"The Fuzzy Math of Manufactured Housing Fire Statistics"

Prepared for:
Manufactured Home Owners and Consumers

By:
James and Patricia Tarmann
Co-Members
"The American Internet Society of Manufactured Home Owners"

Each and everyday 53 American Families will lose their Manufactured Home because of a fire! What's worse is that 2.7 will suffer some sort of injury, and 1.3 will lose their lives needlessly!!! In a typical year this amounts to over 19,500 fires, 930 injuries, and 528 deaths. Statistics for the last decade amount to 218,500 fires, 10,133 injuries, and 4,977 deaths...

The Manufactured Housing industry has touted this product as being, safer than, or as safe as, stick built housing, but in all reality your chances of dying in a manufactured home fire is 50% greater than dying in a stick built home fire. Very often multiple deaths occur, (where more than one die per fire) and that the elderly and the young are at the greatest risk.

United States, fire problem!

The fire problem in the United States is very serious. On a per capita basis, the fire problem in the United States is worse than anywhere else in the industrialized world. In the U.S. annual losses from floods, hurricanes, tornadoes, earthquakes, and other natural disasters combined, average just a fraction of the losses from fires. In 1996 we had over 578,500 structure fires, 72 percent of these fires or 416,520 were in our homes. Fifty six percent or 323,960 of these fires were in one and two family dwellings, which also include manufactured housing. 

Statistics have shown that we are "homebodies." We spend 55 to 75 percent of our time at home. Statistics have also shown that fifty-three percent of us feel safest from fire at home. However, the reality is that 78 to 81 percent of all the people who die in fires in the United States every year die at home.  In 1996, this meant that 3,900 people, who died in a home fire, thought they were in the safest place they could be.

Pre-1976 Mobile Homes vs. Today's Mobile Homes or Manufactured homes!

Since the fifties, and before the standards, fires in mobile homes were rampant, hence: "Mobile Homes are Death Traps." Built like tin cans, that held the fire in, to the flammability of the materials used, fire was a significant enemy of mobile homes.

Now that these homes are constructed according to strict standards, they have proved to do little to save lives in manufactured homes. Hence: "Manufactured Homes are Death Traps"! HUD has assumed that if these homes were constructed more like conventional housing, this would reduce fire deaths associated with this product, but has neglected to address the important factors and statistics that would ultimately save lives.

All along consumers have been led to believe that these manufactured homes are safer, but this is based on comparing apples to oranges or manufactured housing to conventional housing. In all reality, these homes pose a much greater risk of fire severity, and loss of life. Manufactured Homes enjoy a much different status, pertaining to Federal Preemption of federal standards over local building codes.

This makes them quite unique, and incomparable to other housing, such as modular homes, and conventional housing. Comparing manufactured homes in this fashion can only be construed as being deceitful to consumers, that rely heavily on this information in their purchasing decision. HUD and the manufactured housing industry have used this tactic for years and have faired well in the short run, but fail to realize that in the end, their own statistics are bound to expose the truth. The American Consumer, even yours truly fell for this misrepresentation Hook, Line And Sinker!

Apartments are a good source to prove the disparity between conventional housing and manufactured homes to apartments.

The Eleventh Edition of Fires in the United States;

Apartment buildings tend to be more regulated by building codes than single-family dwellings. Many apartments are rental properties, which may also fall under more stringent fire prevention statutes. In many communities, apartments have a significantly different socio-economic mix of residents compared to single-family dwellings. They have more low-income families in housing projects or more high-income families in luxury high rises, or they may be centers of living for the elderly. In large cities, they have all of these groups. Because apartment buildings have large clusters of similar people, they can be given special attention with prevention programs on the cause profiles of apartment buildings in different areas of the community.

In 1996, apartments in the United States accounted for only 16 percent of structure fires or 161,980 fires. This figure is considerably lower than that for other housing. The only difference we find interesting is that apartments are more regulated by building codes and fall under stringent fire prevention statutes. In other words, because of its uniqueness, it has been given much more attention.

As we said manufactured housing cannot, and should not be compared to, other forms of housing because it is unique. This uniqueness of the way it is built, and location compounds the difficulty of firefighters' ability to have a good save. Nearly all manufactured home fires are written off as total losses. Even with the introduction of more fire-resistant materials these homes contain more plastics and other materials that burn hotter, and can give off toxic fumes, their design holds heat in and keeps firefighters from getting at the flames. Fire in a singlewide home creates a tunnel effect that completely travels the length of the home. Doublewide homes experience fires on one side of the home and the heat destroys the other half.

In reviewing the above statistics, what we personally found very interesting was the 10-year trend that we had lost 218,500 manufactured homes to fires. This figure represents that in every ten years; we will lose one year total production of manufactured homes, just to fire. This does not even compare to conventional housing, and is alarming!

Some will argue there are many factors that contribute to housing fires, such as careless use of smoking materials, cooking, children playing with matches, etc. These facts we cannot argue, but find it interesting that again manufactured housing is included in these facts by NFPA (National Fire Protection Association) and not as a separate classification. NFPA's report states that the leading cause of home fires was attributed to cooking. This is not the truth as it pertains to manufactured housing in their report. The leading cause of fires in manufactured housing is electrical, quite a difference! By adding these separate structure classifications together, the statistics are diluted making it appear that the causes of fires in manufactured housing is the same as in site built housing.

In the tenth edition of Fire in the United States, manufactured housing was included with the statistics for conventional housing, but mysteriously in the eleventh edition of Fire in the United States, manufactured housing is reported on its own. The report emphasizes that the HUD standard clearly made an impact. However, the manufactured housing fire problem is still significant. Lets examine this closer.

The statistics in the report are as follows, despite an increase in the manufactured housing stock, fires decreased by 21%, deaths by 10%, injuries by 7%, and dollar loss by 18% over the last 10 years.

We lost 218,500 homes; this is the entire production of manufactured homes in one year.

We lost 4,977 persons, and injured 10,133 others, which happen to be people, not a number, and have cost insurance companies two and one half (2 1/2) billion dollars in losses. From 1987 to 1996, fires had decreased by 5,400. Deaths and injuries showed very little decrease, only four (4) lives were saved and only fifteen (15) less injuries. In dollar loss, we find it interesting that that they used 1985 and 1986 statistics, in place of 1995 and 1996. There is a noticeable oscillation in the dollar loss figures presented over the 10-year period. This is marked by a sharp decrease followed by an increase per year until the losses are on average have returned to approximately 240 million dollars per year. Once this level is reached it is followed by another sharp decrease. If we use this repeating trend as the basis for the 1995 and 1996 numbers, noting the reoccurring upward trend in 1992, 1993, and 1994, and also noting that the increases in the previous cycles are non-linear to estimate the 1995 and 1996 losses, the losses for 1995 would be 206.2 million and for 1996 they would be 220.2 million. This oscillation is an interesting trend, one that should be worthy of further investigation, and most notably since if, this is a reoccurring trend, we would not have peaked until 1997-1998 before having a sharp decrease in the following year. While without further investigation it cannot be established at this time, the dates of these increases seem to follow the years when manufactured housing sales were well above average. This could be an indicator that there may have been a breakdown in inspection and in general, quality control programs during the peak production years, that later lead to loss of life, injury, and unnecessary insurance cost to the public and the insurance industry. Given this trend it would be difficult without further study to determine if there has been any significant reduction in property loss since 1986, only peaks and valleys that amount to an average of 209 million, or an 11 million dollar decrease, which is only a 5% decrease over 12 years.

HUD and the manufactured housing industry state, " manufactured housing is built to the highest standards." This element of control set up by congress was to insure consumers that manufactured housing was designed and constructed, with strength, fire resistance, energy efficiency, and quality. All facets of construction in the "house factory" environment are supposed to be monitored and approved by the U.S. Department of Housing and Urban Development (HUD), or an approved State Administrative Authority (SAA).

The monitoring process by HUD has been provided and carried out by state SAA's (State Administrative Agencies) or by a 3rd party privatized inspection agencies, employed by the manufacturers. These agencies are supposed to provide HUD with the inspections of the factories, for compliance with the standards. Manufactured Home manufacturers may or may not have factory personal inspect the homes for defects. Since only a few of the 35 SAA's carry out in-plant inspection functions this leaves only the 3rd party inspection agencies, which are employed by the manufacturer to carry out compliance inspections. In affect HUD has allowed through regulation the judges of compliance to be depended on the will of the manufacturers for their pay and the amount of their salaries.  The standards require that the home be inspected at a minimum at one station by an independent inspector to insure consumers that at least the home was inspected during one step of the manufacturing process, and it is doubtful that this is even being done.

This inspection process leaves much to be desired, and does nothing to guarantee consumers that the home has not fallen through the cracks. ("statistics from Mississippi have repeatedly shown that at least 50 homes, out of 4000 homes, inspected per year on retailers lots, are red tagged for non-compliance with the standards"). What is alarming is the plant inspection record. There are 85 manufacturing plants in the state of Mississippi, but only 72 plant inspections were conducted in those plants in 1997. This boils down to less than one (1) inspection per plant. In 1999, only 64 plant inspections were conducted.

We now know that several of the states no longer perform, or monitor plant inspections. In most cases the manufacturers hire third party inspectors to perform the inspections. Just for arguments sake, if the figures from Mississippi were used as an average across the United States, only 2/3rds of manufactured home factories are inspected each year, and over 3,750 homes that should have never left the factory were sold to unsuspecting consumers and were non-compliant to Federal Standards. Of course this is a conservative estimate, considering the current state of affairs.

On an average, each state SAA receives 500 complaints per year, and maintains over 300 open files at any given time. This amounts to over 19,500 complaints from consumers per year, and over 11,700 open files at any given time, or one (1) out of every fifteen (15) manufactured home buyers felt that their problems were serious enough, or knew that there was someone with whom they could file a complaint, and did so.

This is shocking, since most consumers would rather just accept, and live with the problem, then to face all the barriers and bureaucratic red tape from HUD, and state agencies. Too many consumers also do not know what conforms or does not conform to the federal standards, and therefore assume that their exorbitant maintenance bills are just part of the bargain.

Most complaints that manufactured home owners make, have very little to do with the latent defects that are hidden in the construction process that may one day take their lives. The leading cause of fires in manufactured homes is as follows, with number 1 being the most common to number 4 being the least: (1996) 1-Electrical Distribution, 2-Heating Systems, 3-Arson, 4-Cooking.  (1994) 1-Heating Systems, 2-Electrical Distribution, 3-Cooking, 4-Arson.

How can the manufactured housing industry and HUD, say that Manufactured Housing is safe when the top two causes of fires are the product itself. Had this product been sold as a children's toy or a tire that Firestone made recently, they would have surely had a recall.  What we find interesting is that it only takes one child to be killed by a toy and it is recalled (Burger King) or one person in the state of South Carolina to die from a Firestone tire and it is an out rage.  In the last ten years, we lost over 300 persons to manufactured home fires, including children, in the state of South Carolina alone, and nothing is said.  Could this be because this information is just now being released?

Up until recently, there have been several articles released by HUD, USFA (United States Fire Administration), NIST (National Institute of Standards and Technology, NFPA (National Fire Protection Administration. The summation of the articles is that, smoke alarms in 40% of fatal fires in manufactured houses, were not present or working properly. HUD's ninth report to congress (1995) suggests that consumers removed or neglected to install the smoke detectors. Yet, the standards in 1976 mandated that units be provided with smoke detectors. The Congress passed the Act in 1974 requiring the establishment of Federal Construction and Safety Standards by 1976. The number one reason Congress found this necessary is because mobile homes caught fire much easier and burned much more quickly. The new federal standards in 1976 mandate that all mobile homes produced be equipped with smoke alarms. Does it mention that consumers are to install the smoke alarms? It is the manufacturer's responsibility to install the smoke alarms, and it is HUD's job to have processes to insure that the smoke alarms are installed and are tested as required by the standards.

Most consumers have heard and read that careless smoking was responsible for fires and a great number of fatalities.  Careless smoking at one time was significant. In the early 80's in the U.S., we experienced over 104,000 cases of home fires associated with careless use of smoking materials. Since then, this number has dropped considerably to around only 35,000 fires. This is a 66 percent decrease.  In our opinion, this decrease was a direct result of the furniture industry making their products much safer for consumers, and little to do with added safety measures of the homes, respectively.

Smoke detectors do save lives. Your chances of surviving a home fire with a detector is 45 percent greater. In the United States 93 percent of homes have at least one detector, but statistics have shown that of only 45 percent of reported home fires, 60 percent of the fatalities had no detectors and 46 percent of occupants when there was a fatality thought that they did work. There were two main reasons for non-working smoke alarms given. 1. Power source missing or dis-connected, 60 percent of the time. 2. Dead batteries. 72 percent of detectors in the U.S. are battery operated, and these accounted for 93 percent of detector problems.

The above statistics applied to manufactured housing fires is alarming. Here we have a device that increases your chances of surviving a fire by at least 45 percent, installed in a product that doubles your chances of losing your life in a fire and all that HUD could manage to do was slap a battery operated smoke detector on the wall, because it was cheap, and not their fault if it did not work 93 percent of the time! This has changed in the last few years. Smoke detectors are now hard wired, to the homes electrical system, but now they only work if connected properly. We will have to wait for these frightening statistics, since electrical distribution is one of the leading causes of manufactured home fires!

In January of 1995, HUD and USFA entered into an agreement to consider possible improvements in fire safety for manufactured homes. They decided that improvements should be cost effective and should be able to be applied to the existing manufactured home stock. Then in 1998, HUD announced that they had selected the National Fire Protection Association, NFPA, "to be a consensus, standards development organization, to develop and maintain standards for the manufactured housing program.  Five years after their agreement with USFA, on May 18,2000, the Department of Housing and Urban Development (HUD) issued a proposed rule on the placement of smoke alarms in manufactured homes. The NFPA, now estimates that in 40% of fatal fires in manufactured homes smoke alarms were not either present or were operating improperly. In general, the new standard requires more smoke alarms to be installed, and interconnected. Finally, all smoke alarms must be tested at the factory to ensure that all are working properly. Does this paragraph suggest that it took five years for HUD to make a decision on smoke alarms, and to see to it that they be tested at the factory. If 5000 people parish in manufactured home fires, over a ten-year period, then we lost 2,500 people over the past 5 years or 12,500 since the standards, (conservative figure), were adopted, and put into force. One would assume that since the introduction of smoke alarms, a vital life saving device installed at the factory, would have been tested all along, and not treated as such a burden.

Pending Legislation!

Recently, there has been legislation pending that would take this industry out of HUD's control, and allow the industry to police themselves. We would not be a bit surprised if Congressman Rick Lazio, who introduced this legislation on behalf of the industry, would find the following statistics for the State of New York interesting, and feel a little embarrassed, but then Congressman Lazio has very few if any constituents in his district that live in manufactured housing!

In 1998 there were 195,000 mobile homes in New York. One mobile home burned for every 35 apartments and homes that went up in flames. Elton Cappiello, Franklin County Fire Coordinator states that manufactured homes are completely "gone within two to 15 minutes," "It's the same as being in a blast furnace or a metal coffin." James Hannigan, executive director of the New York State Association of Fire Chiefs wants sprinkler systems in all manufactured homes in New York. The sprinklers would be in each room and would put down or slow the spread of a fire. "You need all the lead time you can get in manufactured home fires." Mobile -home manufactures and contractors have opposed such measures, saying it would drive up the price per unit. Daniel Corbin, spokesman for the Professional Insurance Agency of New York states "there's more of an exposure to loss, especially to fires, because of the size of the structures and the dynamics of fires inside them, nearly all mobile home fires are written off as total losses"!

While fire sprinklers systems are not currently feasible for manufactured homes, the fact that fire fighting professionals would be proposing such an extreme safety measure for manufactured housing is a statement about the seriousness of fires in manufactured homes. The industry often opposes making manufactured housing safer because it drives up the cost per unit, but the industry does not hesitate throwing away thousands of dollars on fancy moldings and plush carpeting that emit toxic fumes and make the fire burn hotter, just to sell more homes! We guess if it is going to burn anyway, it may as well burn fast and furious as well. We often wonder why manufactured housing is referred to as affordable housing, and now we know.

HUD would love for consumers to believe that they are "On our Side" in all reality they are in bed with this industry.  The Act and its standards, because of HUD's failure to implement and enforce have not improved the industries way of doing business or their product. We as consumers want the prestige of owning a home and the industry knows this, and knows what sells these homes. This is why they build homes that have many of the same amenities and appearance of site built housing, less the safety of site built housing. What the consumer is not aware of because of their belief in their government is that their safety is sacrificed in the bargain to keep the manufacturer's bottom line down. The said equation to this is that HUD helps the industry sell more homes by giving us what we wanted, "but failed to insure that safety and durability came first, while telling us that it did.

The purpose of this report is to share the information that we have collected while investigating the dangers that our family is being subjected to.  A HUD inspection revealed 23 Federal violations. The frightening thing is that although the inspection revealed that our furnace is equipped with the wrong orifices, the smoke alarms that we depend on for early warning, are wired to defective ground fault circuits. All of this and HUD failed to cite the manufacturer with a "serious defect" or "imminent safety hazard." HUD also instructs the manufacturer to make repairs but fails to require that the repair plans are sound repair methods and they WILL NOT, follow-up to insure that the repairs are completed, despite our numerous requests for their help in protecting our family.