupants each and every safety feature that the code requires. And finally, if your local building code official does not understand the Manufactured Home Construction and Safety Standards, share a copy of 24 CFR 3280.105. This issue is too important to ignore.

We will explore more on this issue in our next post.

 

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Shipped Loose Plumbing-What You Should Expect

It seems that at every installation training or seminar I present, installers and retailers complain that the home manufacturer is not providing the materials needed to complete the drain lines under the manufactured home. So I decided to take a look at this issue and see what we can learn.

The first thing we need to do is see exactly what the Manufactured Home Construction & Safety Standards (HUD Code) says about this.

Check out 24 CFR 3280.610(c)(1)-Drainage systems:

Each manufactured home shall have only one drain outlet.

Ok, now check out 24 CFR 3280.610(c)(5) Preassembly of Drain Lines:

Sections of the drainage system, designed to be located underneath the home, are not required to be factory installed when the manufacturer designs the system for site assembly and also provides all materials and components, including piping, fittings, cement, supports and instructions necessary for proper site installation.

So, when you look at both sections together, it should be pretty clear.  The manufacturer is going to design the drainage system so that all of the individual drain line drops through the floor can be connected to one point AND they must provide all the materials needed for the installer to complete the drainage system according to the provided design.

To know that you are getting all the plumbing parts you are required to receive, you need to look at the design supplied with each new manufactured home shipped from the factory. Generally, this DAPIA approved design is included with the box of other shipped loose parts needed to complete the home. Following this design, you should be able to connect all of the drain line drops to that required “one drain outlet” with materials provided by the manufacturer. 

The materials needed to complete the plumbing in the circled area would be shipped loose inside the home.

 

There is another reason it is important that the manufacturers supply installers with the needed parts and designs to complete the drain line, and it is called “preemption”. HUD has ruled (in a letter dated 12-4-1996) that state or local code enforcement may not require licensed plumbers to assemble shipped loose plumbing. But if you are not installing the drainage system according to the Manufactured Home Construction and Safety Standard, (by not following the DAPIA approved design, or using your own materials) then the local code requirements could apply. 

It is important to note that where the drain lines from the home connect to the main sewage connection the local authority has control, and at that connection, a licensed plumber can be required. 

If you are installing manufactured homes in an area that requires licensed plumbers to assemble the drain system, you should consider working with the manufacturers, your state officials, and possibly HUD to end this unnecessary requirement.

If your manufacturer is not shipping these required drain line parts with the home, you should show him 24 CFR 3280.610(c)(5). This is just one more reason why it is important for professional installers to know the HUD Code!

I hope this information is helpful.

Let’s talk about: On-Site Completion

In our previous post we talked about Alternative Construction (click here to view it). This is a special authorization from HUD to allow manufacturers to construct specific homes that do not meet a certain aspect of the Manufactured Home Construction & Safety Standards (MHCSS or HUD Code). Tankless water heaters, accessible showers, garage ready, or two-story homes exceeding the allowable path of travel to an exit door are a few examples. These homes may not meet the letter of the code, but will perform just as well or even better than the MHCSS.

On-Site Completion (SC) is different as the manufactured home (after all site work is done) will meet all aspects of the MHCSS. However, there are certain elements of construction that cannot be completed in the factory, so they will need to be completed at the installation site. For example, a home designed for a stucco or brick exterior may be shipped to the installation location where the stucco or brick can then be applied. Maybe a home was designed for roof dormers or roof extensions, again, these would be added at the installation site. Tile and glass shower enclosures, and completion or installation of a fireplace are a few other examples. These homes would all comply with the MHCSS, but the work can’t be completed until after it is transported to the site.

Tiled Shower enclosures are often completed under On-Site Completion.

 

If you are like me, you might be thinking, why isn’t this addressed as a part of installation? Well, one of the big things that occurred when the manufactured housing law was amended in 2000 was that installation work was somehow separated from construction. So, we ended up with two classifications of work: construction (in the factory) and installation or close- up (occurs on site). However, the line that separates construction and installation is often blurry.

Fireplace and hearth extension along marriage line finished at the site, under On-Site Completion.

 

Even though the federal law was amended almost 18 years ago, the On-Site Completion rule only recently took effect (March 7, 2016), so it is still very new. Through time, many things that are addressed under Alternative Construction may be shifting to On-Site Completion. So keep your eyes open.

Here are the things that installers and retailers should know regarding On-Site Completion (with references to the Manufactured Home Procedural and Enforcement Regulation in the event you want more information than I provide here).

  • The letters “SC” will be included in the serial number of the home. Keep in mind, a manufactured home can have both SC and AC (Alternative Construction) features. 3282.605(a)
  • A Consumer Information Notice must be developed by the manufacturer that explains the process and identifies the work to be completed on site. 3282.603(d)(10)
  • The manufacturer must provide a “Consumer Information Notice” and have it prominently on display in the home (often by the Health Notice in the kitchen). 3282.606(b)

Typical Consumer Notice

  • The retailer (or manufacturer) must provide a copy of the Consumer Information Notice to perspective purchasers before they enter into the sales agreement.  3282.606(c).
  • The manufacturer is required to provide all of the designs to be followed and materials necessary to complete the construction outlined under the On-Site Completion provisions. 3282.608
  • If the manufacturer expects their retailer or installer to perform this work at the job site, the manufacturer is to provide authorization before the work begins. “However, the manufacturer is responsible for the adequacy of all On-Site Completion work regardless of who does the work…” 3282.602(b)
  • Prior to occupancy, the manufacturer must assure that the On-Site Completion work is inspected. This may require inspections by the manufacturer and IPIA (2 separate inspections) or the IPIA can accept the manufacturers inspection (which appears to be the most common approach). 3282.605(c).
  • The homeowner and retailer are to receive a final site inspection report and certification of completion after all inspections have been conducted. 3282.608(m)

I hope that both the professional installer and the retailer understand that this means additional paper work and record keeping.

If you are the professional installer and are expected to perform this work, make certain you have been given the written authority from the manufacturer before you start the work. Maintain this paperwork in your file for the home along with copies of the documentation provided by the manufacturer.

As the retailer, have a record that you provided the Consumer Information Notice to the purchaser before the sale. Have them sign and date the notice, and keep a copy in your home file.

If a retailer or installer is going to accept responsibility for any part of the inspection process, they should assure the authorization to conduct the inspection is received from the manufacturer in writing. Also, keep copies of the construction designs and the “On-Site Inspection Report”.

Finally, always keep in mind that the entire On-Site Completion process is the responsibility of the manufacturer. If you ever are unsure or have questions on the SC process, talk to the manufacturer’s Quality Assurance Manager. He is the one with all the answers!

Let’s talk about: Alternative Construction

Last week during a discussion in an installation training class, it became obvious that too many installers and retailers aren’t being informed about Alternative Construction (AC) and On-Site Completion (SC) and what this means for the manufactured homes that they install and/or sell.

So, lets take a look and see if we can shed some light on these issues, starting with Alternative Construction.

When a manufacturer intends to produce a manufactured home with a construction aspect that does not meet the Manufactured Home Construction & Safety Standards (MHCSS), but will perform at least equal to the MHCSS, they can request HUD allow such construction.

Let me give an example:

Say you want the manufacturer to construct a home for your customer that has tankless water heaters instead of the typical storage type water heater.  Since the MHCSS doesn’t provide for a tankless water heater, the manufacturer needs a special approval from HUD to omit the storage type water heater and replace it with the tankless type. That approval is called a Letter of Alternative Construction (or an AC letter).

Here is another example: your customer needs a shower that is designed for wheelchair access. The MHCSS requires a minimum 2” dam (or threshold) to keep the water from running onto the floor, making it impossible to access the shower with a wheelchair. The manufacturer can request an Alternative Construction authorization from HUD to provide a shower without a 2” dam, designed to facilitate wheelchairs.

Accessible Shower

 In both of these cases, the home will not meet a specific requirement of the Manufactured Home Construction and Safety Standards, however they both will perform equal or better than the actual code requirement.

DAPIA approved floor plan for a home with garage attachment.

 Currently, one of the biggest requests for AC letters is when a manufactured home is designed for the attachment of a site-built garage. There are many issues of code compliance that must be examined when designing a home for garage attachment.  Issues such as the path of egress (exit) from the bedrooms, impact on lighting and ventilation in the area where the garage is attached, additional loads on the structure of the home, and electrical considerations, to name a few. But the omission of the exterior covering (siding) for the application of gypsum to provide the needed fire separation is where you will find the need for the AC letter.  On a side note…the MHCSS still does not address carbon monoxide alarms! If you are selling/installing a home with a garage attachment, talk to the manufacturer about a combination smoke/CO alarm or an added electrical outlet where you can provide this important safety consideration.

Through the years, the most common use for an AC letter has been a home with a hinged roof, usually a 5/12 roof pitch or greater (this never made sense to me, but that is how they handled hinged roofs). Today most manufactured homes with a hinged roof are being constructed under the new On-Site Completion Process, which we will discuss in a our next post.

 Here are a few “take aways” for retailers and installers when it comes to Alternative Construction.

  •  A manufactured home covered by an AC letter is determined to perform equal to or greater than the MHCSS requirements.

Typical notice to consumer of Alternative Construction.

  • Every manufactured home under an AC letter requires a notice to the perspective purchaser. This notice, as well as an appropriate checklist, and other information related to the AC process is provided by the manufacturer.
  • You can identify a manufactured home constructed under a letter of Alternative Construction by the letters “AC” which will be included in the serial number.
  • Often the home will require a special inspection.   
  • Both the retailer and installer should maintain records of compliance with the AC requirements, and a copy of any needed inspection of the completed home.

 Ok…I hope this helps. If you have anything to add, submit a comment.

In our next post we will talk about On-Site Completion.

Electrical Crossovers

While inspecting some multi-section manufactured home installations recently, I noticed some areas needing improvement regarding electrical crossover connections.  So I thought we should talk about this issue as we head into the summer season.

Should not be exposed!

One of first things to keep in mind is that you should never have any Non-Metallic Sheathed Cable (also called NM Cable, often referred as Romex®) used for branch circuit wiring visible under a manufactured home. Crossover wiring is always to be tucked inside the floor cavity or walls, and protected with an access panel or hatch.

Molex brand connector. Look closely for release tab.

Secondly, to make this connection most manufacturers generally use either electrical connectors or junction boxes. Connectors are pretty straight forward, just snap them together. Most manufacturers in the northeast use Molex® brand connectors, and the great thing about these connectors is that they have release tabs so you can separate the connectors without any damage and reuse them as needed. This is important for relocating a home, or if the home were on display before being moved to it’s installation site.

This brand has no release mechanism.

Some older manufactured homes used a connector made by Amp® that was a single use connector. If you looked closely, you would see: “One Time Use Only, Do Not Re-terminate. The issue was there was no release tab on these connectors, so if you pulled them apart the plastic housing would bend and distort the device. When reconnected, the housing wouldn’t be able to connect securely and safety became a concern. The good news is that I haven’t seen these used for at least eight to ten years. But be alert if you are installing older homes as you may see a connector that is not intended to be reused. If so, cut it off and either install a new connector or use a junction box inside an access panel in the floor cavity or marriage wall.

Look closely to see grounding screw.

Greeny grounding type wire nut.

Speaking of junction boxes, here are a few basic things to remember. Where the NM Cable enters the junction box, there should be a cable clamp or connector. Don’t overtighten the clamp onto the cable, just snug it down. The cable should be secured within 12” of the clamp or connector (check the actual installation manual as some require cable securement within 8” of the cable clamp). If the junction box is metal, it should be grounded. You can use a ground clip, ground screw or a “greeny” wire nut for this.  Twist the conductors together before installing the wire nut, and make sure to use a wire nut that is the proper size. Usually the capacity and number of connectors are identified on the top of the wire nut itself. After grounding the junction box and making good connections, place the cover on the junction box!

I am seeing a few of the push-in type connectors in place of the twist style wire nuts, and these seem to work fine. Just make sure you strip the conductor with the proper tool to the proper length per the installation instructions. I saw a few brands of these push-in connectors that limited their use to solid wire only (no stranded wire). On solid wire conductors, these push-in types are generally reusable. But it can be difficult to get the conductors to disengage. You may be better served replacing them.

If you notice that the outer sheathing (or jacket) of the NM Cable is nicked or damaged, make sure you address it properly. If there is a superficial nick in the outer sheathing, wrap electrical tape around the cable at the nicked area, to a thickness that equals the depth of the nick. If the damage exposes any of the conductors or the paper inside the cable, the affected area must be removed! There is no repair for damage that significant.

End wall crossover. Cables need better protection!

If the manufacturer notched out a wall stud or other structural member to run the NM cable, make sure to protect the cables with wire protective plates or “mash or smash” plates as they call them in the south. And make certain the cable is 100% protected!

Always replace the access panels or close the access area to protect the connection from moisture and possible damage. If any floor insulation is missing, replace it as well!

Revisit the manufacturers installation instructions for a little more detail. On a new home, use the connector type the manufacturer provided.  If there are problems making this connection on a new manufactured home, take a picture and report it back to the manufacturer. They can only make improvements if they get feedback from you!

Keep in mind that you should always refer to the Manufacturers Installation Instructions, but if you want to learn more, the Manufactured Home Construction & Safety Standards (MHCSS) at 3280.801 is where you will find the actual code requirements.  Click Here for the MHCSS  Also, it is worth knowing the MHCSS adopts Article 550 of the 2005 National Electric Code. So, check them all out to make sure you are doing things right!

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!