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!

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Working With Code Officials Part 3-Inspections

Today we will look at the last piece of the puzzle on local code officials: The Final Inspection. That last hurdle to get the much-anticipated “Certificate of Occupancy”.

The local code enforcers I work with typically require two inspections for manufactured housing:

  1. A footing/site grading inspection
  2. A final inspection.

Not to say that sometimes additional inspections aren’t needed, but for a typical pier set, two inspections should be sufficient. Here are four things for the professional installer to consider going into the inspection phase of an installation:

  1. Don’t cover your work before the inspection!

If you want a bad relationship with your code official, go ahead and pour your concrete before the footer inspection. Remember to schedule your work with the inspector in mind!

  1. Be present at every inspection.

This is extremely important. It is akin to being on trial without showing up in court! In fact, I suggest that the installer actually direct the inspection! Trust me, I have been audited, inspected, examined, and interrogated more times than I can remember, but in each and every case, I did my very best to set the tone and direction for whatever type of oversight or inspection is occurring.

You can set the tone of the inspection by simply showing off your work.  Explain how you determined the footing sizes. Explain how the home has pier savers and that you don’t need piers at the patio door, but that the triple ganged window needs pier support. Explain how the anchoring system you use takes care of the end wall anchors. Just start with keeping the inspector engaged, and soon he will start having confidence in you, and that will pay dividends on future projects.

BUT…you MUST be present at the inspection!

3.  Have the installation details and instructions at the job site to be used during the inspections.

In my opinion, a good inspector will inspect against the documents that were provided for the permit application. Not just walk around the job site and point out what he doesn’t like.  Having these instructions with you helps eliminate confusion, and as an installer who does the job right, it helps educate the local inspector in the proper way to install manufactured homes.

If the code enforcer points out what he feels is a problem, your first reaction should be to refer to the instructions to verify the issue one way or the other. Don’t just do something because the code official told you to, stick to the designs, charts, instructions, etc. If the code official is wrong, you need to tactfully and calmly show him why you believe you are correct. Keep in mind, this is a business and we need to have a business-like approach.

Remember, if there is a problem with the installation of a manufactured home, the installer bears the responsibility, not the code official!

  1. Utilize the “Complete Installation Checklist”.

If you have been following this blog, or attending my training courses, you know that I am a big advocate of the “Complete Installation Check List” (see “A Very Valuable Tool-Jan. 6, 2017).

Just imagine the reaction of the inspector when he arrives at the job site and you hand him a checklist that is completely filled out with notes and comments to indicate that you have followed the manufacturers installation instructions.  And he can keep a copy of this checklist for his records!

Trust me, that inspector will have gained more confidence and respect for you then you could ever imagine! Presenting the completed checklist as evidence of a properly installed home will help you set the tone for the inspection, and identify you as a true professional manufactured home installer.

In closing, I understand that many professional installers don’t have a warm and fuzzy relationship with local code enforcers. But if we ever hope to improve the image of manufactured housing, I think this relationship is the most logical place to start. It is up to us to start changing mindsets, attitudes and relationships. While a few code officials might be impossible to work with, most code officials are only looking to do their job. They would much rather avoid confrontation just like you!  They don’t need extra work, and honestly don’t take pleasure in failing an inspection.

Change starts with us! Let’s improve our understanding of this entire Manufactured Housing Program and be able to explain preemption and why it is deserved. The permitting process can make or break an installation. Let’s re-examine our approach and use the tools at our disposal. And finally, get involved in the inspection process and start taking charge of our projects! And there is no better time than right now! Spring is Here!