Part V

The Mobile Home design

The manufacturer certifies each design and the performance data obtained by various technical methods for each design for a particular model of home as being compliant with the federal standards and remember; that standards in almost all instances are performance standards rather than specifically required standards. The design is then guaranteed to meet the federal standards by inspection and then approval of such design by the Secretary of HUD's or HIS DESIGNEE. The manufacturer certifies that the home is constructed in accordance with the design and meets all applicable federal standards by affixing the HUD/FHA label on each home. This manufacturer's certification is monitored through or by the production inspection process. This design and performance data includes a detailed set of provisions for support and stabilization that will insure that such home will perform as certified by the manufacturer and approved by the Secretary's designee if followed. Everything contained in the manufacturers design is a part of "mobile home construction". Let's look at the Federal Standards.

It was the intention of this report to avoid the publication of large amounts of technical material such as standards that could easily be obtained on-line or from various other sources. This is however important to the continuity of the report and it will exclude parts of it by placing in bold type and/or underlining the information of special interest. Notes will be in Italics only when related to a standard.

Section 3280--FMHCSS

Design and Construction Requirements for a Mobile Home.

3280.301

Scope.

This subpart covers the minimum requirements for materials, products, equipment and workmanship needed to assure that the manufactured home will provide:

(a) Structural strength and rigidity,

(b) Protection against corrosion, decay, insects and other similar destructive forces,

(c) <Protection against hazards of windstorm>,

(d) Resistance to the elements, and

(e) Durability and economy of maintenance.

3280.302

Definitions.

The following definitions are applicable to subpart D only:

Anchoring equipment: means straps, cables, turnbuckles, and chains, including tensioning devices, which are used with ties to secure a manufactured home to ground anchors.

Anchoring system: means a combination of ties, anchoring equipment, and ground anchors that will, when properly designed and installed, resist overturning and lateral movement of the manufactured home from wind forces.

Footing: means that portion of the support system that transmits loads directly to the soil.

Ground anchor: means any device at the manufactured home stand designed to transfer manufactured home anchoring loads to the ground.

Loads: (1) Dead load: means the weight of all permanent construction including walls, floors, roof, partition, and fixed service equipment.

(2) Live load: means the weight superimposed by the use and occupancy of the manufactured home, including wind load and snow load, but not including dead load.

(3) Wind load: means the lateral or vertical pressure or uplift on the manufactured home due to wind blowing in any direction.

Main frame: means the structural component on which is mounted the body of the manufactured home.

Pier: means that portion of the support system between the footing and manufactured home exclusive of caps and shims.

Stabilizing devices: means all components of the anchoring and support system such as piers, footings, ties, anchoring equipment, ground anchors, and any other equipment which supports the manufactured home and secures it to the ground.

Support system: means a combination of footings, piers, caps, and shims that will, when properly installed, support the manufactured home.

Tie: means straps, cable, or securing devices used to connect the manufactured home to ground anchors.

Vertical tie: means a tie intended to resist the uplifting or overturning forces.

280.303

General requirements.

(a) Minimum requirements. The design and construction of a manufactured home shall conform with the provisions of this standard. Requirements for any size, weight, or quality of material modified by the terms of minimum, not less than, at least, and similar expressions are minimum standards. The manufacturer or installer may exceed these standards provided such deviation does not result in any inferior installation or defeat the purpose and intent of this standard.

Remember our definition for "manufacturer", any person engaged in the manufacture or assembly of a mobile home. Remember the definition for "mobile home construction", all activates related to the assembly and manufacture of a mobile home. What is the purpose and intent of this standard, let's find out?

(b) Construction. All construction methods shall be in conformance with accepted engineering practices to insure durable, livable, and safe housing and shall demonstrate acceptable workmanship reflecting journeyman quality of work of the various trades.

That's the purpose and intent of this standard, to insure durable, livable, and safe housing and is accomplished by using accepted engineering practices.

(c) Structural analysis. The strength and rigidity of the component parts and/or the integrated structure shall be determined by engineering analysis or by suitable load tests to simulate the actual loads and conditions of application that occur. (See subparts E and J.)

The point of (c) is that by certification of the design and performance data by the manufacturer and approval of this design and data by the Secretary's designee prior to the construction of such home, they have by law said that such tests have been performed that show compliance with the federal standards to insure durable, livable, and safe housing, and this would include analysis of support and stabilization to insure the continued performance to the standard and is part of the design package.

3280.305

Structural design requirements.

(a) General. Each manufactured home shall be designed and constructed as a completely integrated structure capable of sustaining the design load requirements of this standard, and shall be capable of transmitting these loads to stabilizing devices without exceeding the allowable stresses or deflections. Roof framing shall be securely fastened to wall framing, walls to floor structure, and floor structure to chassis to secure and maintain continuity between the floor and chassis, so as to resist wind overturning, uplift, and sliding as imposed by design loads in this part. Uncompressed finished flooring greater than 1/8 inch in thickness shall not extend beneath load-bearing walls that are fastened to the floor structure.

Lets take a quick look at what the standard defines as Stabilizing devices; this means all components of the anchoring and support system such as piers, footings, ties, anchoring equipment, ground anchors, and any other equipment which supports the manufactured home and secures it to the ground. All of these individual components are defined above. The allowable stresses or deflections are laid out in another section, and only the relevant standard will be shown.

(b) Design loads--(1) Design dead loads. Design dead loads shall be the actual dead load supported by the structural assembly under consideration.

(2) Design live loads. The design live loads and wind and snow loads shall be as specified in this section and shall be considered to be uniformly distributed. The roof live load or snow load shall not be considered as acting simultaneously with the wind load and the roof live or snow load and floor live loads shall not be considered as resisting the overturning moment due to wind.

(3) When engineering calculations are performed, allowable unit stresses may be increased as provided in the documents referenced in Sec. 3280.304 except as otherwise indicated in Sec. Sec. 3280.304(b)(1) and 3280.306(a).

Note that 3280.306(a) is referenced; let's take a look at this

Section 3280.306 Windstorm Protection

Section 3280.306(b) of this federal standard HUD/FHA claims is really not a federal standard. They have one of two choices in the matter. It is a federal standard as written in the federal standards, or it is not a federal standard. If it not a federal standard then it needs to be removed immediately from the federal standards and placed within an appendix or some other source of reference information. Of course its removal would cause a serious problem since there would be no way to instruct the installer on how to finish the construction of the home and would make it obvious that HUD was not carrying out the intent of this Act. For this reason it is necessary to send instructions for the proper completion of the construction of the home to insure that the home is assembled or completed as per the manufacturers design. This is to insure that improper on-site completion does not to cause the home to fail to perform to the standards and as certified by the manufacturer in their design, which was approved by the Secretary's designee as being in compliance with the federal standards. HUD/FHA has put this absurd assertion in writing that such is not a standard. This shows that HUD/FHA's actions to undermine the intent of this Act are intentional and this action has allowed many lives to be lost and many more injuries to have occurred which may have otherwise not been lost or caused, you can draw your own conclusion as to what this constitutes. There is another serious breach of law by HUD/FHA contained in the regulations that has also caused serious degradation of this program's ability to carry out the congressional intent and purpose of this legislation. This will be covered later, for now, let's move on!

3280.306(a) Each manufactured home shall have provisions for support/anchoring or foundation systems that, when properly designed and installed, will resist overturning and lateral movement (sliding) of the manufactured home as imposed by the respective design loads. For Wind Zone I, the design wind loads to be used for calculating resistance to overturning and lateral movement shall be the simultaneous application of the wind loads indicated in Sec. 3280.305(c)(1)(i), increased by a factor of 1.5. The 1.5 factor of safety for Wind Zone I is also to be applied simultaneously to both the vertical building projection, as horizontal wind load, and across the surface of the full roof structure, as uplift loading. For Wind Zones II and III, the resistance shall be determined by the simultaneous application of the horizontal drag and uplift wind loads, in accordance with Sec. 3280.305(c)(1)(ii). The basic allowable stresses of materials required to resist overturning and lateral movement shall not be increased in the design and proportioning of these members. No additional shape or location factors need to be applied in the design of the tie down system. The dead load of the structure may be used to resist these wind-loading effects in all Wind Zones.

Numbers (2) & (11) are required to be submitted by manufacturer to Design Approval Primary Inspection Agency (DAPIA) as part of the design package.

(2) Structural analysis and calculations, test data and/or other accepted engineering practices used by the manufacturer to validate the design,

(11) Reports of all tests that were run to validate the conformance of the design to the standards.

3280.306(a)(1) the provisions of this section shall be followed and the support and anchoring systems shall be designed by a Registered Professional Engineer or Architect.

This should have the States wondering why on earth HUD/FHA and the manufacturers are telling them that they need to implement their own installation program and design these systems for which a Registered Professional Engineer or Architect has already designed such systems and thereby signifying that the design is capable of meeting this standard. These are federal standards and therefore are enforceable as such. The States should also be asking themselves because of this misrepresentation of the facts by HUD/FHA and the manufacturers if they are in-fact violating federal law. They should also be asking themselves how much money has this cost the State to carry out this fraud perpetrated upon them.

Title VI §604 (d)

Whenever a Federal manufactured home construction and safety standard established under this title is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any manufactured home covered, any standard regarding construction or safety applicable to the same aspect of performance of such manufactured home which is not identical to the Federal manufactured home construction and safety standard.

How does one suppose that HUD/FHA ever intended to carry out to the full extent possible the Congressional purpose of this Act without considering this issue, tie-down/foundation for a mobile home as part of the equation? One thing that is for certain, the architects of this Act certainly considered it essential to whether or not this merchandise was safe to use and made this very clear that these standards were to be a part of the federal standards, enforced by federal law, and they are.

With the federal government claiming the product is safe, throw in some bells and whistles sales gimmicks by the manufacturers and the consumer will never realize that they are just as vulnerable to injury or death from windstorms today as a consumer in 1973. You cannot have 36 or 50 different standards, enforced to varying degrees, 14 states with no standards and guarantee to the consumer a safe home and therefore you cannot expect to carry out the purpose of this Act. It is impossible to believe that a reasonable person(s) would not have known this, but again HUD/FHA is HUD/FHA and HUD/FHA do not always operate in the reality spectrum.

Certainly nothing in this above subsection prohibits a State from creating identical standards, but to what purpose would this serve when the States, provided they take on such responsibility in their State plan, already have the authority under federal law to enforce the windstorm protections standards that already exist. We will discuss State authority after discussing the standard that HUD/FHA says is really not a standard; this is the instruction's to complete the construction of the mobile home, on-site.

Contents of instructions

3280.306(b)(1) the manufacturer shall provide printed instructions with each manufactured home specifying the location and required capacity of stabilizing devices on which the design is based. The manufacturer shall provide drawings and specifications certified by a registered professional engineer or architect indicating at least one acceptable system of anchoring, including the details of required straps or cables, their end connections, and all other devices needed to transfer the wind loads from the manufactured home to an anchoring or foundation system.

It is clear that lawmakers intend to insure that standards were followed by having a system of inspection and enforcement.