Do installation designs and instructions
prepared by a PE have to be approved by the manufacturer and the
DAPIA in all states or only HUD-administered states?
and instructions that are prepared by a PE or RA that are different
from those provided by the manufacturer must be approved by the manufacturer
and the DAPIA as providing a level of protection that equals or exceeds
the protection provided by the federal installation standards in part
3285 only in states where HUD administers the installation program.
State installation programs may deal with the use of alternative designs
The Installation Program final rule clarifies the installation instructions
requirements in states with installation programs and states where
HUD administers the installation program. Section 3286.9(b) requires
the manufacturer to provide DAPIA approved installation designs and
instructions with each manufactured home. This is required in all
states since it is in Subpart A.
Section 3286.103(a)(2) requires designs that differ from the DAPIA
approved designs be prepared by a PE or RA and approved by the manufacturer
and the DAPIA. This is only required in states where HUD administers
the installation program since it is in Subpart B. Therefore, the
state do not have to require manufacturers and DAPIAs to approve designs
developed by PEs/RAs as required in 3286.103(a)(2).
The paragraph in 3286.103(a)(2) was added in response to the MHCC's
concern that HUD did not have any recourse over PEs/RAs if these 'alternative
designs' did not provide a level of protection that equals or exceeds
the protection in the Installation Standards. Therefore, the final
rule requires the designs prepared by a PE or RA also be approved
by the manufacturer and the DAPIA only in states where HUD administers
the installation program.
Are manufactures required to have their DAPIA approved installation
manuals changed (if they are not equal or greater than Part 3285 -
Model Manufactured Home Installation Standards) by the implementation
date of October 20, 2008?
We have been asked if manufactures
are required to have their installation manuals DAPIA approved for
compliance with the Model Manufactured Home Installation Standards
by the effective date of October 20, 2008. The answer is yes. This
requirement applies to all manufactured homes, not just those sited
in HUD administered states. The implementation schedule referred to
in the Manufactured Home Installation Program only applies to the
implementation of the HUD administered installation program in default
Subpart I, 24 CFR 3286.803(b)(1) requires state qualifying installation
programs to have installation standards that meet or exceed the requirements
of 24 CFR 3286.107(a). Does this mean that each state qualifying installation
program will have to require the use of DAPIA and Manufacturer approved
designs for the initial installation of all new manufactured homes
as apposed to using the generalized state-wide installation codes
or model codes, like NFPA 501A?"
Manufacturer must provide with each
new manufactured home, installation instructions that have been approved
by the DAPIA - regardless of the state. These instructions must comply
with the minimum installation standards for the state where the home
will be installed. States may adopt any installation standards that
meet or exceed the federal installation standards in part 3285.
the installer certification required in all states or only HUD-administered
The installer certification is only required in states where HUD administers
the installation program. States that administer their own installation
program will determine the installer responsibilities with regards
to the installation of manufacture homes.
Section 3285.2(d) states: "In making the certification of the installation
when required under part 3286 of this chapter…." Part 3286 only requires
installers in states where HUD administers the installation program
to provide the certification to HUD. States with qualifying installation
programs do not have to require installer certification.
Can you give me some idea
of what the "phase-in schedule", mentioned in 24 CFR 3286.1(b), might
look like so I will know when to submit my Installation Trainer Registration
form (or the State Certification Form)?
We are still working on the phase-in schedule.
However, the phase-in schedule will not have an affect on the Installation
Trainer Registration or State Certification Form. We will be accepting
applications from trainers and states as soon as the Office on Management
and Budget (OMB) approves the proposed forms. This approval is expected
in the coming weeks. Once the Installation Trainer Registration and
the State Certification Form is approved we will be accepting applications
Will HUD recognize a state license if an
installer from a HUD-approved state worked across state lines in a
default state or would they also have to get licensed by HUD?
A licensed installer in a state that administers a qualified
installation program would be required to obtain a HUD license to
install a manufactured home in a state where HUD administers the installation
program. However, an applicant that holds a license in a state with
an approved installation program that issues installation licenses
may seek exemption from the experience requirement - Section 3286.207(b).
Also, an licensed installer in a state with an approved installation
program may postpone the training requirements until 10/20/2009 -
Will state/local inspectors be able to perform
inspections in a state that administers its own installation program
or will the inspectors have to be part of the office that administers
the installation program?
State and local inspectors would be acceptable in states that administer
its own installation program.
Is the installer's license good in all states where HUD administers
the installation program or just the state where the installer received
the training and certification?
The HUD administered
installer's license is valid in all states where HUD administers the
installation program. However, the installer may be required to obtain
state and/or local licenses that are required to do business in a
Will certified installers working within
a state qualifying installation program be required to have the same
amount of training and continuing education as their counterparts
in HUD administered states?
No. In order for a state to have a qualified
installation program the state must have installer training; however,
that installer training does not have to meet or exceed the HUD administered
state's training requirements. Only the state installation standards
must meet or exceed the Model Manufactured Home Installation Standards.
Will certified installers working within
a state qualifying installation program be required to keep the same
types of records as their counterparts working in HUD administered
No. The installer must follow the state's requirements
for record keeping in states that administer its own installation
trying to determine how close a state administered program has to
mirror the HUD administered program's requirements in 24 CFR 3286
Subparts B through H to be accepted?
A state administered installation program must
have the following:
|| Installation standards that meet or exceed the
protection provided by the Model |
||Manufactured Home Installation Standards;|
|| Training and licensing of manufactured home
|| Inspection of the installation of manufactured
Only the installation standards must meet or exceed the HUD installation
standards. The state must have training and licensing of installers
and inspections of manufactured homes - but these aspects do not
have to meet or exceed the requirements in HUD administered states.
What new form will be used as a result
of the installation program final rule?
Are there any conditions under which existing
inventories of painted anchors may be used after October 20, 2008,
the effective date of HUD's Model Installation Standards (Standards),
as painted anchors will not meet the level of protection against weather
deterioration and corrosion as required by 3285.402 of the Standards?
HUD Manufactured Home Manufacturer's
Monthly Production and Shipment Destination Report, Revised Form
Manufactured Home Retailer Report - Home Tracking Information,
HUD Manufactured Home Retailer Report - Home Installation Information,
Form HUD- 306|
HUD Manufactured Home Installer License Application, Form HUD-307|
HUD Manufactured Home Installation
Trainer Registration Application, Form HUD-308|
HUD Manufactured Home Installation
Certification And Verification Report, Form HUD-309|
State Installation Program Certification,
Existing inventories of painted anchors
manufactured prior to October 20, 2008, may be used to install manufactured
homes until February 2, 2009, in all states including those states
in which HUD will administer the installation program. However, since
the HUD installation standards do not preempt state law, states such
as Florida may continue to enforce their own anchoring requirements
on October 20, 2008, including required levels of zinc coating for
weather and corrosion protection of anchors.
Are requirements in the Manufactured Home Construction
and Safety Standards (24 CFR 3280) for inclusion of certain information
in manufacturer's installation instructions applicable if those provisions
are not specifically required by HUD's Model Installation Standards
(24 CFR Part 3285)?
in the Manufactured Home Construction and Safety Standards (24 CFR
3280) regarding manufacturer's installation instructions continue
to apply and are required even if those requirements were not included
or specifically referenced in HUD's Model Installation Standards (24
CFR Part 3285).
Is it permissible to only include the minimum
and maximum permitted angles for diagonal tiedown strap requirements
in manufacturer's installation instructions without any information
to dimensionally describe their location?
No. Without the dimensional information being provided in the instructions,
it is difficult for installers and inspectors to verify that the diagonal
tiedown straps are being installed in accordance within the permitted
range of minimum and maximum angles. Therefore, the dimensional parameters
must be provided in the manufacturers instructions to determine the
acceptability of diagonal tiedown placement and spacing. The Tables
in 3285.402 providing the maximum spacing for diagonal tiedown straps
also include dimensional requirements for installing the straps and
are based on a minimum angle of 30 degrees and a maximum angle of
60 degrees between the diagonal strap and the ground.
Is there a conflict between Footnote 2 in
Figure C to 3285.310 which states that column loads listed in Table
3 to 3285.303 are total loads for both sections while Footnote 3 to
Table 3 states that the maximum column loads shown are for each section
of the manufactured home?
Note 2 is correct. Note 3 of Table 3 to 3285.303 will be revised when
the Model Installation Standards are next updated to read as follows:
"Loads listed are maximum column loads for both sections of the manufactured
Are the plumbing tests required to be conducted
at the installation site by 3285.603 and 3285.604 of HUD's Model Installation
Standards of the water supply and drainage systems for only the elements
of the systems installed by the installer or is a retest of the entire
water and drainage system required including those plumbing parts
provided at the site? If plumbing tests of the water supply and drainage
systems are required, when should they be conducted?
The entire water supply and drainage systems are to be retested in
accordance with 3280.608 and 3280.612 at the site including those
plumbing parts that are field installed at the site. The tests are
to be conducted after all field installed water and drainage piping
is connected to the manufactured home at the installation site but
prior to connection to the water supply and sewer or septic system.
it necessary for an installer to crown the ground surface under the
home so that there are no depressions in which surface water can accumulate
under the home, if the home is skirted around the perimeter between
the bottom of the home and the ground or the home is provided with
a perimeter foundation or enclosure and the remainder of the site
is sloped to remove all ground water as indicated in the illustration
in 3285.203 of HUD's Model Installation Standards?
No. It is only necessary
to crown the ground surface under the home when there is no perimeter
skirting, foundation or enclosure provided between the bottom of the
home and ground as shown in the Figure to 3285.203 of HUD's Model
Installation Standards. However, the remainder of the site must
be graded sloped, or designed to provide drainage away from the home
to the property line.