I spent much of last week in DC at the Manufactured Housing Consensus Committee (MHCC), a federal advisory committee to HUD regarding the regulation of manufactured housing.*
The MHCC was created through a bill passed in 2000. (“The Manufactured Housing Improvement Act.”) One task the committee performs is to consider public suggestions for changes to HUD’s regulation of manufactured housing.
For context, things do not move quickly in this august body, which operates under Roberts Rules of Order. In the October 2010 meeting the committee tabled (not for the first time) the first public suggestion it ever received for consideration (probably back in 2002 or so), regarding a testing protocol for Manufactured Home anchoring systems.
In my opinion, the committee is better at holding things up than getting things done. The committee is comprised substantially of industry representatives, and my perception is that their goal is to use the committee to delay or kill new regulations for the manufactured home industry.
Two highlights from the last meeting:
Preemption of Local Fire Sprinkler Requirements:
Under current law and HUD rules, if a locality requires fire sprinklers in single family dwellings, they are required in manufactured homes. As more localities adopt the 2010 International Residential Code (which requires fire sprinklers in single family dwellings), such requirements are becoming more common.
My perception is that many manufactured home manufacturers would like to be exempted from such safety requirements. (I guess this follows the previously noted industry logic that manufactured homes aren’t dwellings.) This topic precipitated a discussion of fires in manufactured homes, in which an industry lobbyist quoted, apparently as proof of manufactured home safety, a 2004 USFA report stating that deaths in manufactured homes have fallen dramatically (57%!) since 1976, (the date at which manufactured homes were first subjected to a federal building code).
Unfortunately, the lobbyist forgot to mention (inadvertently, I’m sure) data from that same report which indicated that the per-fire death rate in manufactured homes remains twice that of conventional housing. He also skipped over data elsewhere (but from the same source) indicating manufactured homes have a fire death rate per 100,000 housing units 32-50 percent higher than the rate for other dwellings.**
The fire sprinkler issue was sent to a subcommittee for further review.
Wheelchair and Walker Accessibility:
Have you bought a washer/dryer recently? Ever noticed some of them have a sticker saying something along the lines “suitable for use in a manufactured home”?
Why do they need this sticker? Well, the building code for manufactured homes only requires a 28-inch entry door, and many regular-sized appliances won’t fit.
Besides being a pain for finding usable appliances, this twenty-eight inch door standard is a barrier to the accessibility of manufactured homes for people with disabilities. For those keeping track, twenty-eight inches is four inches smaller than the thirty-two inch door clearance called for under the Uniform Federal Accessibility Standards, and eight inches smaller than a standard front door.
A proposal to increase the minimum size of manufactured home entry doors has been pending before the committee for several years. In this meeting, the committee took the bold action of sending the proposal back to an informal task-force for further consideration. On the upside, the task force will also be considering requiring an increase in the minimum width of access to one bathroom and one bedroom in each manufactured home unit.
That’s about it for the meeting highlights. If this blog post interested you, I’ve got good news for you: there are two empty consumer seats on the MHCC. If you apply now, you might be able join me for the spring 2011 meeting.
*You probably call them mobile homes or trailers. (But not RVs—those considered cars.)
** To be fair, other sources indicate that while more people die per-fire in manufactured homes, there are fewer fires, so the death rate per-home is comparable between manufactured and conventionally constructed homes.