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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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.