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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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!