HUDs Model Installation Standards for Manufactured Homes

Presenter: Michael S. Henretty & Jason McJury

Monday, September 11, 2017
4:00 PM – 5:30 PM
Federal Manufactured Housing Program

September 2017

“ The mission of HUD is to create strong, sustainable, inclusive communities

and quality affordable homes for all. ” 1
 HUD’s Manufactured Housing Programs

• Mission: “To protect the quality, durability, safety,

and affordability of manufactured homes and
facilitate the availability of affordable manufactured
homes and to increase homeownership for all
Americans.”
(NATIONAL MANUFACTURED HOME CONSTRUCTION AND SAFETY STANDARDS ACT OF 1974 (AS AMENDED IN
2000), 42 U.S.C. 5401)

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 Program Scope
• Manufactured homes provide subsidy-free affordable
housing for more than 20 million Americans.

• The manufactured housing industry creates more than

38,000 jobs in over 127 communities nationwide.

• Manufactured housing industry consists of 127 operating

production facilities

• FY 2016 manufactured housing production was 121,732

floors, equaling a total of 78,372 homes. Year-to-date home
production and floor production were both 15% ahead of
the same period last year (January – September 2016)
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 Program Scope
• Total inventory of occupied manufactured housing was
6,917,000, which is about 9.5 percent of single family
housing stock. (Annual Housing Survey 2013)

• Almost one in five homes in rural America is a manufactured

home.

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 Program Description
• The National Manufactured Housing Act of 1974, as
amended in 2000, established the authority and framework
for the preemptive Federal Standards and the Regulations
used to enforce the Standards that are in use and effect
today.

• The Act authorized HUD to regulate the design and

construction of all new manufactured housing.

• The HUD Program is funded by label fees collected from

manufacturers.

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 Program Description (cont’d)
• The Federal Manufactured Housing Program is administered
exclusively from HUD Headquarters in Washington, DC (no
support provided by HUD’s field offices).

• Program support is provided by private and state agency

partners accepted by HUD.

• Contractor services are used to assist HUD in monitoring

and assessing the performance of Private and State Agency
partners, for implementing and carrying out the installation
and dispute resolution programs; and for administering the
Manufactured Housing Consensus Committee (MHCC).

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 Program Purpose
The Manufactured Housing Program was established by the
National Manufactured Housing Construction and Safety
Standards Act of 1974, amended in 2000, as a nationwide
program to protect the quality, safety, durability, and
affordability of manufactured homes. The Office of
Manufactured Housing regulates the industry and enforces the
Federal Manufactured Home Construction and Safety
Standards, the Model Installation Standards and the Dispute
Resolution Program.

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 Program Scope
• Manufactured housing industry consists of 127 operating
production facilities

• Fiscal Year 2016 Manufactured Housing Production was 121,731

floors equaling a total of 78,372 homes. Year-to-date home
production was 18.8% ahead and floor production was 13.4%
ahead of the same period last year (October 2016 – March 2017)

• Total inventory of occupied manufactured housing was 6,917,000,

which is about 9.5 percent of single family housing stock. (Annual
Housing Survey 2013)
• One in every five rural single family homes is a manufactured
home.

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 Manufactured Home Act
The National Manufactured Housing Construction and Safety
Standards Act gives HUD authority to:

• Establish preemptive manufactured home construction and safety standards

using the MHCC

• Determine whether manufactured homes comply with the standards

• Conduct inspections and investigations necessary to enforce the standards

• Contract with separate and independent organizations to carry out monitoring

and inspection work

• Establish model installation standards and implementing program regulations

• Establish and implement a dispute resolution program

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 What is a Manufactured Home?
• THE HUD STANDARDS DEFINE A MANUFACTURED HOME AS:
“A STRUCTURE, TRANSPORTABLE IN ONE OR MORE SECTIONS, WHICH IN
THE TRAVELING MODE IS EIGHT BODY FEET OR MORE IN WIDTH OR FORTY
BODY OR MORE IN LENGTH OR WHEN ERECTED ON SITE IS 320 OR MORE SQUARE
FEET, AND WHICH IS BUILT ON A PERMANENT CHASSIS AND DESIGNED TO BE
USED AS A DWELLING WITH OR WITHOUT A PERMANENT FOUNDATION WHEN
CONNECTED TO THE REQUIRED UTILITIES, AND INCLUDES THE PLUMBING,
HEATING, AIR CONDITIONING, AND ELECTRICAL SYSTEMS CONTAINED IN THE
STRUCTURE…”

• THE HUD STANDARDS AND REGULATIONS DO NOT APPLY TO

MODULAR OR SELF PROPELLED RECREATIONAL VEHICLES.

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 HUD Code Production Levels
• Approximately Eight (8) million HUD Code Manufactured
Homes have been built since the Program’s inception in
1976.

• In Fiscal Year 2016: Total Floors = 121,731 / Total Homes =

78,372

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 What is Manufactured Housing?
• America’s largest source of
unsubsidized, affordable, single
family housing.
• Comprises approximately 10% of
single family homes in the United
States
• 96% of MH Homeowners have
annual household income of
$50,000 or less
• Built to America’s only national,
pre-emptive building code.
• Regulated by HUD since 1976.
• 1 in 5 homes in rural America is a
manufactured home

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 A Manufactured Home Defined

• The HUD Standards define a manufactured home as:

“A STRUCTURE, TRANSPORTABLE IN ONE OR MORE SECTIONS, WHICH IN THE

TRAVELING MODE IS EIGHT BODY FEET OR MORE IN WIDTH OR FORTY BODY
OR MORE IN LENGTH OR WHEN ERECTED ON SITE IS 320 OR MORE SQUARE
FEET, AND WHICH IS BUILT ON A PERMANENT CHASSIS AND DESIGNED TO BE
USED AS A DWELLING WITH OR WITHOUT A PERMANENT FOUNDATION
WHEN CONNECTED TO THE REQUIRED UTILITIES, AND INCLUDES THE
PLUMBING, HEATING, AIR CONDITIONING, AND ELECTRICAL SYSTEMS
CONTAINED IN THE STRUCTURE…”

• The HUD Standards and Regulations do not apply to

modular or self-propelled recreational vehicles.
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 HUD Code Production Levels

• Approximately Eight (8) million HUD Code

Manufactured Homes have been built since the
Program’s inception in 1976.

• In Fiscal Year 2016: Total Floors = 121,731 / Total

Homes = 78,372

• In Fiscal Year 2017: Anticipated total home

production of 80,000

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What is HUD’s role in Manufactured Housing?
• The Office of Manufactured
Housing Programs:
‐ Administers, updates, and
enforces the National
Manufactured Home Construction
and Safety Standards
‐ Administers, updates, and
enforces Model Manufactured
Home Installation Standards
nationwide
‐ Administers the National
Manufactured Home Dispute
Resolution Program

• Through the Office of Single Family

Housing, FHA operates mortgage
insurance programs through which
eligible Manufactured Homes can
be purchased or refinanced

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Approved Manufactured Housing Partners
• 36 State Administrative Agencies (SAAs)
• 36 State Installation Programs
• 26 State Dispute Resolution Programs
• 15 In-Plant Primary Inspection Agencies (IPIAs)
• 6 Design Approval Primary Inspection Agencies
(DAPIAs)
• 5 Contractors
‒ Assist in monitoring IPIAs, DAPIAs, and
Manufacturer Quality Assurance.
‒ Assist in administering Dispute Resolution and
Installation Programs.
‒ Assist in administration of the Manufactured
Housing Consensus Committee
‒ Assist in planning meetings of the MHCC,
Wisconsin State Capitol, Madison
SAAs, and PIAs

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 HUD’s Role in States
• Serves as the State Administrative
Agency for 14 states that do not
participate as a HUD SAA partner.
Tasks include receiving consumer
complaints and administering
Notification and Correction of
Defects.
• Administers Manufactured Home
Installation programs in 14 states
that do not have their own
installation programs.
• Administers Dispute Resolution
Program in 24 states that do not
have their own programs.

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 National Program and Industry Impacts
• About 10 million manufactured home owners

• 22 million Americans live in manufactured homes

• In 2011, manufactured housing accounted for:

- 71% of all new homes sold under $125,000
- 50% of all new homes sold under $150,000
- 30% of all new homes sold under $200,000

• Manufactured housing industry is an important economic

engine, accounting for about 38,000 jobs

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 Standards & Regulations
24 CFR 3280
• Nationally Preemptive Manufactured Home Construction
and Safety Standards

24 CFR 3282
• Manufactured Home Procedural and Enforcement
Regulations

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 Other Standards & Regulations
24 CFR 3285
• Model Manufactured Home Installation Standards

24 CFR 3286
• Manufactured Home Installation Program

24 CFR 3288
• Manufactured Home Dispute Resolution Program

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 Industry Stakeholder Overview
Production and Retail Stakeholders

Manufactured Home Builders

• Approximately 45 corporations or other legal entities with
123 production facilities

Manufactured Home Retailers

• About 2,000 retailers with about 4,000 locations

Supply Chain
• Product and component suppliers, installers, etc.

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 HUD’s Regulatory Partners
All Agencies/partners must be accepted by HUD
• Design Approval Primary Inspection Agencies
- Review and approve building plans and Quality Assurance
Manuals/Manufactured contract with DAPIAs for design services provided
- 6 Agencies (5 private, 1 unit of state government)

• In-Plant Primary Inspection Agencies

- Oversee implementation and effectiveness of quality assurance
programs/Manufacturers contract with IPIAs for In-Plant inspection services
provided
- 15 Agencies (5 private, 10 units of state government)

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 HUD’s Regulatory Partners (cont’d)
• State Administrative Agencies
- Handle consumer complaints and oversee manufacturer actions within
their state related to remedial actions/SAAs are paid by HUD for
enforcement services provided
- 37 Agencies (All units of state government)
• Approved State Installation Programs
- Establish and enforce HUD approved installation program based on model
installation standards.
- 37 agencies / all units of state governments.
• Approved State Dispute Resolution Programs
- Establish and administer HUD approved dispute resolution program
- 26 agencies / all units of state governments.
Primary objective of the monitoring services needed by the Program is assessment of the
performance of these agencies to assure manufacturer compliance to HUD Standards and
Regulations. This will require comprehensive knowledge of HUD Standards and Regulations
to provide the monitoring oversight required.

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 Manufactured Home Constituents

Source: 2012 Mobile Home Market Facts, by Foremost Insurance Company

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 Installation Program
• Obtained contractor to assist with implementation of
installation program for 14 HUD administered states with
SEBA Professional Services.

• SEBA helps OMHP manage trainer and installer licensing

processes, and monitor inspections.

• SEBA helps OMHP review HUD-approved installation

programs

• SEBA helps OMHP review manufacturer installation manuals

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Installation Program

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 Installation Program
• HUD Manufactured Home Installation website at
www.manufacturedhousinginstallation.com:

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 Dispute Resolution Program

The Manufactured Home Dispute Resolution Program (DRP) is

available to assist in resolving disputes between manufacturers,
retailers and installers of manufactured homes regarding
responsibility and, if required, correction or repair of defects in
manufactured homes.

To qualify for resolution under the Manufactured Home

Dispute Resolution Program, defects must be reported within
the one-year period after the date of first installation.

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 Dispute Resolution Program
• HUD Dispute Resolution website:

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Ending the Blame Game

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Dispute Resolution Program

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 The HUD Monitoring & Enforcement Process
Home Designed

Design approved by HUD-accepted Design Approval Agency (DAPIA)

Factory-built by manufacturer to design specifications HUD and

Contractor
Monitoring
Production Inspected by HUD-accepted Primary Inspection Agency (IPIA)

SAA
Installation Program (HUD or State Administered) Involvement

Manufacturer Notification and Correction of Defects

(in coordination with SAA or HUD)

HUD or State Dispute Resolution Program

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 On Site Completion
– A manufacturer-authorized retailer add-on, not including a
garage add-on, provided during installation, that may
initially take the home out of compliance but the home is
brought back into conformance
– Site completion of a fireplace hearth that cannot be
completed in the factory because it spans the mating line
of a multi-section manufactured home
– Site completion of exterior French doors that cannot be
completed in the factory due to potential damage during
home shipment
– Site completion of roof dormers including windows in
dormers that cannot be completed in the factory due to
shipment height limitations
 On Site Completion
– Site completion of sidings not considered close-up, such as
stone, brick, stucco, or other materials that cannot be
installed at the factory due to transportation challenges
– Site completion of limited, specific building components
such as any appliance and or fireplace provided they are
listed or certified for use in manufactured homes (may be
provided by retailer, purchaser, manufacturer
– Removable or open floor sections to accommodate
basement stairs
– Completion of sidewall bay windows
– Completion of site installed tile tub surrounds
 Alternative Construction
– Homes that will not comply with the standards
• Two story home designs
• Accessible Showers
• Homes without floor insulation installed over heated basements
– Triple Wide homes with center section roofs installed at the site
– Use of tankless water heaters
– Homes that exceed 2571 square feet, due to WHV requirements
– Homes with les than 50 amp power supply
– Homes with site construction specifically addressed otherwise
• Garages
• Carports
 Installation
– Exterior siding close up at mating line
– Chain hung lighting fixture completion
– Completing ceiling suspended fans
– Exterior lighting fixture completion
– All low slope (less than 7/12) hinged roof completion for Wind Zone 1 only.
– Peak flip and peak cap roof completion for low slope (less than 7/12), Wind Zone 1
– Duct connection between home sections
– Main power supply connection and section crossovers
– Dryer venting completion
– Range cooktop exhaust termination vent
– Plumbing connections between halves
– Gas line connection between sections
– Mate line gasket
– Floor, roof, wall interconnections
– Evaporative/Swamp Coolers
 Building Permit to Occupancy Permit
• Permits to install a manufactured Home can only be issued to a licensed
HUD installer a list is maintained at manufacturedhousinginstalltion.com.
There is an exception for homeowners to install their own home.

• Homes must be installed to the Manufacture Installation Manuals or if an

alternative foundation plan you should have a plan that has an
engineer’s/registered architect seal and seal from the manufacture and
its DAPIA. You can at your option require a state seal from the PE or RA
HUD does not require state specific seals.

• Permits for trade work attachments are at the discretion of the local
building department.
 Building Permit to Occupancy Permit
• Inspection for foots and or slabs before a pour is at your discretion.

• Your finial inspection for installation should be based on the Manufacture

Instruction Manual and any supplement plans approved for the house.

• If the HUD label has an AC or SC in the label number there also should be
an inspection form showing that that work has been inspected before
your finial inspection. We will go over what you need to do for a final
inspection. On another side,

• After all inspections are passed you sign off on the HUD 309 form and
the house can have an Occupancy permit issued one is issued by your
locality.
 Foundations for HUD Code homes
• In freezing climates there are two options for compliant foundations.

• Test soil and if it is non frost susceptible then you can use a standard
slab, runners, or pads.

• For a site to be non-frost susceptible the soil must be tested and must
have less than 6% fines passing a #200 Sieve on an ASTM D442 test. HUD
allows a licensed installer to take the samples on a single site and send
the soil to a lab for the test.

• Untested or sites that fail need to have a frost protected foundation

system that is an alternative design to what is in the standard MII
Non Frost Susceptible Design
Frost Protected Slab Design
Insulated Skirting Design
Insulated Skirting Design
 Other Solutions
• Manufacturer
approval of
proprietary
system/design
HUD’s Inspection Form (HUD 309)
Inspection Photographs
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 Thank You.
For more information visit:
www.hud.gov/mhs

Or e-mail:
[email protected]
“ The mission of HUD is to create strong, sustainable, inclusive communities
and quality affordable homes for all. ” 59