Nationwide “AC” Regarding Manufactured Housing Window Shortage

I have been made aware of a recent action by HUD regarding the manufactured housing program that is worth sharing with installers and retailers.

Evidently, manufacturers are having problems purchasing windows that meet the older standards referenced in the Manufactured Housing Construction and Safety Standards (HUD Code). As a result, HUD has issued a blanket letter of Alternative Construction (AC Letter) that allows for the use of windows that meet the more recent standards generally accepted in other building codes.

As you know, AC letters require that the letters “AC” be included in the serial number of the home and that a notice be provided to any perspective purchaser explaining the issue. The blanket AC Letter requires that the manufacturer post the required purchaser notice “in the kitchen area of the home”. No action is required on the part of retailers and installers. For more information on Alternative Construction, see my post on that topic Let’s talk about: Alternative Construction (2-26-2018)

It is important that retailers and installers understand this situation so that they can accurately answer any questions posed by their customers who happen to see this notice. It is possible that you may run across a new manufactured home that utilizes multiple AC letters, like one for windows as well as other construction features. Make certain you check in the homeowners’ packet for any other AC approvals that may require your action.

Finally, while this is a blanket, nationwide AC Letter, I am sure that not every manufacturer will need to utilize this waiver. I suggest you talk with your manufacturer’s Quality Assurance Manager and ask them to keep you up-to-date on this issue.

Below is the link to the HUD website where you can access the AC letter and the notice:

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.

What I Learned at the Louisville Manufactured Housing Show

Ever since I started my career in the manufactured housing industry, I have heard about the big manufactured housing show held in Louisville Kentucky each January. Last week, at the invitation of my friends at the Michigan Manufactured Housing Association, I finally got to see it for myself.

I must admit, it was quite impressive. There were almost 60 homes (both modular and manufactured) on display, and plenty of venders to keep me supplied in pens and key chains for years to come.

Photo courtesy of The Louisville Show

 

The big surprise was how many folks approached me to talk about problems with installation. Specifically, problems with their local code officials. If you have followed this blog over the past 3 years, you know that I have written on this topic several times. But attending the show, and hearing from so many people with similar stories about code enforcement, I knew we should talk about it once more. Here is a sampling of what installers, community owners and retailers were talking about:

  • Code officials requiring vertical tie downs for manufactured homes in Wind Zone 1.
  • Local requirement to add smoke alarms to the home.
  • Code officials requiring licensed plumbers to perform all plumbing tests, and the assembly of the shipped loose drain lines.
  • Requiring blower door testing to every manufactured home.
  • Code officials that refuse to sign off on required forms (namely HUD 309) for fear of being penalized.

While individually, these issues might not seem like much, collectively they illustrate that 44 years after the manufactured housing program began, we have done a terrible job educating the code enforcement community on manufactured housing.

So, what can we do about it? Plenty!

First, we need to start involving the industry leaders (trade association and manufacturers) when these issues come up. All too often, installers and retailers are quick to do whatever the local code official asks, just to pacify him or her. In other words, we go along just to get along. This needs to stop. With the support and involvement of the folks at the top, we should be looking at ways to educate and win over the local code officials.

Next, we need support from HUD. As you all know, fewer and fewer states are participating in the manufactured housing programs along with HUD. Too many of the ones that are participating have drifted very far away from the program principals. Whenever given the opportunity, we need to encourage HUD be more visible with every state government. Not just with the people who run the programs, but rather with those who establish the policies…such as the Governors and Cabinet Secretaries. Additionally, we need to encourage HUD to start assuring that all states are held to the same expectation. Remember, a rising tide lifts all boats!

Also, we need to continue to become the experts on manufactured housing. By now you all should have a copy of the Manufactured Home Construction and Safety Standards, and if you don’t have a copy, Click Here. Next, you need to actually read it! Become the expert that the code officials can come to whenever they have a question!

The same is true with the home installation instructions. Read them! When you find things that seem odd, talk to the factory QC department and engineers (not sales or service staff). Maybe they can be changed or better explained!

Know the importance of the building permit application process. Organize your documents with a Manufactured Housing Building Permit Coversheet (click on the link).  Forget the single page pier print, and start submitting (and following) DAPIA approved details to support everything you do to assure a properly installed home.

Finish the whole process off by keeping good records and completing the Installation checklist. Here is one I created should you want to use it:  Expanded Manufactured Housing Installers Checklist PDF!

Maybe I will see you at the show next year!

Basics that Every Manufactured Home Professional Should Know. Focus on Modular Homes, Garages & Site Installed Furnaces

In our last post we started taking a closer look at some of the important elements of the manufactured housing law and regulations that you should know. Today, we will look at a few more.

During an installer training class last week, our discussion landed on the difference between a manufactured and modular house. I like to point to 24 CFR 3282.12(c) of the Manufactured Home Procedural & Enforcement Regulations. Simply put, a modular home is ONLY intended to be placed on a permanent foundation, such as a masonry crawlspace or basement. While a manufactured home may be placed on a permanent foundation, it is not required.

Taking it a step further, a modular home is not intended to be moved once it is installed on the basement or crawlspace. A manufactured home must always remain permanently transportable regardless of the foundation used for support.

And finally, a modular home is designed and constructed to the state adopted building code (such as the International Residential Code) while a manufactured home must meet the Manufactured Home Construction & Safety Standards (AKA the HUD Code).

In a nutshell, we should never see a modular home being relocated or moved. They are designed for their specific site to a site-specific code, placed on a basement and often with the transportation components (chassis or carrier) removed. While a manufactured home must always retain the ability to be moved (permanent chassis), it is not restricted to a specific foundation, and is designed and constructed to a federal building code.

***

Recently we have been seeing many more manufactured homes with attached garages. To assure that the home can safely and structurally handle a garage, the manufacturer must design and produce that is garage-ready. The process the manufacturer must follow is known as “Alternative Construction”. You may have been introduced to Alternative Construction (AC) in the past whenever a manufactured home had a hinged roof. While we could argue the benefit of the added expense and paperwork required just because the home had a 5/12 roof pitch, there is a huge advantage to going through the Alternative Construction process if you are planning on attaching a garage to a manufactured home.

Garage Ready home being installed.

Alternative Construction is basically an authorization from HUD to the manufacturer to allow them to construct a manufactured home that may not meet a specific provision of the HUD Code, but as a result of the “alternative construction” the home performance of the home is not affected.

So, if the manufacturer produces a “Garage Ready” home that has been evaluated under the Alternative Construction process, you can have confidence that all of the HUD code considerations have been taken into account. Things like the distance from the bedrooms to an exit door (without passing through the garage), that there are no windows looking into the garage, there is fire rated wall and door separating the garage from the home, and the structure of the home can accept any additional loads resulting from the garage attachment.

If you just attach the garage without benefit of the AC process, there is no assurance that the home will remain structural sound and safe as required by the HUD Code, and you assume the liability in the event any issues arise. It is always important to remember that the HUD Code still does not address carbon monoxide alarms. So please make sure you consider this important safety feature when adding a garage to a home.

Consider providing carbon monoxide alarms for homes with attached garages or that contains fuel burning furnaces, water heaters or fireplaces.

 

You should also know that Alternative Construction extends to much more than garages and hinged roofs. Alternative Construction provides a way to customize the manufactured home to fit many of the needs or desires of your customer. Tank-less water heaters and wheel chair accessible showers are common consumer requests that can be provided through the AC process. So, if you or a customer is requesting some non-traditional features in their home, maybe Alternative Construction is the process you should explore. For more information check out 24 CFR 3282.14. Also, an earlier post on this topic.

***

On a similar note, did you know that the Manufactured Home Construction & Safety Standards allows for the field installation of the furnace? The HUD Code requires that the manufacturer provide connection points to the air supply and return ducts, but the actual furnace may be provided by the installer.

This is ideal for a manufactured home being placed on a basement or maybe utilizing an alternative fuel source, and no additional approvals is needed. It is provided for right in the code.  For more on this, check out 24 CFR 3280.709(e)(6).

***

Ok…that is enough for now, but there is plenty more to talk about in future posts!

The highlighted text will direct you to the referenced requirement. And as always, the views expressed are mine and should not be taken as anything more than my personal opinion.

A Few Basics of the Federal Program that Manufactured Home Professionals Should Know, Part 1

When I was in junior high school, we conducted an experiment to see how a particular statement could get twisted as it was passed along from person to person. After being whispered across the classroom, the information had very little resemblance to the original statement. We immediately learned not to trust everything that you hear.

I think the same thing happens in the manufactured housing industry. Often what we learn about the manufactured housing program gets passed down to us from our supervisors, colleagues, regulators and others. And just like that experiment in school, the facts often get twisted if not completely forgotten.

With this in mind, I think we should take a look at a few of the provisions in the manufactured housing law and regulations, that well intended professionals have a responsibility to know.

—-

One of the things I share in all of my training classes is that every new manufactured home MUST comply with all applicable standards; without exception! However, sometimes folks in our industry will enter into a contract or waiver with the consumer, attempting to create an exception to the program requirements (See Who Really Owns the Tires & Axles? for an example). If this is you, check out the following section of the Manufactured Housing Construction & Safety Standards Act.

§5421. Prohibition on waiver of rights.
The rights afforded manufactured home purchasers under this chapter may not be waived, and any provision of a contract or agreement entered into after August 22, 1974, to the contrary shall be void.

That seems pretty clear to me, a new manufactured home must fully meet the code and program requirements, without exception. Even if a consumer signs a waiver, the federal law renders that waiver void!

—-

A few times I have encountered folks attempting to create a loophole in the program by misconstruing the definition of “purchaser”. Their thinking is that they could buy a new manufactured home from a manufacturer or retailer, becoming the first purchaser and re-sell the home to the consumer, thereby ending the protections of the manufactured housing program to the consumer. Well, take a look at the definition of “Purchaser” in the Manufactured Home Procedural & Enforcement Regulation 24 CFR 3282.7(aa).

Purchaser means the first person purchasing a manufactured home in good faith for purposes other than resale.

If your purpose is to re-sell the home, you are not the purchaser.

—-

If you still say that you are in the “mobile home” business, as opposed to the “manufactured home” business, I’ll guess that you still wear leisure suits, listen to ABBA, and drive a Ford Pinto. There hasn’t been a “mobile home” produced since June 15, 1976. Except for modular homes (constructed to a state adopted building code), any single-family home built in a factory in the past 43 years is a “Manufactured Home”. Check out 24 CR 3282.8(a)

Using outdated or misleading terms to the purchaser can have unintended consequences. Better get with the times and use the correct terminology!

—-

Have you ever been told that a local building code official is not permitted inside a manufactured home? I have heard that claim for years, and it is not true! What the regulations actually say is that a building code official may not inspect a new manufactured home for compliance with the HUD Code. Basically, the code official should trust that the inspection process in the factory was sufficient (see 24 CFR 3282.11(b) of the regulations for more detail).

However, a code official entering the home is not a problem. I contend that a code official should enter every home to check the data plate information. And since the HUD Code doesn’t address certain construction standards that many other residential building codes require, the local code inspector is within his rights to look for items like carbon monoxide alarms, or baluster spacing (if the home has railings installed inside the home) to name a  few.

I have always advocated that every manufactured home professional should have their own copy of the Manufactured Home Construction & Safety Standards. Without a copy of the HUD code, you will never be able to determine if the code official has exceeded his local or state authority and started to tread on the federal program.

CLICK HERE to access the HUD Manufactured Housing web site to download a copy of the HUD as well as the federal law and regulations!

It might be a good idea to explore more of these type of issues in future posts. Please keep in mind, these posts are my personal opinion, and are not to be construed as anything more.

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.

 

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!