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.