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.

Manufactured Home Installations Are Changing!

The other day I received a call from a manufactured home retailer who was concerned because a code official refused to issue a building permit unless the installation documents were better organized. The code official wanted the installation details to be organized with a “Manufactured Home Building Permit Application Cover Page”. Other installers in the area had begun using this document to organize the pages, tables and charts from the home manufacturer’s installation manual instead of just using a pier print. As a result, this code official was so impressed that she now requires this cover page for all manufactured home permit applications.

If you are not familiar with the “Manufactured Home Building Permit Application Cover Page” click HERE. It is a simple one-page document where the installer can go through the manufacturer’s installation instructions to organize and detail the information needed for a proper installation. Plus, it is a great start to installer record keeping that is required for all new home installations. For more of an explanation on how this document can help you, click on this link to see the original post.  A Tool to Improve the Building Permit Application Process

This made me think, are there other improvements to manufactured housing installation that are starting to catch on? Well, yes there are!  Here are a few that I have recently observed:

Independently Supported Patio Covers and Carports

While monitoring several installations in Michigan, I was impressed to see how posts and columns were properly installed along the front and back of the carports and patio covers to assure they are independently supported. Just lagging the hanging rail to the home will overload the home, and can possibly lead to structural failure in a wind storm event. If you are still using the manufactured home to support these accessory structures, you need to watch this video HERE.

It clearly shows how attaching a carport, patio cover, or similar structure to a manufactured home (that was not designed for such an attachment), can lead to a structural failure of the home.

Example of a properly supported patio cover

Not only are installers in Michigan improving their installations, but here is a home in Pennsylvania where the porch roof supports itself and does not add additional loads on the home.

Porches Isolated From the Crawl Space

I have finally begun to see installations where the skirting or crawl space enclosure separates the porch area from the rest of the crawl space. We all know that water under the home is a huge problem, and rain water coming through floor decking boards and allowing this water to collect in the crawl space is a big problem.

Rain water coming through deck boards can lead to problems in the crawl space.

Finally, I have been seeing installations where barriers are provided to isolate the porch area from the rest of the crawl space, and the skirting around the porch is held above grade to allow any water that comes through the decking board to flow away from the home.

The lattice only serves to hide the piers and frame. It is installed to allow any water to flow away from the home.

 

Skirting Attachment

Attaching skirting directly on the siding of the home has been the conventional method of skirting application for years, simply because it is easy. However, this application has led to water infiltration, poor performance and appearance of the siding. It is extremely encouraging to see how many installers are now attaching skirting under the home.

Proper skirting attachment, prevents water infiltration and improved appearance.

 

Installation Check Lists

I am seeing quite a few installers have begun to use the installation check list, and have started to customize the enhanced checklist to better fit their particular installations. These checklists, along with the building permit cover page, go a long way to reduce the liability of the installer. Check out this post and download your own copy of the Expanded Installation Checklist.

Manufacturers Getting On Board

As reported in our last post, New Installer Resource & Upcoming Training Available, Clayton Homes started publishing a quarterly newsletter designed to improve installation. Also, I have seen that the Commodore Corp. has been providing their retailers/installers with some home specific foundation details to help streamline the installation process. I am sure that there are some other manufacturers doing similar things, and I hope more follow suit.

Bottom line, the installation process is slowly changing for the better. So, as a professional installer, you should want to be in front of these changes and use them to your advantage.

 

Encouraging Feedback From Manufacturers

Have you ever had to tell a friend that their fly was down? Or maybe they had some broccoli stuck between their teeth? While it may be a little awkward to point out someone’s simple mistake, you know that ultimately your friend appreciated your honesty and candor. This leads me to ask installers “does the home manufacturer ever point out any mistakes or issues that you may have gotten wrong during the installation process?”. Since the installations of all new homes must be in accordance with their installation instructions, it seems to me that the manufacturer is in the best position to point out when something is overlooked or simply done incorrectly, even if that discussion may be a little awkward.

However, I continue to see too many cases where installation mistakes are routinely ignored by the home manufacturer. As a result, little problems become big problems which are far more difficult and costly to correct, and in some cases, correction is impossible.

For example: there are countless communities across the country where manufactured homes have had garages attached to the home. While an attached garage is a great feature to offer the consumer, few manufactured homes are designed to accommodate this add-on. Multiple structural and life-safety concerns can result from a garage attachment if not a part of the original design. Problems such as: improper fire separation between the garage and the living area (including windows opening into the garage space), overloading the roof, walls and foundation of the manufactured home due to the weight of the garage and potential snow on the garage roof, failure to provide an electrical branch circuit to provide power to the garage, failure to provide a carbon monoxide alarm as required by most state building codes for homes with attached garages, and possibly having egress doors leading into the garage space, to name a few.

Example of a “garage ready” home. Designed specifically to accept the on-site constructed garage.

When called upon to investigate problems in communities like this, I often wonder why the manufacturer(s) of these homes never mentioned that the homes weren’t designed for attached garages. Wouldn’t you think a good friend or partner would point that out and maybe suggest that they could design and construct homes specifically for garage attachments? But instead, too often not a word is said until the situation gets out of control.

In all fairness, there are now several manufacturers offering garage ready homes, but this is a fairly recent development.

I am sure you all have seen similar issues. Maybe you have seen manufactured homes in communities that have carports or patio covers attached directly to, and being supported by the home. Or maybe the homes have recessed porches or decks which allow rain water to flow between the decking boards and directly into the homes’ crawl space. Or maybe the homes are set in pits which collect water, instead of atop a slightly elevated site that will shed water away. I could go on, but I think you get the point.

Rain water falling onto this recessed porch has no where to go except into the crawl space. If enclosed by skirting, it must be fully vented and allow for the free flow of water from under the porch area.

I would hope that any business partner of mine would be just like that friend who lets me know when I am wearing my shirt inside out. But in the manufactured housing industry, that is not always the case.

A “pit set” and recessed porch. How will water ever escape this crawl space?

So, just who is in the best position to tell you when you missed a button, belt loop or maybe a tie-down strap? First off, I think the factory sales representative could be one of the first ones to let you know that there could be a problem. Next would be the factory’s service department. Anyone from the factory that visits your sites should be able to provide some feedback to improve the overall installation.

Too many factory representatives choose to overlook these issues or maybe they don’t know anything is wrong. I have long advocated for the training of service personnel, and with a few exceptions, they operate outside of the building code or regulations or even the manufacturer’s quality control process. While I have met quite a few really sharp sales people, many are a little weak when it comes to understanding code requirements.

So maybe it is time to start expecting more from our friends at the factory. It is not always easy to tell someone they are messing up, but that is what a good friend would do.

Manufactured Homes & Attached Structures Part 1

It is pretty hard to drive through any manufactured home community and find a home that doesn’t have some type of attached patio cover, carport, deck, Florida room or door canopy. In fact, it is so common that it is almost expected by homeowners and routinely overlooked by installers, retailers, community owners and building code officials. I think we should talk about this common practice to be certain we are doing the right thing.

Typical patio cover improperly attached, adds over 1 ton of weight to the manufactured home.

 

A typical manufactured home installation manuals will say something like this:

Install site-built structures such as steps, landings, garages, awnings, carports, breezeways, porches, decks, railings, sheds and utility rooms to the manufacturer’s instructions and according to the following:

  • Construct site-built structures to be structurally independent unless provided for in the design of the home

 (there are additional bullet points in the home installation instructions that we will explore in future posts).

A properly supported door canopy!

 

So why must these common awnings, landings, steps and the like, have to be “structurally independent” of the manufactured home?

It all starts with the Manufactured Home Construction & Safety Standards (HUD Code) and the Model Installation Standards. The HUD Code is no different from other building codes as they all establish the minimum building code requirements.  Building codes cannot anticipate aftermarket construction or additions, and neither can the home producers. So, when we are thinking about attaching patio covers or carports to a manufactured home, we need to focus on the potential impact these added structures can have on the home and the foundation.

Unauthorized site-built additions to a home can impose unintended vertical and horizontal loads beyond what the building code minimum requires. Let‘s start with a look at the vertical load, and save the horizontal (wind) load for the next post.

Most manufactured homes are designed to handle a roof snow load of 20 to 40 pounds per square foot (psf) based on where the home is to be installed. In addition to this snow load, manufacturers must include the actual weight of the home itself (somewhere around 20-25 psf) and the assumed weight of the contents inside of the home (for furnishing, people, pets, etc.). The HUD Code requires that the manufacturers calculate this as an additional 40 psf. Ultimately, a typical manufactured home must be designed to support between 80 and 105 psf with limited deflection of the structure. The foundations are then designed to transfer all of this weight into the ground to assure a stable, plumb and level home.

This improperly supported deck can easily pull free from the home and collapse!

 

Now let’s assume you attach a 20’ x 12’ (240 sq. ft.) patio cover to fascia board of the home.  For a home located in the south roof load zone, that would add 4,800 lbs. (240 sq. ft x 20 psf of snow) of potential snow load beyond what was intended by the manufacturer of the home (not to mention the weight of the patio cover!). About half of that load would be transferred to the columns supporting the front of the patio cover, but the remaining weight (2,400 lbs.) is being transferred back to the fascia board, into the roof trusses and into the structure and foundation of the manufactured home itself.

You have just added over a ton of weight to the home that was not accounted for by the building code or the design of the home.

Carport pulled fascia from the roof trusses

 

I have seen first hand where this added weight has led to ceiling cracks, inoperative windows and doors, floors bowing, and piers cracking, breaking or sinking into the ground and other structural failures.

Broken ceiling panel, due to added structure.

 

There are some other issues to consider as well. The fascia board is not intended to resist the pull of an awning or patio cover. Fascia boards can easily pull free from the home and cause significant damage to the home. The same can be said for decks attached to the floor rim (or band) joist. You run the risk of deck collapse since the rim joist attachment to the floor joists in a manufactured home is not designed for attachment of a deck. The International Residential Code does not allow deck attachment to rim or band joists without a positive attachment such as a deck tension ties. Basically, a threaded rod and bracket that runs through the rim joist and screws to the floor joists.

Simpson Strong-tie deck bracket

See https://www.windsorlocksct.org/site/deck_lat_load.pdf for more details.

So that leaves the installer with two options:

  1. Install columns on both sides of an added structure so the home is not bearing any additional weight.
  2. Ask the home manufacturer to design the home to accept whatever loads will be added. In fact, a few manufacturers already have some designs, but typically they call for attachment to the side wall, not the fascia board.

Ok…we are just starting to explore this issue and there is much more to discuss!  Let’s talk about how added structures impact horizontal (wind) loads in our next post.