Comments on the Manufactured Housing Consensus Committee Meeting, Sept 11-13, 2018

I heard from a few folks that attended the Manufactured Housing Consensus Committee (MHCC) meeting held last week in Washington, DC. Since they shared their observations with me, I thought it would provide you with a short summary of the meeting.

Let’s start with what did NOT happen:

HUD did not introduce a new Administrator to oversee the program. As you may recall, the previous administrator and one other high-level manager were removed in December, 2017 (see my post from December 27, 2017 on this topic). But no replacements were announced.

HUD did not include any installers in the discussions. I had hoped that HUD would have invited an installer or two to attend the meeting to try and keep things balanced. But once again, installers were not represented.

Local Code Officials were not invited. I hoped that HUD would invite a few local code officials to participate in this meeting. However, none were invited.

Ok…so let’s talk about what DID occur at this meeting:

The MHCC talked about the HUD Interpretive Bulletin on frost free foundations. Basically, the MHCC wants HUD to withdraw their earlier issued bulletin and allow the states and local governments to have final say in how to protect the manufactured home foundation from frost heave. I personally believe that protecting a foundation from frost heave should be a local or state issue. However, HUD should provide some guidance to help local code enforcers have a better understanding of manufactured home foundations.

The MHCC talked a lot about carports, porches, garages, patio covers and the like. It seems that the discussions suggested that the installer or retailer will need to get much more involved in the design of these after-market structures and as a result, take on additional responsibility. The MHCC wants to add information to the data plate about this. It appears to some folks that this approach is just kicking the can down the road….to the installers and retailers.

The MHCC talked about installation inspectors getting involved in On-Site Completion (SC) inspections. Too bad there were no installation inspectors at the meeting.

They also talked about things like removal of the steel chassis, multi-family manufactured homes and the energy standard (which hasn’t been updated since 1994).  But, not much promise of changes anytime soon.

Looking on the bright side, this was the first face to face meeting of the Manufactured Housing Consensus Committee in a long time (October 2016). So, I guess it is good they met.

Maybe the next time, they will invite some installers!

Keep this in mind!

If any of you attended this meeting and/or would like to add your comments, feel free!

Advertisements

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

What’s In Your Tool Box?

If you’re like me, you can never have too many tools. But to properly and safely install a manufactured home, there are some special tools that you need to use. I though it might be helpful to put together a list of the top 11 things that every professional installer should have at every job site.  

 Angle finder with a magnetic base.

                We all know that when installing ground anchors, the angle of the straps cannot exceed 60°.  Be sure you have a tool to measure the strap angle to be certain your strap angle is correct. If you don’t have one, purchase an angle finder and  start checking the straps angle. By the way, it is always smart to snap a picture for your installer file!

 

A continuity tester.

                You know that ever installation manual requires that you perform a continuity test on all metal parts in the home that could possibility become energized. Metal parts like the chassis, heat ducts, metal light fixtures, gas lines, water heaters and furnaces, metal siding or metal roofs, range hoods, etc… A continuous path to ground must be present and you need to perform this test to verify all of these metal parts are grounded.

A continuity tester is a must!

 Continuity testerTester

A circuit tester with a GFCI trip button.

                This allows you perform the required operation test throughout the home as well as test GFCI  outlets, and assure that any slave receptacles (receptacles downstream of the actual device) are protected as well. This is also an easy way to check the operation of any switched receptacles.

Grainger tester

An apparatus to perform a water supply line pressure test.

                This device is probably going to have to be fabricated from plumbing parts. It must include a gauge that can measure pressure, and inlets with shut off valves to allow you to introduce water and air pressure into the water piping. Remember to remove the source of air when conducting the test. 

 H2O testing

A manometer (or other testing gauges that measure in increments not greater than 1/10 lbs.) to conduct gas line testing.

                By now you should know about the two required gas line tests; the high-pressure test (3 psi) that checks the piping and the low-pressure test (6-8 oz or 3/8 to 1/2 psi or 10” to 14” of water column) that checks the entire system as well as the connections to the appliance.  Again, this may be an apparatus  you assemble yourself, or maybe purchase an electronic, digital version. If someone else (like the fuel provider), performs this test for you, make certain to provide them with a copy of the proper test procedures from the installation manual, and get receipt or other written proof that the test was conducted for your files.  

 DSC02976

GFCI protected extension cords.

Working in often damp or wet conditions, with a great possibility of cords being stepped on, frayed or otherwise damaged, you want to reduce the risk of electric shock hazzard. All extension cords must be equipped with Ground Fault protection.gfci-power-extensions-tower-manufacturing

A thermometer to check the water temperature at each of the bath tubs, bath tubs/showers or showers.

                Run the water in each tub or shower fixture for 1 minute at the hottest setting and use a thermometer to assure that the water temperature is not greater than 120°. While the fixtures are generally pre-set, I have seen defects that allowed the water temperature to exceed 120°. Don’t take the risk, test the fixtures.

H2O thermometer

A glue bottle.

                In the event that you ever need to replace a wall panel, section of the ceiling, or a section of the floor decking, it is critical for you to glue the panel or decking to the framing members. A ¼” bead of PVA glue (white glue) is generally sufficient.

wood glue

Go/No Go Gauges for water supply lines.

                If you ever have to install a crimp ring on a water supply line, you need to assure that the crimp is done properly and Go/No Go gauge is the only way to do that!

 go No Go

Safety Glasses

                Everyone working at the job site must wear safety glasses. Having a few extra pairs handy is a great idea.  If your crew likes to wear sunglasses on the job site, make sure that they are equipped with shatter resistant lenses and side shields. 


safety glasses

First Aid Kit.

                Every good set crew has a fully equipped first aid kit available. If you don’t have one, a basic kit runs only about $30.

 first aid kit

I am sure that there are some other important tools that I am forgetting. Feel free to drop me a message if you can add to this list.

A Tool to Improve the Building Permit Application Process

Having just wrapped up a week of talking to building code officials in three different states, I was reminded of the importance of the building permit application process and how professional installers need to improve the flow of information between themselves and the building code officials. 

Far too many installers continue to pretend that the entire installation process for a manufactured home can be boiled down to a one-page pier print. Then complain if the code official doesn’t uniformly enforce installation requirements on other installers. The problem is that it is very difficult to organize the documents needed into a manageable sized packet of information. The typical installation manual is far too cumbersome and code officials are not going to spend time flipping through these 100+ page manuals for each permit application. Nor should they!

I thought if we could create a tool to help assemble a packet of designs, extracted from the manufacturer’s  installation instructions, it could streamline the process, focus on the important issues of support and stabilization and help eliminate bad actors from the business of manufactured home installation. This post is intended to help installers assemble just such an informational packet through the use of a cover-sheet to pull everything together! 

I know you don’t think you have the time to organize all the documents needed for a complete building permit application, or that the code official doesn’t want anymore then the one page pier print. But if we are ever going to move the manufactured housing industry and careers as professional installers forward, we need to look at the bigger picture when it comes to working with building code officials. 

Here are a few things to consider:

 Manufactured homes have gotten significantly more sophisticated over the years, yet our approach to working with the building code officials remains unchanged! If we want to improve the image of manufactured housing and attract a larger segment of the home buying public, we need to earn the confidence of the code officials.    

Getting familiar with charts like this is step #1 to a more professional installation

 As a trained and licensed professional installer, you should take charge of your installations by being in control of all of the documents needed to properly install the home. The way we have always done things in the past is probably wrong, out dated, and a waste of money and time. Housing designs have changed rapidly over the years, both installers and code officials must be on top of these changes. The only way to keep up with the changes is to make sure we are submitting and following current and pertinent installation documents with every permit application. We just lacked a tool to help installers organize the designs they need for a building permit. 

 Are there unlicensed installers stealing work from you? Once building code officials start seeing exactly what is to be expected for every building permit and subsequent installation, unlicensed installers will not be able to keep the pace.

 Most importantly, a properly applied for building permit eliminates variables and unknowns from the process and goes a long way in increasing profits and reducing liability.

Ok…here is a breakdown on what should be included at permit application as a minimum:

Identify the licensed installer! Show the code official your license so that they come to expect a licensed installer for every new manufactured home installation.

Identify the home by manufacturer as well as home width, side wall height, roof pitch, foundation type and for a few manufacturers, the size of the eaves along the sidewall.

A copy of the manufacturer’s DAPIA approved installation instructions that highlight the appropriate charts and tables needed to construct the foundation. If not submitting the entire installation manual and only the table of contents page shows the DAPIA stamp, provide a copy of that page as well.

Provide DAPIA approved documents from the manufacturer that show approval for any alternate installation methods you might be using (such as alternative anchoring system or shallow frost protected foundation).

Include the Complete Installation Checklist from the installation manual or a Expanded Installation Checklist (from October 16, 2017 post) to better address the installation.

Provide notes on the soil bearing capacity, frost depth and other site-specific considerations that are needed to assure a proper installation.

Typical Pier Print-an installation tool, but must be used with several other design details.

 

And finally, prepare a plan of the home where you can layout the proper location of piers. CAUTION! Pier prints from the manufacturer are not to be trusted. Every pier print refers the installer to the actual installation instructions.  You may want to use the pier print as a tool to help you determine pier locations, but never trust these pier prints without first reviewing it yourself! 

A sample of the permit application cover sheet.

The link below will take you to my attempt at developing a tool to help professional installers organize the documents needed for the building permit application. Feel free to modify it for your particular use.  Click Here for Manufactured Home Building Permit Application Cover Sheet

You will likely need to add some additional documents for the code official (plot plan, sewer tap permits, etc.), but the cover sheet in the above link, will help you get the home specific details in order. Consider making this a part of your typical building permit procedure. I promise, if you try it one time you will quickly see the benefit! 

    

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!

The Importance of a Good Marriage (Line)!

A good marriage is critical to your emotional and financial security.  The same can be said about the marriage of two or three sections of a manufactured home. For all of the good work and craftsmanship that goes into the construction and installation of a manufactured home, I can’t help but think that the marriage line joint is the weakest link in the process. If the marriage line is not secure, level, and reasonably tight, problems are sure to creep in! Heat loss, wall and ceiling cracks, carpets and floors shadowing the seams, and doors binding can all be symptoms of a good marriage gone bad.

 So, let’s talk a little about the marriage line to make sure we are doing all we can to strengthen this weak link.

Everybody knows to remove all shipping plastic from the home. But it is especially important along the roof line as venting of the roof cavity depends on air flow from one home section to the other. Any plastic left around the roof line can restrict the air flow to properly vent the roof.

Look closely for the staple!

Inspect the marriage wall for leftover staples or nails once the shipping plastic is removed. I know they are a pain in the neck, but one staple left in the marriage line can cause big problems.

Damaged heat duct crossover gasket.

Inspect the heat duct gasket. If it is damaged, you need to replace it. Was it the shipping plastic or straps that caused the damage? If so, snap a picture and let the manufacturer know! Consider a shield made from coil stock that can be removed once the home is in place.

Look for any electric cables that might get pinched or otherwise damaged when the sections are pulled together.  Re-secure them to prevent damage.

Gasket needing inspection!

Is the marriage line gasket intact? Damaged? Properly placed?  If you read my previous posts, you should know I think this is a big problem area. Read my post from April 17, 2017 “Would You Like That Supersized?” for some other thoughts on this gasket.

Gaps between the A and B sections of a home can lead to structural problems over time. While professional installers generally don’t pay much attention to shear walls (the walls that transfer wind loads through the structure of the home to the anchoring system), it is very important to understand that in many two-section manufactured homes, all of the shear walls are found in only one of the sections. The manufacturer is depending on you to make a structurally sound joint to transfer these wind loads across the marriage line to the section of the home with the shear walls.

Wind loads are safely transferred only when you properly fasten the sections together. Basically, a structural, tight fitted joint is required in order for the home to withstand wind storm. No gaps in marriage line!

The manufacturer’s installation instructions states, “Shim any gaps up to one inch between structural elements with dimensional lumber. If any gaps exceed one inch, re-position the home to eliminate such gaps”Read that carefully. It means gaps are not permitted! You must either use shims up to 1″ or get the home sections closer.

mate line 1 gap

This needs a shim!

This is very important not just at the floor, but the walls and roof as well! Gaps between sections can cause the screws, nails, or lags to shear off, pull out, or fail at the exact time they are needed the most!

These lags should have been staggered!

Make sure to stagger your fasteners (A half/B half), and be sure they don’t split out the lumber. The lags or screws you use must properly penetrate into the receiving members by 1 ½”. You might need to use longer fasteners than the ones provided by the manufacturer.

Strapping at roof line.

If you are using straps at the roof, it is critical to remember that this joint also needs to be solid and tight. If the staple crowns or nail heads cut through the strap material, the strap won’t be able do the job that the manufacturer intended.  Make sure your fasteners go through the blocking, beams, or rails provided, and not into the truss!

Take a few minutes before your next set and double check the manufacturer’s instructions for fastening the marriage line. Take a lot of pictures, and give some feedback to the manufacturer (the Quality Assurance Manager in this case). They might be able to tweak things at the factory to make your job easier. In fact, if you aren’t on a first name basis with the QA Manager at the factories you deal with, you need to change that. These guys are a wealth of knowledge! Every QA Manager I have ever met wants to produce the best homes possible. What they are lacking is feedback from you!  

A good, strong, tight marriage line is not always easy and at times very difficult. But, with a little tender loving care, you will get that good marriage line, and we all know, a good marriage is well worth any price!