Shipped Loose Plumbing-What You Should Expect

It seems that at every installation training or seminar I present, installers and retailers complain that the home manufacturer is not providing the materials needed to complete the drain lines under the manufactured home. So I decided to take a look at this issue and see what we can learn.

The first thing we need to do is see exactly what the Manufactured Home Construction & Safety Standards (HUD Code) says about this.

Check out 24 CFR 3280.610(c)(1)-Drainage systems:

Each manufactured home shall have only one drain outlet.

Ok, now check out 24 CFR 3280.610(c)(5) Preassembly of Drain Lines:

Sections of the drainage system, designed to be located underneath the home, are not required to be factory installed when the manufacturer designs the system for site assembly and also provides all materials and components, including piping, fittings, cement, supports and instructions necessary for proper site installation.

So, when you look at both sections together, it should be pretty clear.  The manufacturer is going to design the drainage system so that all of the individual drain line drops through the floor can be connected to one point AND they must provide all the materials needed for the installer to complete the drainage system according to the provided design.

To know that you are getting all the plumbing parts you are required to receive, you need to look at the design supplied with each new manufactured home shipped from the factory. Generally, this DAPIA approved design is included with the box of other shipped loose parts needed to complete the home. Following this design, you should be able to connect all of the drain line drops to that required “one drain outlet” with materials provided by the manufacturer. 

The materials needed to complete the plumbing in the circled area would be shipped loose inside the home.

 

There is another reason it is important that the manufacturers supply installers with the needed parts and designs to complete the drain line, and it is called “preemption”. HUD has ruled (in a letter dated 12-4-1996) that state or local code enforcement may not require licensed plumbers to assemble shipped loose plumbing. But if you are not installing the drainage system according to the Manufactured Home Construction and Safety Standard, (by not following the DAPIA approved design, or using your own materials) then the local code requirements could apply. 

It is important to note that where the drain lines from the home connect to the main sewage connection the local authority has control, and at that connection, a licensed plumber can be required. 

If you are installing manufactured homes in an area that requires licensed plumbers to assemble the drain system, you should consider working with the manufacturers, your state officials, and possibly HUD to end this unnecessary requirement.

If your manufacturer is not shipping these required drain line parts with the home, you should show him 24 CFR 3280.610(c)(5). This is just one more reason why it is important for professional installers to know the HUD Code!

I hope this information is helpful.

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Working With Code Officials-Part 1

Every time I thought about posting on the topic of working with code officials, I would get bogged down in the sheer number of issues that need to be discussed. Is the code official allowed inside the home? What can they inspect? Why is code enforcement so inconsistent? Why are we afraid of upsetting the code official? Shouldn’t the code officials know installation better than me?

There is a tremendous amount of misunderstanding, misinformation, failed communication, and worst of all, mistrust between the code enforcers and our industry.  With all of that in mind, I felt the best approach was to start with a series of short posts that hopefully will all come together and make sense.

So, to quote the Wizard of Oz, it is best to start at the beginning. For manufactured housing the beginning starts at PREEMPTION. If you are not familiar with this term, this is your lucky day!

The word “preemption” simply means that one thing takes the place of another. Think about how a breaking news story “preempts” your favorite TV show! So, the National Manufactured Housing Construction and Safety Standards (HUD Code) takes the place of (preempts) the state and local building code.

 

So, what do you think this means to the code official?  Basically, he is being asked to issue a building permit for a manufactured home without doing the things he would normally do for any other house. But the typical code official has a lot of questions. Has anyone properly reviewed the building plans? Has anyone conducted any inspections during the construction process? Is this HUD code any good? Has anyone done the things he would have done if the home was being built on site?

The code official needs education! However, we do a very poor job explaining the manufactured housing program and how manufactured homes are likely more highly scrutinized and inspected than any conventional constructed home. Because of the strength of manufactured housing program, the code officials can have confidence in homes we install.

A Manufactured home has earned the right of preemption from local building code!

Not taking full advantage of the preemptive nature of the HUD Code adds unnecessary costs to the installation of the home and does nothing to improve the image of manufactured housing industry.  If we earn the confidence of the local code enforcers, we will earn the confidence of the home buying public. And it all starts with knowing how to answer all of the code official’s questions. Explain how the plans were reviewed and stamped as proof of compliance. Explain the in-plant inspection processes, and the accountability that is in place to assure that the manufactured house is not just affordable, but safe, durable and high quality. Explain to the code officials that the manufactured housing program works on behalf of the building code official.

We need all code officials to understand that they don’t need to worry about the rough framing, plumbing, electrical and other construction inspections. All of these inspections were already conducted on their behalf.  While they can’t review all of the building plans, the plans were reviewed on their behalf. If something were to go wrong, there are mechanisms in place to get things corrected.  As a result, the code official can have confidence in every new manufactured home that comes into their town. The problem is that a lot of code officials don’t know how the program works! They need training, and the installers are in the best position to start training them!

Here are just a few of the things to consider:

·         Installers must know the installation manual! Stop saying “we always did it that way” and start following the manual, making positive changes to our installation procedures.

·         Get involved with the building permit application process. Submit details, designs or instructions that have been plan reviewed and stamped. That means a stamp from one of the agencies that does plan review for the manufactured housing program; RADCO, PFS, HWC, TRA, NTA, NEB (whoever is listed on the data plate).

·         Know the HUD code. Be able to explain why the drain lines under the home do not need insulated. Be able to explain why ARC Fault protection is not required. Be able to explain flash rings, bonding wires, closed combustion appliances, limited combustible materials at the cooking range area …just to name a few.

Ok, that is enough for now. But stayed tuned, Part 2 on this topic will post next week!