[Federal Register Volume 59, Number 10 (Friday, January 14, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 94-825]
[[Page Unknown]]
[Federal Register: January 14, 1994]
_______________________________________________________________________
Part II
Department of Housing and Urban Development
_______________________________________________________________________
Office of the Assistant Secretary for Housing-Federal Housing
Commissioner
_______________________________________________________________________
24 CFR Parts 3280 and 3282
Manufactured Home Construction and Safety Standards on Wind Standards;
Final Rule
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Office of the Assistant Secretary for Housing-Federal Housing
Commissioner
24 CFR Parts 3280 and 3282
[Docket No. R-93-1632; FR-3380-F-02]
RIN 2502-AF91
Manufactured Home Construction and Safety Standards on Wind
Standards
AGENCY: Office of the Assistant Secretary for Housing-Federal Housing
Commissioner, HUD.
ACTION: Final rule.
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SUMMARY: HUD is amending the Federal Manufactured Home Construction and
Safety Standards (FMHCSS) to improve the resistance of manufactured
homes to wind forces in areas prone to hurricanes. Under this rule,
manufactured homes will have to be designed to withstand wind speeds of
up to 110 miles an hour in hurricane-prone areas, in accordance with
design provisions of the American Society of Civil Engineers Standard
ANSI/ASCE 7-88. Also, the Department is making certain other changes to
the standards to ensure that structural assemblies, components,
windows, connectors, and fasteners will be adequate for the area in
which the home is to be placed. The revised standard also requires
exterior roof and wall coverings to be fastened adequately to sheathing
and framing members, to resist higher design wind pressures.
The purpose of this rule is to increase the safety of manufactured
homes, thereby reducing deaths and injuries and extensive property
damage losses in areas where wind-induced damage is a particular hazard
and risk.
EFFECTIVE DATE: July 13, 1994, except that Secs. 3280.403(b) and (e)
and 3280.404(b) and (e) will become effective January 17, 1995. The
incorporation by reference of certain publications listed in the
regulations is approved by the Director of the Federal Register as of
July 13, 1994, except that the incorporation by reference of
publications listed in Secs. 3280.403(b) and (e) and 3280.404(b) and
(e) will become effective January 17, 1995.
FOR FURTHER INFORMATION CONTACT: G. Robert Fuller, Director,
Manufactured Housing and Construction Standards Division, Department of
Housing and Urban Development, 451 Seventh Street, SW., ATTN: Mailroom
B-133, Washington, DC 20410-8000. Telephones: (voice) (202) 755-7430;
(TDD) (202) 708-4594. (These are not toll-free numbers.)
SUPPLEMENTARY INFORMATION:
I. Background
Developmental History
The purpose of the National Manufactured Housing Construction and
Safety Standards Act of 1974 (42 U.S.C. 5401-5426, at 5401) (the Act)
is to reduce the number of personal injuries and deaths and the amount
of insurance costs and property damage resulting from manufactured home
accidents, and to improve the quality and durability of manufactured
homes. Section 604 of the Act confers authority on the Secretary of HUD
to issue, amend, or revoke any Federal manufactured home construction
or safety standard.
Following Hurricane Andrew, the Department conducted field
investigations of the damage experienced in the hurricane by
manufactured housing units, as part of a full-scale review of the
Federal manufactured home standards. The goal of these investigations
and the review of materials and recommendations was to ensure that the
Federal standards provide adequate protection to manufactured home
occupants during high wind conditions. On April 14, 1993, the
Department published a proposed rule (58 FR 19536) that reported the
preliminary conclusions of the Department's efforts, and sought public
comment on changes that the Department was considering for the Federal
standards. The Department also contacted each of the members of the
National Manufactured Home Advisory Council (Advisory Council),
individually, in order to solicit their individual comments on the
proposed wind standards rule, because the proposed timetable for final
publication did not permit convening the Advisory Council. The
individual responses of the Advisory Council members have been
considered as public comments and included in the docket file for this
rule.
On June 9, 1993, the Department announced (58 FR 32316) that the
comment period would be extended to July 9, 1993. The Department has
continued to receive and consider comments well after that date, while
this final rule was being developed. Because the timeframe originally
proposed for the implementation of standard changes was postponed as a
result of public comments and the extension of the comment deadline,
the Department consulted with the National Manufactured Home Commission
and convened the Advisory Council for consultation and to seek
recommendations from the Advisory Council as a whole (see the notice
published at 58 FR 34586 (June 28, 1993)). The Advisory Council met in
Washington, DC, on July 13 and 14, 1993, to discuss wind standards and
other proposals for changes to the standards for manufactured housing.
The recommendations of the Advisory Council as a whole were
included in a resolution. The resolution questioned the sufficiency of
the evidence to support adoption of the proposed rule and recommended
that: (1) The Department undertake negotiated rulemaking or other
comparable process for this standard; (2) the costs of any rule be
considered, both cumulatively and by zones; (3) the Department examine
its legal and regulatory authority with respect to installation, if it
finds that an installation standard would be an appropriate means of
increasing wind safety; (4) the Department consider all nationally
recognized model codes; (5) the Department make available documents
relating to the development of new wind standards; (6) the Advisory
Council be reconvened to review public comments and the Department's
analysis; (7) the Department should promptly complete the process of
updating the wind standards, considering the issues and questions
raised by the Advisory Council and in public comments; and (8) the
Department should prepare an adequate regulatory impact analysis upon
which it can support the decisions to be made on implementation of new
standards.
The Department has considered the conclusions and recommendations
of the Advisory Council in developing this final rule and the final
regulatory impact analysis. The regulatory impact analysis is
responsive to several of the Advisory Council's concerns, while this
preamble addresses other points raised by the Advisory Council.
With respect to the other points raised by the Advisory Council,
many commenters also suggested that installation is a crucial factor in
the safety of manufactured homes. The Department agrees that the
installation of manufactured housing units may be an important factor
in the safety of such housing and is initiating a review of the
Department's authority and ability to influence tiedown requirements.
However, the Department does not believe there is any significant
advantage in, or that the public interest would be served by,
reconvening the Advisory Council for the purpose of reviewing the
public comments or the Department's compliance with its statutory
responsibilities in the development of these standards. Nor does the
Department believe there is any advantage to the public interest in
undertaking negotiated rulemaking for these standards because they have
been subject to an extensive notice and comment period and have been
discussed with the Advisory Council, a body representative of the
manufactured housing industry, government, and consumers.
Major Differences From Proposed Rule
As a result of the Department's review of public comments and
consultation with the Advisory Council, at this time the Department has
decided not to pursue substantial changes to the standards in areas of
the country not generally subject to hurricanes (Wind Zone I). However,
the Department recognizes that in many areas of the country the Federal
standards applicable to the design and construction of manufactured
housing are far below standards specified for site-built and modular
housing by State and local codes. Thus, the Department shall initiate a
new review of the standards for the rest of the country, and it expects
to publish proposals for these areas next year.
The Department has also decided not to include in the final rule
the following items that were in the proposed rule:
(1) Maximum dimension of 12'' for roof overhangs;
(2) Lower load duration factor than provided in the 1991 National
Design Specification for Wood Construction (NDS);
(3) Requirement for a 1.5 safety factor to calculate resistance of
anchoring and foundation systems to higher design forces in Wind Zones
II and III;
(4) Manufacturer's design and details for a permanent foundation
system (certified by a registered professional engineer or architect)
applicable to each manufactured home design; and
(5) Shortened period for implementation of the standards after
publication.
Relationship to Energy Rule
On October 25, 1993, the Department published a final rule amending
the Federal Manufactured Home Construction and Safety Standards
(FMHCSS) to include preemptive standards significantly upgrading the
existing energy conservation requirements (58 FR 54975) (Energy Rule).
The effective date of that rule is October 25, 1994.
Several of the provisions to be affected by the Energy Rule are
also affected by the rule published today. Because of the earlier
effective date for those provisions in today's rule, the Department
will publish technical amendments to the Energy Rule, before the
effective date of that rule, that also will reflect the new
requirements imposed under today's rule. In some minor instances, the
changes adopted in today's rule already include requirements that
otherwise would have been imposed upon the effective date of the Energy
Rule. Those changes are identified further in the section-by- section
analysis later in this preamble.
Problem To Be Addressed
Each year significant damage to manufactured housing is produced by
straight winds, hurricanes, and tornadoes. Damage is primarily in the
form of roof failure, loss of roof diaphragm material, connection
failures, and tiedown/foundation failures. The most predictable areas
for wind damage to manufactured housing are those subject most directly
to hurricanes. Last year Hurricanes Andrew and Iniki provided dramatic
examples of the destruction faced by housing in hurricane-prone areas.
The damage to manufactured homes by Hurricane Andrew was so
extensive that many were rendered unrecognizable. Ninety-seven percent
of all manufactured homes in Dade County were totally destroyed, while
only eleven percent of single-family homes were destroyed. The American
Red Cross reported that of the 1,176 licensed and registered
manufactured homes in Homestead, Florida, 1,167 were completely
destroyed. The American Red Cross and FEMA have also reported a total
of 11,213 manufactured homes destroyed in Florida and Louisiana in
Hurricane Andrew, and an additional 3,016 manufactured homes
experienced major damage. Almost 36% of all housing units destroyed
during Hurricane Andrew were manufactured homes.
The loss of these units had implications extending beyond the loss
of the homes and possessions of their owners. These homes, shredded by
the winds, also became dangerous flying missiles, inflicting more
property damage on neighboring structures.
In its October 1992 report on Hurricane Andrew, the Federal
Emergency Management Agency (FEMA) stated that, ``in all areas, mobile
homes (manufactured housing) were most susceptible to damage or
destruction. Many mobile homes imploded from the wind loads of
Hurricane Andrew. In coastal areas, where mobile homes were properly
`cradled' and elevated, the cradled foundations remained intact, but
the mobile homes mounted to these foundations were often heavily
damaged or destroyed.''
Concerns for potential losses during high winds in coastal and
other areas were identified previously in a May 1991 report by the
Federal Emergency Management Agency (FEMA), which predicted that the
United States can expect more hurricanes of greater intensity during
the 1990s and early 2000s than it has experienced in recent years.
Furthermore, estimates suggest that by the year 2010 the population
density on Florida's coasts will have increased about 130 percent from
the 1988 level. Moreover, as the national population ages, an
increasing percentage of coastal inhabitants will probably be older
individuals, a group more likely to occupy manufactured houses. The
American Association of Retired Persons (AARP) reports that 40 percent
of the purchasers of new manufactured homes are at least 50 years old.
The elderly can be more difficult to evacuate and may be more prone to
be injured during periods of extreme high winds.
The technology for achieving economical wind resistant designs in
housing is available. It involves calculations of risk for extreme
wind-prone coastal areas and the establishment of construction
standards based upon these risk calculations. Through use and
implementation of this approach, risks of injury and death can be
minimized and economic loss limited to acceptable levels in coastal
areas subject to high winds.
In determining a course of action to address these issues, the
Department had to balance two competing concerns: (1) The need to raise
manufactured housing standards, to protect individuals, their homes,
and their neighbors from future high winds; and (2) the need to
preserve the affordability of a key source of low-cost housing. This
rule is the result of the Department's decision to improve protection
of homeowners in hurricane- prone areas as soon as possible, but to
delay making changes to the standards in lower wind-risk areas, in
order to give adequate consideration to cost factors. Although the
changes are expected to increase costs to consumers in the high-wind
areas, the Department has concluded that the increases are justified,
because the improved standards will significantly reduce future losses
to occupants and the public by strengthening the features that make
manufactured homes vulnerable to damage and destruction in high winds.
Perhaps more importantly, the improved standards may help avoid the
inestimable costs of devastation to people's lives and emotional health
and to the communities, in the likelihood that another powerful
hurricane hits a community of manufactured homes in the hurricane-prone
regions of the country.
Field Investigations--Hurricane Andrew
Among the major deficiencies contributing to manufactured housing
damage in Hurricane Andrew were inadequate connections between exterior
roof or wall coverings and supporting sheathing or framing and between
walls, roofs and floors. In particular, losses of roof coverings were
widespread, and were considered by some to be the first mode of failure
for manufactured homes damaged in Hurricane Andrew. Other roof-related
damage was due to loss of sheathing, failure of connections, or a
combination of these problems. Numerous failures of uplift straps also
occurred, when the staples pulled out through the metal straps,
permitting the straps to tear away from the members to which they had
been fastened. In some cases, entire sections of roofs were blown away.
Another common area of failure was loss of exterior wall siding.
Metal or plastic siding used in manufactured housing was readily
damaged or penetrated by flying debris during the high winds in
Hurricane Andrew. Loss of roof or wall cladding allows the building to
be penetrated by the weather and has far-reaching consequences beyond
the area of envelope integrity.
As a result of these losses, and damage to windows and doors, there
was significant water damage and deterioration to many manufactured
homes. In addition, failure of coverings or attachments to the
manufactured home structure also caused missile-type damage to other
homes.
Other losses were precipitated by prior deterioration around
windows and doors that had allowed moisture to enter, thereby weakening
the resistance of surrounding wood framing and floor decking.
Apparently this deterioration was a result of inadequate design or
enforcement practices, or a combination of both. In some manufactured
homes the loss of opening protection resulted in increased internal
pressures within the buildings, which contributed to the failure of
interior components including ceilings. In other cases, entire sections
of sliding glass doors on leeward walls were literally sucked out of
their frames because of inadequate resistance of the combined assembly
to the wind forces imposed during Hurricane Andrew.
Edges and corners of roofs and endwalls of manufactured homes
appeared to have been particularly vulnerable to the high wind forces,
according to the damage typically reported in these areas. Structural
failures of endwalls also occurred, but the presence of nearby interior
shearwalls prevented further losses (though not all designs are
provided with interior shearwalls in the vicinity of the endwall).
However, in many other cases, the entire superstructure was completely
removed from the floor system.
Numerous anchor system failures were reported in the areas
subjected to the highest wind speeds. Many of the systems failed due to
improper installation or the type of anchor used. In addition, anchor
capacity appeared to have been reduced further because of the saturated
condition of the soil.
Summary of NIST Report
As part of its review of the adequacy of the Federal Manufactured
Housing Construction and Safety Standards (FMHCSS), the Department
contracted for a study by Dr. Richard D. Marshall of the National
Institute of Standards and Technology (NIST) [Report NISTIR 5189, May
1993]. According to Dr. Marshall and several other investigative
reports, damage to manufactured homes in Hurricane Andrew ranged from
loss of roofing to total destruction. In general, HUD-labeled units
suffered less damage than did pre-HUD units. However, conventional
residential construction adjacent to manufactured home parks performed
better, in some instances significantly better, than did manufactured
homes. Based on wind speed assessments and damage surveys, it appears
that HUD-labeled manufactured homes began to experience damage to roof
and wall coverings at fastest-mile wind speeds of up to 95 mph (43 m/
s), and significant structural damage at wind speeds of from 100 to 120
mph (45 to 54 m/s).
Commonly observed failures included loss of roof membranes and
blow-off of roof sheathing, failure of uplift straps at truss-to-wall
connections where staple crowns pulled through the strap, loss of
cladding on endwalls and near corners where large negative (suction)
pressures developed, loss of appurtenances with resultant missile
damage and damage to the primary house unit at connection points,
complete separation of the superstructure from the floor and chassis
frame, and loss of the complete unit because of the failure of tiedown
straps or the withdrawal of soil anchors. The NIST report also pointed
out that the capacity of the anchors appeared to have exceeded the
marginal resistance of the superstructure, and that if the
superstructure separation failures had not occurred, the number of
anchor systems failures could have been much more widespread.
In almost every case in Florida, some form of anchoring had been
installed. Outside the area of strongest winds, there were relatively
few anchor failures. Within the radius of strongest winds, anchor
failures that were observed involved 2 ft. (610 mm) helical ground
anchors (some embedded in about 3 cu.ft. (0.8 cu.m) of concrete) or
rock anchors into coral. No failures of 4 ft. (1.2 m) helical anchors
were noted. However, it is not clear that any anchors of that length
were actually installed in the area subjected to the highest winds.
Dr. Marshall of NIST compared wind load provisions of the current
FMHCSS with the American Society of Civil Engineers (ASCE) Standard
ANSI/ASCE 7-88, the South Florida Building Code, the Standard Building
Code, and wind design provisions proposed by the Manufactured Housing
Institute. Based on these comparisons of design loads for manufactured
housing units of typical dimension and geometry, considering the
rationale for using importance factors and unreduced pressure
coefficients, and in view of the fact that it is a true consensus
standard, Dr. Marshall concluded that ANSI/ASCEP 7-88 should be the
basis for updating the wind load requirements for manufactured housing.
In addition, since the NIST study only addressed design loads, in the
interest of safety and economy, it was also recommended that
prescriptive requirements of the proposed standard be consistent with
the specified design loads and that testing and analysis to assure this
consistency be conducted.
ASCE 7-88: Consensus Procedures for Development and Adoption
The ASCE, founded in 1852, is the oldest civil engineering
organization in the United States and has a membership of more than
110,000. The ANSI/ASCE Standard 7-88, Minimum Design Loads for
Buildings and Other Structures (November 1990) (ASCE 7-88, in this
preamble), was developed by ASCE based on studies conducted at academic
and research institutions in the United States and other parts of the
world.
ASCE 7-88 is the only truly consensus minimum design load standard
currently available in the United States. The ASCE rules, approved by
the American National Standards Institute (ANSI), require all standards
committees to have a membership balanced between producers, consumers,
building officials, and general interest groups. Each of these groups
represents between 20% to 40% of the committee membership. At the time
ASCE 7-88 was adopted, 89 members were on the standards committee.
The approval or revision of an ASCE standard is an elaborate
process, which involves extensive balloting and resolution of all
negative votes. When a standard is to be adopted, the standards
committee is broken down by expertise into task committees. Those task
committees draft the standard and present it to the full standards
committee for balloting. All objections within the standards committee
are satisfied by one of three ways: (1) the objector agrees to withdraw
the objection; (2) by a vote of 75%, the full committee accepts the
objection and changes the standard; or (3) by a vote of 75%, the full
committee rejects the objection. The full committee then votes on the
standard.
In order for the standard to pass the full standards committee, at
least 65% of the committee membership must vote and 75% of those votes
must be in the affirmative. Moreover, the affirmative votes cannot be
less than 55% of the approved voting membership. After the standard
passes the standards committee, it is issued to the public for further
comment. As in the standards committee, all objections are individually
considered and processed in the same manner (i.e., withdrawn or
accepted or rejected by a vote of 75% of the standards committee).
After a certain cutoff date and after all objections are addressed, the
standard is published as an ASCE consensus standard.
ASCE 7-88: Wind Load Provisions in Model Codes
Building codes in each State or local jurisdiction control the
design and construction of buildings and structures in that
jurisdiction. Most communities in the United States adopt, in large
part, one of the three model building codes: the National Building Code
of the Building Officials and Code Administrators International (BOCA);
the Standard Building Code (SBC) of the Southern Building Code Congress
International, Inc. (SBCCI); or the Uniform Building Code (UBC) of
International Conference of Building Officials (ICBO). Wind load
provisions in these model building codes are based on the ASCE 7-88
standard, but with some modifications.
The ASCE 7-88 standard considers all of the factors that influence
the magnitude of wind loads on a building. In addition to wind speed,
those factors include: (1) Terrain surrounding the building, (2) shape
of the building, and (3) desired safety of the building frame and
components. The model building codes use most of these factors from
ASCE 7-88, but modify some of the factors based on experience; because
of tradition, other factors are not considered.
Some provisions of model building codes are adopted from industry
manuals. The use, adoption, and modification of wind-load factors by
the model building codes result from an attempt to simplify the wind-
load provisions and react to the concerns of affected industries and
special interest groups. In general, these modifications by model code
agencies result in lower design requirements for wind forces than would
be required under ASCE 7-88.
Even with these modifications, final wind loads for most buildings
are fairly consistent in all model building codes. All three of the
major model building codes incorporate the basic wind speed map of ASCE
7-88, and reference the ASCE standard in whole or in part, but either
modify the standard or require additional prescriptive design and
construction provisions. In addition, all three provide the use of ASCE
7-88 as an alternative to be applied at the discretion of the designer.
However, the model building codes do not cover the design or
construction of manufactured housing. The only control local
governments have over manufactured housing and mobile (manufactured)
home parks is through certain zoning regulations, or anchoring, set-up,
or installation requirements. As noted by one commenter (150) and
discussed in the next section of this preamble, incorporation of the
ASCE 7-88 standard will be critical to ensuring continued acceptance of
manufactured housing by local jurisdictions in high wind areas.
Building Codes in Southern Florida
Generally, the local jurisdictions in Florida have adopted
modifications of the SBC or South Florida Building Code (SFBC). As one
of its primary recommendations in the aftermath of Hurricane Andrew,
the 18-member Dade County, Florida, Grand Jury stated that the 35-year-
old South Florida Building Code must be rewritten to duplicate the
tougher, national wind standard of ASCE 7-88. The Grand Jury recognized
ASCE 7-88 as a standard that more adequately reflects the design
strength necessary for windows and doors. In acknowledgment of the
Grand Jury's recommendations, the Dade County Building Code Committee
adopted (effective January 1, 1994) the Wind Loads section of ASCE 7-
88, using Exposures C and D, only. The Grand Jury further recommended
that Dade County officials issue a moratorium on the permanent
replacement of manufactured homes until officials could be assured that
the replacement homes meet the ASCE 7-88 standards. Further, noting
that lower standards are applied to manufactured housing than to
conventional housing, the 1992 Fall Term Grand Jury asserted that ``the
low standard amounted to discrimination against those persons unable to
afford the costs of conventional housing.''
In its Final Report, filed August 4, 1993, the Dade County Grand
Jury referenced the initial Grand Jury findings regarding the
engineering advantages of the ASCE 7-88 standard and commended its
adoption into the SFBC. The Grand Jury reported that:
[T]his additional and essential modification of the SFBC should
provoke a wide-ranging improvement of most of our building designs,
methods and products. It should also result in the building of
structures that will provide greater safety and security during a
hurricane.
In order to protect those living in and near manufactured homes, the
Grand Jury has reiterated the recommendation that a moratorium be
instituted on the installation in the County of any new mobile homes
that do not meet the wind-loading standards of ASCE 7-88.
In addition, the SBCCI, after assessing the damage caused by
Hurricane Andrew, concluded that standards applicable to manufactured
housing need to be reviewed to bring them up to the level of other
construction types, unless society is willing to consider manufactured
homes to be expendable. The SBCCI said that even if manufactured homes
are considered expendable, the issue of the hazard they present to
neighboring buildings and structures needs to be addressed.
Accordingly, they further concluded that steps need to be taken to
strengthen the structural frame, enforce tiedown provisions, and assure
that the installation of homes is done by those who are knowledgeable
in the requirements of the code. Unless these issues are addressed, the
SBCCI believes there will continue to be great costs associated with
hurricane damage.
Improved Anchoring and Foundation Systems
Enforcement of anchoring and tie-down systems for manufactured
housing construction has generally been considered a State or local
government and their building officials' responsibility. Section
3282.303 of the Manufactured Home Procedural and Enforcement
Regulations (24 CFR part 3282) urges, but does not require, State
Administrative Agencies to monitor installation of manufactured homes.
Thus, standards for foundations and anchorings and enforcement of those
standards are not uniform among the States, and in some States are
nonexistent. For example, the State of Florida has statewide laws
related to installation, but enforcement of those laws is left to local
building officials, while Louisiana is one of 23 States that does not
regulate installation of manufactured homes at all.
The National Conference of Building Codes and Standards (NCSBCS),
under contract with the Department, sent a team to inspect manufactured
homes damaged or destroyed by Hurricane Andrew. Their report, dated
September 25, 1992 (Rev. October 1, 1992), evaluated anchoring systems
used in Florida and Louisiana. The team found that virtually all
manufactured homes they saw in Florida had been anchored, but anchors
had failed in most destroyed homes.
Some of the systems that failed were anchors embedded only two feet
into the soil, which were pulled out of the ground by the force of the
storm. Other systems that failed included short anchors embedded in
concrete or driven into the coral. In Louisiana, most manufactured
homes the team saw had no anchoring systems at all, or only had two or
three anchors on each side; less than one-half the number generally
specified by manufacturers' instructions for hurricane zones. Also,
where anchors were installed, most had been installed incorrectly;
often embedded only partially in the ground with 12'' or more
protruding above finished grade.
While the majority of anchoring system failures appeared to result
from improper installation, the NCSBCS Team observed several cases
where the holding capacity of anchors appeared to have been reduced
because of water saturated soil. In order to determine the adequacy of
anchoring systems installed in soil that might be exposed to heavy
rainfall and hurricane force winds, further investigating and testing
of anchors will be conducted by the Department.
Numerous failures reported after Hurricanes Andrew and Hugo and
other previous wind storms support the Department's concerns over
anchoring systems for manufactured housing that are inadequate to
resist probable high wind forces. In addition, as the NIST Report
indicated: ``[i]f superstructure failures had not occurred [in
Hurricane Andrew], the number of anchor system failures might well have
been greater * * *.''
Some field and laboratory testing of commercially available ground
anchor and steel strapping systems has been conducted under a HUD
contract with Wiss, Janney, & Elstner, Inc. (See WJE Report No. 901798,
July 26, 1991, HUD USER--HUD-0005823). The initial test results
indicate that anchors have a significantly lower load resistance
capacity than even the levels required by the current standard.
Resistance or capacity would be even lower if anchors are not installed
in accordance with anchor manufacturer's and home manufacturer's
installation instructions or under saturated soil conditions.
The Department has also been conducting laboratory tests to
evaluate the resistance of manufactured home support and anchoring
systems to lateral wind and seismic forces. After the results of the
laboratory data have been evaluated and compared to the field data, the
Department may propose changes to lower allowable anchor system
resistance values.
In the interim, the Department cautions home and anchor
manufacturers, installers, retailers, insurance companies, lenders, and
State and local government agencies that anchoring should be rated for
specific soil, loading, and installation conditions for which the
anchor is acceptable. Failure to do so may result in anchoring and
tiedown systems which have inadequate ultimate capacity to resist
probable design wind forces.
II. Analysis of Public Comments
Characterization of Commenters
The Department received 1,116 comments in response to the proposed
rule and the notice extending the comment period. Although
approximately 235 of these comments are included in file of the Rules
Docket Clerk as being received under the extended deadline, many of
these were delayed in receipt in the Rules Docket Clerk office because
they were sent first to other offices within the Department.
The great majority of the comments were duplicative or identical
form letters (of the 1,116 total comments, only 75 to 100 included
distinctive comments). The commenters generally can be characterized as
follows:
-- Businesses (including retailers, manufacturers, suppliers, finance
companies, park owners, etc.)--704
--Industry groups (including State and national associations)--24
--Members of Congress (including original correspondence and
transmittals of constituent letters)--245
--Other governmental agencies and representatives (Federal, State, and
local agencies or representatives)--27
--Members of the National Manufactured Home Advisory Council
(individually)--15
--Individuals (including consumers, engineers and other experts,
salespersons, etc., in individual capacities)--80
--Private standards groups--6
--Consumer groups--2
--Tenants groups--1
--Insurance industry--3
--National Commission on Manufactured Housing--1
--DAPIA (Design Approval Primary Inspection Agency)--2
--Correspondence forwarded from White House--2
--Law firms--3
--Other national associations--1
Many of the comments received by the Department and addressed in
the following discussion were common to numerous commenters. Other less
universal comments addressed in the discussion may be referenced by
number in parentheses following a statement. These numbers correspond
to the number given the comment in the file maintained by the Rules
Docket Clerk. Comments filed as received in response to the original
comment period are referenced as numbers 1-882 (#817 was inadvertently
skipped in the numbering sequence), while those in response to the
extended comment period are referenced as numbers
1(2)-235(2).
Comments, Generally
A number of commenters acknowledged the need to update the
Department's standards for manufactured housing. One commenter (77)
welcomed the better publicity and reputation the industry would enjoy
as a result of updated standards. However, many of these commenters
also stated opposition to the specific standards proposed by the
Department.
About two dozen commenters, including consumer and insurance
industry groups, standards organizations, government agencies, and
engineers, generally supported the basic standard proposed (e.g., 17,
55, 76, 137, 145, 150, 197, 633, 12(2), 204(2), 207(2)),
although several of these commenters also expressed concern about
specific cost items. Supporting comments emphasized the importance of
affordable, safe housing, rather than merely affordable housing (17),
and characterized ASCE 7-88 as the only consensus wind standard in the
Country (76, and others).
Procedural Comments
Comment: The 30-day comment period allowed in the proposed rule did
not permit sufficient consideration of the rule and development of
public comments. In addition, the justification for the shortened
effective date that the proposed rule had indicated would apply to the
final rule was not justified by the need to implement regulatory
changes before the 1993 hurricane season.
Response: Because of the numerous requests for longer response
periods from both the public and members of Congress, and because it
was apparent that a rule could not be in place in time for the 1993
hurricane season, the Department has allowed additional time for public
comments and implementation of the final rule. The proposed rule was
published on April 14, 1993, and the comment period was extended to
July 9, 1993.
Because of the Department's desire to consider the full extent of
public response on this rule, the Department has continued to receive
comments regularly while the final rule and regulatory impact analysis
were being prepared and has continued to log and review those comments.
Therefore, in effect, the comment period for this rule has been
approximately 5 months.
To alleviate the concerns relating to the industry's need for ample
time to redesign homes and retool manufacturing facilities, the
Department has decided to extend the effective date originally proposed
for this rule. Accordingly, the rule provides for an effective date of,
at least, 180 days from today's date of publication. Thus, the concerns
of the commenters in these regards have been addressed by the
Department.
Comment: The National Manufactured Housing Advisory Council should
be convened, as required by law, to consider the standards proposed by
the Department.
Response: Despite the infeasibility of convening the Advisory
Council within the timeframe originally proposed for the implementation
of improved standards, the Department made an extraordinary effort to
consult with the individual members of the Advisory Council. The
responses of a number of the individual members of the Advisory Council
have been considered and included in the docket file for this
rulemaking.
Later, because of the Department's extension of the comment period
and recognition that a final rule could not be in place in time for the
1993 hurricane season, the Department immediately convened the Advisory
Council so that it could discuss the proposal as a panel. The resulting
recommendations of the Advisory Council, as a panel, also have been
considered carefully in determining both the scope and the specific
requirements of this final rule. Additional discussion of the
proceedings of the Advisory Council can be found elsewhere in this
preamble.
Comment: Several commenters questioned the impact of the rule on
families, in the context of Executive Order 12606, which requires
consideration of the impact of a regulation on family formation,
maintenance, and general well-being.
Response: In the proposed rule, the Department indicated that the
rule was not subject to review under the Executive Order. The
commenters questioned this position based on information that some
potential consumers would be unable to purchase manufactured homes if
the prices of those homes were raised to cover the costs of the new
standards. To the extent that production cost increases resulting from
this rule will be passed on to consumers, one effect of the rule is
expected to be the loss of marginal consumers from the market. Some of
these marginal consumers will have to find less expensive, rental
housing; some will opt for comparably priced site-built housing.
However, the significance of this result is not a loss of housing, but
a redistribution of the kinds of housing available. Although as a
result some families may lose an ownership option, the general well-
being of families, and society, is served better by ensuring adequate
quality standards for such housing.
Although the Department does not believe this final rule implicates
family concerns within the spirit of the Executive Order, the
Department has analyzed the rule as required under the Order.
Therefore, in the paragraph on Executive Order 12606 under the ``Other
Matters'' section of this preamble, the Department certifies that the
requirements of the Order have been met in the issuance of this rule.
Comment: The proposed rule indicated that manufacturers should
anticipate the contents of the final rule and should prepare to comply
with the more stringent standards soon after publication of the final
rule. This schedule for implementation of the new standards fails to
recognize the need for lead time to design, test, and seek approval of
changes necessitated by the standard changes. In addition, while
personnel resources are concentrated on the redesign requirement,
production personnel may have to be laid off. This problem is
compounded by the possibility that another redesign will be necessary
as a result of the new Federal energy standards.
Response: To a large extent, the Department already has been
responsive to the concerns expressed in this comment by conceding that
the rule will not become effective for 180 days. The Department is
sensitive to the procedural requirements that a manufacturer faces when
undertaking design changes. However, there is no doubt that by the time
this rule becomes effective, all aspects of the industry should have
had sufficient advance notice of the necessary product improvements to
prepare for implementation of the new standards.
Innovative solutions and safer products generally depend on some
commercial incentive. The Department believes, based on the knowledge
of its technical staff, the reports they have reviewed, and some of the
comments received, that those parties involved in the production,
sales, and siting of manufactured housing will be able to comply with
these standards reasonably quickly, when continued sales depend on such
compliance.
Cost Considerations
Comment: The cost impact of the standard changes should be
analyzed, as required by Executive Order 12291 and 42 U.S.C. 5403(f),
and a regulatory impact analysis should be prepared.
Response: As stated in the ``Other Matters'' section of the
preamble of the proposed rule (57 FR 19539), the Department agreed that
it would prepare and submit a regulatory impact analysis before
publication of the final rule, in accordance with established Office of
Management and Budget (OMB) guidance. Although many of the benefits,
and some costs, of increased standards are difficult to quantify for
purposes of such an economic analysis (e.g., loss of life, uninsured
costs, insurance deductibles, and injuries), the Department has
complied with the requirements of Executive Order 12866 (September 30,
1993) and OMB. As noted under ``Significant Regulatory Action'' in the
``Other Matters'' section of this preamble, a final regulatory analysis
based on the provisions in this final rule is available to the public.
However, while economic concerns have always been an important
component of the Department's decisionmaking process and, in this case,
resulted in modification of the rule, the Department stresses that its
statutory mandate to reduce the number of personal injuries and deaths
and the amount of insurance costs and property damage resulting from
manufactured home accidents, and to improve the quality and durability
of manufactured homes, requires that the Department look beyond
affordability issues. In promoting homeownership opportunities for
lower-income persons, the Department strongly believes that such
housing must also be safe. The concern with safety extends beyond the
occupants of the housing, to all those who may be affected by the
failure of such housing to meet minimum performance standards under
reasonably foreseeable conditions. For example, in a Federal Emergency
Management Agency (FEMA) report on ``Building Performance: Hurricane
Andrew in Florida'' (FIA-22, 2/93), cited by commenter 76,
It was observed that the breakup of corrugated metal siding and
roofed buildings such as manufactured homes and pre-engineered metal
frame buildings contributed significantly to the generation of
airborne debris. This was evident from debris damage to nearby
downwind structures.
As stated by another commenter (205(2)): ``The prospect of
reducing the loss of life and property and reducing the cost of
disaster relief efforts from such losses as Hurricane Andrew would
certainly be to the benefit of the entire housing industry and the
individual and corporate citizen taxpayers of the United States.'' In
addition, the upgrades required under this rule also would increase the
ability of the homes to withstand damage during transportation and
installation of the units, and the improved windows would be more
energy efficient (see comment 150).
The Department recognizes the viability of manufactured housing as
a source of affordable housing for many people and will continue to
work with the industry to ensure a quality product at a reasonable
cost. However, the Department will also continue to exercise all of its
statutory responsibilities relating to housing and its occupants in a
manner that serves the optimal societal interests. This final rule is
evidence that the Department agrees with those commenters that said the
savings in storm damage repair, loss of personal property, and
potential personal injury or loss of life, in addition to other
expected benefits, exceeds the cost differential for these new
standards. The Department has also reviewed cost impact figures
provided by numerous commenters during the development of the final
regulatory impact analysis.
Comment: The increased cost of manufactured housing that will be
the result of the more stringent standards may price many consumers out
of the market for unsubsidized housing. A home manufactured to the new
standards will require a higher downpayment, and potential consumers
will find it more difficult to qualify for financing. The level of
regulation proposed would limit consumer choice and would deny
consumers the right to match housing to their budgets (1).
Response: The Department is concerned about the effect of these
standards on the ability of consumers to afford and purchase
manufactured housing. However, because the standards are, for the most
part, performance standards and do not prescribe methods of
construction, the manufactured housing industry can, and the Department
expects will, approach this problem by developing innovative designs,
components, and construction techniques that meet the standards but
maintain the affordability of manufactured homes. The Department has
also removed some of the proposed prescriptive requirements. These
changes from the proposed rule should help maintain the affordability
of manufactured housing while still assuring safety.
As stated by one commenter (215(2)), sacrificing a minimum
reasonable wind standard for manufactured housing so that it can be
more affordable makes as much sense as allowing a car to be sold
without brakes for the same reason. A similar opinion was expressed by
a consumer, who commented (117(2)):
If tougher standards increase the cost of a mobile home by a
fair percentage I believe people will be willing to pay a little
more for better protection. Most of these homes are not second homes
but the principal residence of retirees.
Earlier in the preamble the Department acknowledges the legitimate
concern with affordability, but also notes the importance of safe
housing that protects other societal interests.
Conversely, as noted by commenter 145 (FEMA), ``[t]he disruption of
lives and families resulting from the damage to manufactured housing
often happens to those least able to fully recover.'' Therefore, the
financial impact of insufficient standards also may fall most heavily
on those least able to absorb that impact. The Department agrees with
commenter 215(2) that the poor should not have to accept a lower
safety factor against catastrophic failure of housing than the rest of
society.
Finally, a commenter representing a number of insurance carriers
(17) noted that builder/developer estimates of cost increases for
building code improvements for site-built structures have far exceeded
documented incremental cost increases in the past. The commenter
observed that cost estimates with respect to manufactured housing and
the higher standards proposed by the Department may contain similar
exaggerations. This possibility is discussed by the Department in the
regulatory impact analysis prepared in connection with this final rule.
Comment: In looking at storm damage estimates for purposes of a
cost-benefit analysis, the Department should distinguish damage to
manufactured homes that complied with existing HUD standards from
damage to pre-HUD homes.
Response: As previously discussed, both manufactured homes built
before the imposition of HUD standards and those built after the
standards became effective experienced significant damage during
Hurricane Andrew. Therefore, the numerical breakdown between pre- and
post-HUD standards is not a determinative factor in the Department's
process with respect to the final content of this rule.
However, in its comments on this rule, the AARP (commenter #150)
noted that ``[w]hile more than half of the manufactured homes destroyed
were built prior to implementation of the HUD standards, many of these
older homes were constructed in accordance with American National
Standards Institute (ANSI) Standard A119.1, which had the same wind
load resistance requirements as the current HUD standards.''
Comment: As a practical matter, manufacturers will build their
homes to the most stringent standards that would apply to their sales
areas. Therefore, those manufacturers that would build homes for more
than one zone will build all their homes to accommodate the highest
wind load requirements, and the cost of compliance with the new
standards will actually be higher than the estimates that are based on
numbers of units per Zone (12).
Response: The Department does not discourage voluntary compliance
with standards that are higher than those required. However, the
Department believes that the decision to comply voluntarily with higher
standards will be controlled by the cost of such compliance and the
manufacturer's market demands. Accordingly, such compliance is
questionable and cannot be considered in the regulatory impact
analysis.
Comment: The implementation of new standards will adversely affect
the marketability of existing homes not built to those standards (87),
leading to increased defaults and credit losses (139).
Response: The standards implemented by this rule will not affect
manufactured homes already occupied by consumers. Thus, the resale
market for these existing units generally should not be affected,
except to the extent that prospective purchasers have the financial
resources, realize the construction limitations of the existing units,
and choose to purchase units meeting the new standard or other housing
options. Because prospective purchasers of used manufactured housing
are likely to be in lower income brackets, however, the Department
expects little or no impact on the resale market for manufactured homes
already occupied by consumers.
Comment: The additional cost attributable to increased costs for
lumber is of particular concern (639).
Response: As noted above, the Department is concerned about all
additional costs and the affordability of homes constructed to the new
standards. Any specific concern with lumber costs has been alleviated
because of recent changes in market conditions, which have shown that
high prices being charged for lumber earlier this year were an
aberration. Lumber costs have significantly reduced since original cost
estimates were prepared. In addition, the final rule will permit the
use of the 1991 NDS without exception, which lowers earlier
manufactured housing industry projections of the lumber changes and
estimated costs for complying with the new standards.
Scope of Requirements
Comment: The prescriptive standards in the proposed rule would
eliminate the ability of manufacturers to be innovative in developing
safer and more attractive homes.
Response: A number of the prescriptive standards in the proposed
rule have been removed in the final rule. For those that remain,
manufacturers can utilize 24 CFR 3282.14, to take advantage of the
Department's policy encouraging innovation through alternative
construction.
Comment: Because the proposed rule was largely justified as a
response to damages incurred in hurricane-prone areas, the standards
and time frames contained in the proposed rule should not be applied to
other zones subject to lower wind speeds.
Response: At this time the Department has deleted the proposed
changes to Zone I from the final rule. Therefore, homes designated to
be sited in Zone I must comply with the previous wind standard for
those areas. However, many commenters and the Advisory Council
indicated that the Department should strive to bring the Federal
standards to a level of comparability with conventional housing
standards. The Department will review existing wind standards in the
remaining areas of the country for possible future action.
Choice of Standard
Comment: The Department has not demonstrated that ASCE 7-88 is the
appropriate standard to be adopted for the higher wind loading
requirements. For example, the Standard Building Code may be a more
appropriate standard for the purposes of this rule.
Response: A number of engineers have written in support of the ASCE
7-88 standard, noting that the standard was developed based on
scientific studies performed in wind tunnels, which were subsequently
verified by tests on full-scale structures. By adopting the Southern
Florida Building Code (SFBC), which incorporates the Standard Building
Code, the people of south Florida thought they were protected by one of
the toughest building codes, with respect to wind. However, the wind
load requirements of the SFBC now have been surpassed by other codes
that are based on recent research. For example, the SFBC does not
reflect peak gusts or use pressure coefficients as high as are now
considered suitable. As a result, the SFBC design wind speed of 120 mph
would only correspond to a design wind speed of less than 100 mph for
many elements of the construction. As previously noted in this
preamble, Dade County has adopted (effective January 1, 1994) the wind
loads section of ASCE 7-88, using Exposures C and D, only.
Comment: No model code has adopted the ASCE 7-88 standard. The
Department does not justify its attempt to impose more stringent
standards for manufactured housing than are applied to site-built
homes. It is an abuse of Federal authority to impose standards that go
well beyond any State building code currently in existence (87).
Response: The relationship between the model codes and ASCE 7-88 is
discussed earlier in the preamble in the section on Development and
Adoption of ASCE 7-88. In addition, the Department notes that the ASCE
7-88 standard already is incorporated into its Minimum Property
Standards (24 CFR part 200, subpart S), which apply to certain site-
built housing within the Department's jurisdiction.
The current wind load requirements for manufactured housing for
high wind zones correspond to a wind speed of 80 mph; other types of
housing are subject to much higher design wind speed requirements in
the same high wind areas. Therefore, as noted by the AARP in its
comments (150), adoption of ASCE 7-88 actually will ensure substantial
equivalence of wind design requirements between manufactured and site-
built housing.
Furthermore, Dade, Broward, and Palm Beach Counties in Florida have
adopted ASCE 7-88 (with the 110 mph wind load) for site-built homes,
and the Department believes other coastal jurisdictions will follow.
Model codes also have adopted or are moving toward the adoption of the
ASCE 7-88 standard. In fact, by not including the higher standards for
the remainder of the country (Zone I), a majority of manufactured homes
produced in this country will comply to a standard well below the
building codes currently in existence for site-built housing.
Comment: The Department should recognize ``deemed-to-comply''
standards.
Response: The Department considered the deemed-to-comply standards,
but determined that a performance standard would allow manufacturers
flexibility to be innovative in their approach to compliance with the
standards. Such innovation will reduce the cost associated with strict
adherence to the deemed-to-comply standards.
Comment: The rule expands the ASCE 7-88 definition of ``components
and cladding'' to include exterior coverings and fastenings, and the
limited availability of these materials may make compliance difficult
(221).
Response: The Department has made alternative provisions in the
standard for adequate resistance of exterior coverings to specified
design wind pressure requirements.
Enforcement
Comment: The proposed rule did not address testing issues. The
Department does not specify whether the proposed structural design
changes have been subjected to destruction testing. (144) Although
there is no agreement on a testing protocol, truss suppliers will need
time to retest their many truss designs. (8, 16, and incorporated by
reference in others) The need to test many types of siding, siding
gauges (thicknesses), and accessories, fasteners, and fastener patterns
also may lead to tooling changes, which will require more time. (9)
Response: Testing will continue to be evaluated under the DAPIA
review process, which is not revised by this rule. However, the
Department has extended, to 180 days (or, for some provisions, one
year) from today's publication of the rule, the implementation schedule
for the new requirements, in order to give producers sufficient time to
comply with the standards.
Comment: The existence of multiple wind zones and corresponding
requirements within a single State creates difficulties with respect to
enforcement, as well as with production. It is not clear who bears the
responsibility for monitoring the placement of homes within a wind zone
for which they are intended (87, 91, 92, 610).
Response: The Department appreciates the difficulties of enforcing
the standards when multiple zones exist in a single State. Accordingly,
the Department has specifically listed those local governments in the
higher wind zones in each State. Depending on the facts surrounding the
sale of a manufactured home, both the manufacturer and the dealer will
be responsible for assuring that the home will be in compliance with
the standards by siting the home in the proper zone. The State
Administrative Agencies (SAAs) will be informed of the changes
resulting from this rule and will assist the Department in discovering
homes that are sited in noncompliance with these standards.
Anchoring and Tie-Downs
Comment: The change in lease communities could be revolutionary, as
homes become more permanent in nature (122) and homes are taxed more as
real, rather than personal, property. Generally, lessors are required
to restore the site to its original condition when they move. This
requirement, and the relocation of utility connections, would be made
more difficult with more permanent foundations. In addition, the FHA
Title II allowance for installation would not be sufficient for the
additional costs of permanent foundations (146, and others).
Response: The Department has evaluated these comments and has
removed the design requirement for a permanent foundation. However, the
Department remains concerned that some form of strengthened tiedown
system may be necessary to protect homes adequately in high wind areas.
Thus, the Department will be reviewing the issue of permanent
foundations and other strengthened anchoring systems in conjunction
with regulatory action on wind resistant design and construction
requirements for the remainder of the country.
Comment: The impact of the new Wind Standards can be adversely
effected if there is inadequate enforcement and monitoring of the
placement of homes to assure that only homes that have been designed
for the wind load requirements of the Zone are permitted to be sited.
There is a need for better local inspection; the home is only as good
as its anchoring system (149). There is compelling evidence that much
of the damage from Hurricane Andrew was attributable to the lax
enforcement of State and local building codes, including anchoring
requirements, rather than to inadequate standards (80, 122). Similarly,
the main problem with manufactured homes is the proper installation of
anchoring equipment, which the Department cannot regulate (100).
Response: Although the use of tiedowns was widespread in the areas
affected by Hurricane Andrew, indicating some attempt to comply with
codes, the tiedowns generally performed very poorly. None of the
tiedowns observed was certified in accordance with code requirements.
The Department is reviewing the authority to regulate installation of
manufactured homes and is exploring ways to encourage States and
localities to adopt and enforce more stringent anchoring requirements.
The Department also is reviewing appropriate methods, including a
disclosure requirement, to inform consumers about the installation of
the home in a manner that achieves the highest wind protection
performance for the home's design.
Meanwhile, the Department will be contacting the Governors of all
States, and in particular States where the wind risk is the greatest,
to advise the Governors of the changes in the wind standards and the
need for each State to establish installation standards and a system of
enforcement and monitoring.
Comment: Typical ground anchors performed adequately in Hurricane
Andrew (14(2)-17(2), 73(2), 88(2), and others). If
given enough time, ground anchor manufacturers can develop an anchoring
system that is comparable to a permanent foundation system (29).
Response: With very few exceptions, manufactured homes in the path
of Hurricane Andrew were destroyed by the resulting wind forces. The
lack of adequate attachment of single or double-wide units to ground
anchors was a major factor in loss of units. The chassis of some units
could be found some distance away from their original site. However, in
some cases the anchors did hold the floor of the unit down while the
``box'' of the structure was torn away by the high winds. For this
reason, there is justification for increasing the strength of the
structure by this final rule.
The effective date of these new requirements will now be at least
180 days from today. The Department agrees that innovative anchoring
systems comparable to permanent foundations systems can be developed;
however, anchor manufacturers are cautioned regarding the resistance
capacity of auger-type anchors presently used for installing
manufactured homes, when those anchors are subject to high winds and
ensuing saturated soil conditions. The Department's tests show
substantially less resistance than required by 24 CFR 3280.306(f), even
when tested under dry soil conditions.
Comment: Substantially increased siting requirements would be a
problem especially for retirees in land-lease communities and for
minority owners who reside on ``heir property'' and cannot secure clear
title to their site (672).
Response: Alternative anchoring systems that are expected to
provide the required resistance to high wind forces are already
available in the market. The Department believes that if siting
requirements are increased by State and local governments, the
manufactured housing industry will likely develop ways to accommodate
siting in land-lease communities.
Technical Comments
Comment: The Department has not justified its proposal to require a
lower load duration factor for designing wood members and fastenings to
resist wind forces than is specified in the 1991 edition of the
National Design Specification for Wood Construction (NDS) published by
the American Forest and Paper Association (AFPA).
Response: The Department agrees that the higher factor of 1.6 in
the NDS has been justified by research completed by AFPA for wood
members subjected to short duration loads of 10 minutes or less. This
is generally recognized as the maximum period for exposure of
structures to wind forces. In addition, the 1991 NDS has already been
adopted without exception by certain model code agencies. However,
cyclic testing to evaluate fasteners and connectors has not yet been
completed. Preliminary results suggest that a higher load duration
factor may be appropriate. Therefore, the Department will accept the
higher load duration factor of 1.6 on an interim basis and will
recognize the 1991 NDS without exception in this final rule. The
Department intends to monitor this research and may propose a different
load duration factor for fasteners and connectors in the future,
subject to the research and test results.
Comment: There is no basis for the 12'' limitation and prescriptive
requirements for eave and cornice projections; their implementation
would inhibit design innovations.
Response: While longer eave and overhang projections will subject
trusses, fasteners, and connectors to significant increases in design
loads, and thereby increase their likelihood of failure under extreme
wind conditions, the Department agrees that the provision should be
removed because it does restrict innovation, and truss and home
manufacturers are capable of designing roof systems and connections to
resist the higher wind forces. However, manufacturers that use larger
projections than 12 inches are cautioned to review their designs
carefully to assure that all components and fastenings are adequate to
resist the design pressures specified in ASCE 7-88 or the table in
Sec. 3280.304.
Comment: The prescriptive requirements for sidewall-to-roof and
floor connections using steel strapping or brackets should be replaced
with performance criteria that permit the use of alternative methods of
connection, such as structural sheathing that overlaps the roof and
floor.
Response: In general, the Department agrees that the use of
performance-based standards is preferred. However, on-site
investigations of the damage from Hurricane Andrew revealed that
current designs using 30 gage straps failed. Based on the above
information, the Department has retained the prescriptive requirement
for strapping in high wind areas, but will permit to be used a
combination of strapping and structural sheathing that overlaps the
roof or floor, instead of only steel straps or brackets, provided the
sheathing and its fastenings are demonstrated by calculations or tests
to have equivalent strength and resistance to the design wind uplift
forces.
Comment: The use of the 1.5 factor of safety for design of
anchoring systems is not consistent with ASCE 7-88.
Response: The Department concurs that there is no provision in the
ASCE 7-88 standard for increasing the wind pressures for the design of
anchoring systems to resist overturning and sliding forces. Therefore,
the anchoring design provisions for Wind Zones II and III, which are
based on the ASCE 7-88 requirements, will not require the application
of the 1.5 factor of safety to be applied to the design wind drag and
uplift pressures. However, the 1.5 factor of safety will continue to be
required for calculating the required resistance of anchoring systems
for Wind Zone I, since the design lateral and uplift wind forces remain
based on the current standard, which is lower than all model building
codes.
Comment: The Department should clarify whether new wind uplift
design loads in the Table (in Sec. 3280.305) are gross or net uplift
loads.
Response: The uplift wind loads in the table are the full or
``gross'' loads. Gravity or dead loads may be deducted from these loads
when calculations are prepared using the design pressures in the table.
Comment: Existing truss testing procedures in Sec. 3280.402(c)(2)
should be clarified as to: (1) The acceptability of existing inverted
truss testing procedures for evaluating new wind uplift design loads;
(2) whether vertical live and gravity roof load testing must still be
conducted with trusses in the upright position when uplift forces are
higher than downward loads; and (3) whether eave loads are to be
applied simultaneously with roof uplift loads.
Response: (1) The inverted test method may continue to be used on
an interim basis while the Department evaluates results of an industry
study to compare results of the existing test method, which applies
load to the bottom chord of the truss, to results obtained from
applying the load to the top chord of the truss. (2) Testing must
continue to be conducted in the upright position, because the loads are
applied to different members (chords) of the truss. (3) Uplift loads
are to be applied to truss eave projections when uplift loads are
applied to the truss bottom chords during each loading phase required
by Sec. 3280.402(c)(2).
Comment: A new provision should be added requiring a professional
engineer to prepare and certify wind load designs and calculations.
Response: The Department will consider this suggestion for future
rulemaking on wind load requirements.
Comment: Special standards should be required for asphalt shingle
performance in high wind areas, because of the large number of failures
that occurred in Hurricane Andrew and ensuing structural and water
damage caused by these failures.
Response: The asphalt shingle industry research is not yet
completed in this area. As an interim step, this final rule requires
each shingle to be secured with two additional fasteners and
underlayment to be cemented to the roof decking.
Comment: Testing requirements should be specified for windows and
doors to avoid missile damage in high winds. Safety standards can be
enhanced without affecting affordability, by requiring operating
shutters and proper anchoring (88(2)).
Response: The Department encourages manufacturers to provide
shutters or protective devices for homes in Wind Zones II and III.
Under this rule manufacturers will be required, at a minimum, to
provide instructions for an appropriate method of shutter or cover
installation to protect the home, and to include shutter information on
the data plate. The instructions must provide a method for protecting
the windows and doors that is capable of withstanding design wind
pressures without taking the home out of conformance with the
standards. The application of shutters does not do away with the need
for testing the doors or windows they protect.
Comment: A requirement should be added for the use of perforated
metal straps at the marriage line of the roof, between sections of
doublewides, to transfer wind forces from the windward to the leeward
side of the roof.
Response: As part of its continuing evaluation of wind design
requirements, the Department will assess the merits of this proposal.
Comment: The Department needs to establish standards to regulate
the addition of appurtenances to manufactured homes, such as porches,
carports, and canopies, which experienced a large number of failures in
Hurricane Andrew. The danger to occupants is further increased because
the rule does not address the effect of dangerous appurtenances (52,
65, 122).
Response: Under 24 CFR 3282.8(j) the standards currently do not
govern add-ons, as long as the add-on doesn't affect the ability of the
home to comply with the standards. However, as noted in that section,
the Secretary has authority to promulgate standards for some add-ons.
Accordingly, the Department is examining its authority in this area and
may establish requirements in the future. In the interim, HUD
encourages all States to establish standards covering the construction
and attachment of these kinds of appurtenances to manufactured homes.
Comment: Exposure D in ASCE 7-88 should be used for coastal
shoreline areas.
Response: Under this rule manufacturers are required to include on
the data plate a statement that units designed to meet the minimum
standards in this rule should not be located within 1500 feet of the
coastline in Zones II and III. By this statement, the consumer is
alerted that only units designed and anchored according to the higher
design standards specified for coastal areas in ASCE 7-88 should be
placed along the coastline.
Comment: ``Wind safety'' is a misnomer; the science of weather
forecasting allows ample notice of dangerous storms to permit
evacuation (296-314). Homeowner safety is better served by evacuation
in high winds than from protection afforded by the manufactured home
structure. If a manufactured home is purported to be designed and
constructed to withstand higher wind speeds, occupants may be less
likely to evacuate the homes at the approach of a dangerous storm.
Response: The Department agrees that if it is safe to do so,
homeowners should attempt to reach a shelter capable of resisting high
winds. However, without the imposition of these enhanced Wind Safety
Standards, the numbers of deaths and injuries attributable to the
inadequate performance of manufactured homes in high winds will
continue unabated. In addition to reducing deaths and injuries, the
Department's statutory responsibilities require the implementation of
higher wind standards to reduce the insurance cost and amount of
property damage resulting from manufactured home accidents and
improvement of the quality and durability of manufactured homes. The
Department believes that these higher wind standards will fulfill those
responsibilities.
Comment: The NIST study cited by the Department does not fault the
performance of trusses; increasing the uplift requirements would not
improve the quality of assembly. The problems associated with
manufactured housing are related more to fasteners and tiedowns
(13(2)).
Response: The field studies referenced in the NIST Report
identified numerous roof system failures that were generally due to
failure of the end connections between the trusses and the sidewalls.
However, even if the trusses had been properly connected to the
manufactured home structure, the Department believes that trusses not
designed to resist the uplift pressures referenced in this rule still
may have failed. Therefore, in this final rule the Department has
retained the proposed increased design requirements for roof trusses.
Other Specific Comments
Comment: The Department is encouraged to coordinate this rule with
a review of seismic and flood loads, especially with respect to
foundation and attachment designs (25).
Response: The requirements in the proposed rule for a permanent
foundation design have been eliminated in this final rule. However, as
the Department continues to review the issue of adequate anchoring/
foundation systems for manufactured homes, it will also review these
other considerations.
Comment: There are not enough DAPIA personnel in the HUD system to
review and approve design changes within the time provided for the
effectiveness of this rule (83, 124, 136, 179).
Response: The Department has agreed to delay the effectiveness of
the new requirements for 180 days, which should allow sufficient time
for the DAPIA process, as well.
Comment: The Department should consider requiring the DAPIA
approval stamp on all pages of a manufacturer's installation
instructions (48).
Response: The final rule continues to require that the manufacturer
provide installation instructions certified by a registered
professional engineer indicating at least one acceptable system of
anchoring (24 CFR 3280.306(b)). However, the Department will consider
the suggestion to require a DAPIA approval stamp on each page of the
manufacturers' installation instructions when developing future
revisions to the Manufactured Home Procedural and Enforcement
Regulations (24 CFR part 3282).
Comment: Some explanation is needed about the effect of the new
standards on ``B'' letters, interpretative bulletins, and compliance
determinations (122).
Response: This new standard supersedes any portions of ``B''
letters, interpretative bulletins, and compliance determinations that
are in conflict with this standard.
Comment: If the higher standards are adopted, manufacturers will
prefer to build modular homes that meet the necessary State standards.
Response: Manufacturers are free to channel their activities in any
way that best responds to market forces. In the development of the
regulatory impact analysis, the Department has accounted for the cost
of potential lost business. To the extent that manufacturers could
redirect their production to alternative housing, the costs of the
higher standards would be lessened. However, as noted above, the
Department believes that the trend in State standards also will be to
stricter wind standards. Therefore, while manufactured homes may
experience a price increase because of these standards, they will be
affordable relative to site-built homes meeting the higher State-
imposed standards.
Comment: The Department should prepare a brochure on hurricane
awareness and windstorm protection.
Response: As noted in the discussion on Improved Anchoring and
Foundation Systems earlier in the preamble, the Department is reviewing
what would be an appropriate consumer information disclosure
requirement on installation. As part of that review, the Department may
consider requirements on the disclosure of general information relating
to high winds and hurricanes, and may coordinate with FEMA on the
development of a brochure on hurricane awareness and protection for
occupants of manufactured homes.
(Note: Other specific comments that have become moot as a result
of the decision not to proceed with changes in Wind Zone I and
requirements relating to a permanent foundation system are not
addressed in this preamble.)
III. Description of Changes to the Standards
Because of the risk of loss of life to building occupants and the
extraordinary loss of property due to Hurricane Andrew, the Department
has determined that it is necessary to amend the Federal Manufactured
Home Construction and Safety Standards (FMHCSS) to raise the level of
wind resistance standards, especially in areas subject to high winds.
Specifically, the Department is amending the FMHCSS to include a Basic
Wind Zone Map that is based on the map contained in the incorporated
standard ASCE 7-88, ``Minimum Design Loads for Buildings and Other
Structures.''
The revised map contains a more concentrated area for the 100 mph
wind zone than was specified in the current standard or the proposed
rule. The boundary between Wind Zones I and II follows the 90 mph
isotach on the ASCE 7-88 basic wind speed map, while the boundary
between Wind Zones II and III remains the 100 mph isotach indicated in
the proposed rule. The design wind speeds for high wind areas are
designated as 100 mph for Wind Zone II and 110 mph for Wind Zone III.
This rule does not change the current design wind speed for Wind Zone
I.
Based on the revised map, this final rule enumerates the States,
Territories, and local governments in which the more stringent
standards will be applicable. The enumerated areas are those that the
Department has determined to be at least partially within the higher
wind zones demarcated on the revised map. The Department also will
monitor local building code requirements and will consider adoption
through rulemaking of requirements for manufactured homes that are
comparable to any more stringent requirements established for site-
built homes by a State or local building authority.
The current wind standard for manufactured housing is considered
inadequate because it addresses only positive (external) design wind
pressures for walls, components, windows, and cladding, without
specifying that designs must take into account the effect of negative
pressure (suction) on these building elements, as well as internal
pressures on walls and roof/ceiling systems. The formulae used in ASCE
7-88 also include other factors, which account for higher uplift forces
on roof eaves, ridges, overhangs, and corners. These and other issues
are now addressed in high wind areas by requiring the manufactured home
structure, components, and cladding to be designed to resist design
wind forces for Exposure C, as specified in ASCE 7-88.
Requirements for structural assemblies, components, connectors,
fasteners, and a number of other areas will be strengthened so that
parts and portions of the home will be able to resist the same wind
forces as required for site-built and modular housing. In addition, the
increased wind loads required by this rule are applicable whether
structural systems, components, or other aspects of the design are
substantiated by engineering analysis or by suitable load tests (see
subpart E of part 3280). The revised standards also require that the
ground anchoring and foundation support systems continue to be designed
by a registered engineer or architect in a manner adequate to withstand
the higher wind forces specified.
III. Section-by-Section Analysis
The Secretary has determined that the following changes should be
made to the standards:
(1) Section 3280.4--The American Society of Civil Engineers (ASCE)
is added to the list of organizations issuing standards that are
incorporated by reference. The street addresses are corrected for two
other organizations listed.
(2) Section 3280.5--Technical and conforming corrections are made
to standardize paragraph designations to Federal Register format and
clarify the information to be included on data plates. The new
requirements also incorporate changes to the data plate adopted in the
Energy Rule (58 FR 54975, 55003) for effect in October 1994, in order
to avoid having inconsistent requirements become effective within a
short time.
The data plate is also being expanded to indicate that manufactured
homes should not be located within 1500' of the coastline in Wind Zones
II and III unless the home and its anchoring or foundation system are
designed for the increased requirements of Exposure D in ASCE 7-88. The
data plate will now also indicate whether the home has been equipped
with storm shutters and, if shutters are not provided, will strongly
recommend that the home be made ready for these devices in accordance
with the method described in the installation instructions.
(3) Sections 3280.302(a)(8), 3280.303(d), 3280.305(c)--The
definition and references to ``hurricane resistive design'' in these
sections are deleted, in favor of the Wind Zone II and III designations
in the revised Basic Wind Zone Map. These changes will result in the
identification of design wind forces and wind speeds for which the home
has been designed, rather than the designation of homes as ``hurricane
resistive.''
(4) Section 3280.304--The incorporated standards are amended to
require that the minimum design loads be based on ASCE 7-88, which
replaces the obsolete ANSI A58.1-1982 standard currently referenced in
this section.
In addition, the National Design Specification for Wood Members
(NDS), incorporated by reference, is updated to the most current
specification issued by the American Forest and Paper Association
(AFPA). Because manufacturers will need to redesign the structure's
resistance to wind forces, the redesign should be accomplished with the
most current design values for wood. Accordingly, the 1991 NDS is
incorporated in its entirety into the standards.
(5) Section 3280.305(c)--The standards are amended to require that
for manufactured homes in high wind areas, the home and each wind
resisting part, including components and cladding, be completely
designed to resist the design wind pressures specified for a 50-year
recurrence level by ASCE 7-88 or the pressures specified in a table of
equivalent design wind load provisions. The Department has designated
three wind zones: Zone I (current wind design requirements for Zone I);
Zone II (design wind speed of 100 mph); and Zone III (design wind speed
of 110 mph).
The Table of Design Pressures in the proposed rule is clarified and
expanded. Editorial revisions to clarify the application of the uplift
pressure requirements for exterior roof coverings, eaves and gables. In
addition, footnotes are included to indicate:
Distributional pressure effects between windward and
leeward walls;
The application of the Table is limited to roof slopes
between 10 and 30 degrees and that horizontal drag pressures need not
be considered for roof slopes under 20 degrees;
The design uplift pressures are the same regardless of
whether they are applied normal to the roof surface or to the
horizontal projection of the roof; and
Exterior roof and wall coverings (excluding glazing),
sheathing, and fastenings need not be evaluated for the design
pressures specified by the Table, when fastened to a 3/8'' structural
rated sheathing and the sheathing is oriented and secured to framing
members in accordance with the fastening schedule specified in the
Table.
The Basic Wind Zone Map is revised by delineating the boundary
between Wind Zones I and II as the 90 mph isotach, and the boundary
between Wind Zones II and III as the 100 mph isotach, on the ASCE 7-88
basic wind speed map. This change will result in certain areas of
existing Wind Zone II being located in the modified Wind Zone I. The
boundary between Wind Zones I and III in Alaska is now designated as
the 90 mph isotach on the ASCE 7-88 map.
(6) Section 3280.305(d)--Interpretative Bulletin D-5-76, under
which the Department has been operating since the late 1970s, is
paraphrased as a new paragraph (2). It clarifies that the deflection
limit for a cantilevered roof is 2 times the length divided by 180.
Eaves and cornices shall be designed for a net uplift pressure of 2.5
times the design uplift wind pressure cited in Sec. 3280.305(c)(1)(i)
for Wind Zone I, and for the design pressures cited in
Sec. 3280.305(c)(1)(ii) for Wind Zones II and III. This change has
already been issued in the Energy Rule (58 FR 54975, 55006), but is
modified in this rule to reflect the standards established for the new
Wind Zones.
(7) Section 3280.305(e)--The standards for fastening of roof
framing to wall framing and wall to floor framing are changed to
require the use of 26 gage minimum steel strapping, or those elements
shall be connected by a combination of strapping and structural rated
wall sheathing that overlaps the roof and floor. Investigations after
Hurricane Andrew revealed that current designs allowed 30 gage straps
with staples for connections of roofs to walls, and walls to floors;
such straps were inadequate to resist even moderate wind forces.
(7) Section 3280.306(a)--The wind design loads used for calculating
resistance of support and anchoring systems to overturning and lateral
movements are revised to include the simultaneous application of the
horizontal drag and uplift forces determined in Sec. 3280.305(c).
(8) Section 3280.306(g)(2)--The standards are amended to require
that the manufacturer's instructions for anchoring equipment be
certified in accordance with the testing procedures found in ASTM
D3953-91, Standard Specification for Strapping, Flat Steel and Seals.
The certification must be made by a registered engineer, architect, or
independent third party testing agency. This is an updated standard for
steel strapping that supersedes the standard originally referenced in
the Federal standard.
(9) Sections 3280.403 and 3280.404--These sections are amended to
require all primary windows, including egress windows and sliding glass
doors, to resist the design exterior and interior wind pressures
specified in Sec. 3280.305(c)(1) for components and cladding. These
requirements are effective one year from today's date of publication of
this rule, as provided in the ``DATES'' section of this preamble. In
addition, manufacturers are required to provide instructions for the
installation of shutters or protective covers, to protect the windows
and doors.
(10) Section 3282.362--Minor conforming changes regarding the data
plate are made in paragraph (c)(3)(i). These changes are explained
under Sec. 3280.5.
V. Other Matters
Significant Regulatory Action
The Director of the Office of Management and Budget has indicated
that this rule could constitute a ``significant regulatory action'' as
that term is defined in section 3(f) of the Executive Order on
Regulatory Planning and Review issued by the President on September 30,
1993. Because an estimation of the new requirements as proposed
indicated that they might have an annual effect on the economy of $100
million or more, a regulatory impact analysis has been prepared for
this final rule. This analysis concludes that the requirements that
will be imposed by this final rule will have an effect on the economy
of less than $100 million, and will have benefits that outweigh the
costs of the additional requirements. This analysis is available for
public inspection during regular business hours in room 10276, Rules
Docket Clerk, Office of General Counsel, Department of Housing and
Urban Development, 451 Seventh Street, SW., Washington, DC 20410.
Regulatory Flexibility Act
The Secretary, in accordance with the Regulatory Flexibility Act (5
U.S.C. 605(b)), has reviewed this rule before publication and by
approving it certifies that this rule will not have a significant
economic impact on a substantial number of small entities. However, the
regulatory impact analysis referenced in the preceding paragraph also
provides relevant analysis and discussion of possible economic impact
on businesses, including small businesses, that must comply with the
provisions of this rule. The rule will establish additional safety
standards for manufactured housing, and therefore would affect the
design and construction requirements in specified areas of the country.
The nature of the rule and its purpose do not present an opportunity
for the Department to vary the rule's requirements so as to reduce
burdens on small entities.
Environmental Impact
At the time of publication of the proposed rule, a finding of no
significant impact with respect to the environment was made in
accordance with HUD regulations in 24 CFR part 50 that implement
section 102(2)(C) of the National Environmental Policy Act of 1969 (42
U.S.C. 4332). The proposed rule is adopted by this final rule without
any change that would be significant for purposes of additional
environmental impact. Accordingly, the initial finding of no
significant impact remains applicable, and is available for public
inspection between 7:30 a.m. and 5:30 p.m. weekdays in the office of
the Rules Docket Clerk at the above address.
Executive Order 12612, Federalism
The General Counsel, as the Designated Official under section 6(a)
of Executive Order 12612, Federalism, has determined that the policies
contained in this rule have federalism implications, and are subject to
review under the Order. Specifically, the rule provides for mandatory
specifications for the construction of manufactured homes that exceed
the standards currently permitted in certain areas of the country.
States and local governments would no longer have the option of
imposing separate requirements that exceed current standards, but are
less stringent than these new standards. However, because the Federal
standards already preempt local discretion in the construction of
manufactured homes, this marginal degree of preemption is not believed
to be significant for purposes of identifying federalism concerns.
Therefore, for these reasons and because of the health and safety
aspects of this rule, the General Counsel has determined that the
federalism implications are not sufficient to warrant the preparation
of a federalism assessment under the Order.
Executive Order 12606, the Family
In the proposed rule, the Department indicated that the rule was
not subject to review under Executive Order 12606, The Family. As
addressed earlier in this preamble, some of the commenters were
concerned about this position. Although the Department does not believe
this final rule implicates family concerns within the spirit of the
Executive Order, the Department has analyzed the rule as required under
the Order.
The General Counsel, as the Designated Official under the Executive
Order, has evaluated the potential of this rule to have a significant
impact on family formation, maintenance, and general well-being.
Although as a result of the more stringent construction requirements
implemented by this rule, some families may lose an ownership option
for housing, the general well-being of families, and society, is served
better by ensuring minimal quality standards for such housing. The
Secretary of Housing and Urban Development has certified that, to the
extent permitted by law, the rule has undergone a Family Impact
Assessment under the Executive Order.
Regulatory Agenda
This rule was listed as Item 1551 in the Department's Semiannual
Agenda of Regulations published on October 25, 1993 (58 FR 56402,
56433) in accordance with Executive Order 12866 and the Regulatory
Flexibility Act.
The Catalog of Federal Domestic Assistance program number is
14.171.
List of Subjects
24 CFR Part 3280
Fire prevention, Housing standards, Incorporation by reference,
Manufactured homes, Reporting and recordkeeping requirements.
24 CFR Part 3282
Administrative practice and procedure, Consumer protection,
Incorporation by reference, Intergovernmental relations,
Investigations, Manufactured homes, Reporting and recordkeeping
requirements.
For the reasons stated in the preamble, parts 3280 and 3282 of
title 24 of the Code of Federal Regulations are amended as follows.
PART 3280--MANUFACTURED HOME CONSTRUCTION AND SAFETY STANDARDS
1. The authority citation for part 3280 is revised to read as
follows:
Authority: 42 U.S.C. 5403 and 5424; 42 U.S.C. 3535(d).
2. Section 3280.4(b) is amended by adding an additional
organization in the listing of organizations issuing referenced
standards immediately following the listing for the Air Conditioning
and Refrigeration Institute (ARI), and revising the addresses for two
previously listed organizations, to read as follows:
Sec. 3280.4 Incorporation by reference.
* * * * *
(b) * * *
AFPA [previously (N)FPA]--American Forest and Paper Association,
1250 Connecticut Avenue, NW., Washington, DC 20036 [previously named
(N)FPA-National Forest Products Association].
* * * * *
ASCE--American Society of Civil Engineers, 345 East 47th Street,
New York, NY 10017-2398
* * * * *
SJI--Steel Joist Institute, 1205 48th Avenue North, Suite A, Myrtle
Beach, SC 29577
* * * * *
3. Section 3280.5 is revised to read as follows:
Sec. 3280.5 Data plate.
Each manufactured home shall bear a data plate affixed in a
permanent manner near the main electrical panel or other readily
accessible and visible location. Each data plate shall be made of
material what will receive typed information as well as preprinted
information, and which can be cleaned of ordinary smudges or household
dirt without removing information contained on the data plate; or the
data plate shall be covered in a permanent manner with materials that
will make it possible to clean the data plate of ordinary dirt and
smudges without obscuring the information. Each data plate shall
contain not less than the following information:
(a) The name and address of the manufacturing plant in which the
manufactured home was manufactured.
(b) The serial number and model designation of the unit, and the
date the unit was manufactured.
(c) The statement:
This manufactured home is designed to comply with the Federal
Manufactured Home Construction and Safety Standards in force at the
time of manufacture.
(d) A list of the certification label(s) number(s) that are affixed
to each transportable manufactured section under Sec. 3280.8.
(e) A list of major factory-installed equipment, including the
manufacturer's name and the model designation of each appliance.
(f) Reference to the roof load zone and wind load zone for which
the home is designed and duplicates of the maps as set forth in
Sec. 3280.305(c). This information may be combined with the heating/
cooling certificate and insulation zone map required by Secs. 3280.510
and 3280.511. The Wind Zone Map on the Data Plate shall also contain
the statement:
This home has not been designed for the higher wind pressures
and anchoring provisions required for ocean/coastal areas and should
not be located within 1500' of the coastline in Wind Zones II and
III, unless the home and its anchoring and foundation system have
been designed for the increased requirements specified for Exposure
D in ANSI/ASCE 7-88.
(g) The statement:
This home has--has not--(appropriate blank to be checked by
manufacturer) been equipped with storm shutters or other protective
coverings for windows and exterior door openings. For homes designed
to be located in Wind Zones II and III, which have not been provided
with shutters or equivalent covering devices, it is strongly
recommended that the home be made ready to be equipped with these
devices in accordance with the method recommended in the
manufacturers printed instructions.
(h) The statement: ``Design Approval by'', followed by the name of
the agency that approved the design.
Sec. 3280.302 [Amended]
4. Section 3280.302 is amended by removing and reserving paragraph
(a)(8).
Sec. 3280.303 [Amended]
5. Section 3280.303 is amended by removing and reserving paragraph
(d).
6. Section 3280.304 is amended by revising the last item listed
under the heading ``Steel:''; by revising the entry ``National Design
Specifications for Wood Construction'' listed under the heading ``Wood
and Wood Products:''; and revising the entry under the heading
``Unclassified:'' in paragraph (b)(1), to read as follows:
Sec. 3280.304 Materials.
* * * * *
(b)(1) * * *
Steel:
* * * * *
Standard Specification for Strapping, Flat Steel and Seals--ASTM
D3953-91.
Wood and Wood Products:
* * * * *
National Design Specifications for Wood Construction, 1991 Edition,
With Supplement, Design Values for Wood Construction, AFPA.
* * * * *
Unclassified: American Society of Civil Engineers Minimum Design Loads
for Buildings and Other Structures--ANSI/ASCE 7-88.
* * * * *
7. Section 3280.305 is amended by adding a new paragraph (b)(4) and
by revising paragraphs (a), (b)(3), (c)(1) and (2); adding a heading
for (c)(3) introductory text; and revising (c)(3) (iii), (c)(4), (d),
and (e), to read as follows:
Sec. 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.
(b) Design loads-- * * *
(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 Secs. 3280.304(b)(1) and
3280.306(a).
(4) Whenever the roof slope does not exceed 20 degrees, the design
horizontal wind loads required by Sec. 3280.305(c)(1) may be determined
without including the vertical roof projection of the manufactured
home. However, regardless of the roof slope of the manufactured home,
the vertical roof projection shall be included when determining the
wind loading for split level or clerestory-type roof systems.
(c) Wind, snow, and roof loads--(1) Wind loads--design
requirements. (i) Standard wind Loads (Zone I). When a manufactured
home is not designed to resist the wind loads for high wind areas (Zone
II or Zone III) specified in paragraph (c)(1)(ii) of this section, the
manufactured home and each of its wind resisting parts and portions
shall be designed for horizontal wind loads of not less than 15 psf and
net uplift load of not less than 9 psf.
(ii) Wind loads for high wind areas (Zone II and Zone III). When
designed for high wind areas (Zone II and Zone III), the manufactured
home, each of its wind resisting parts (including, but not limited to,
shear walls, diaphragms, ridge beams, and their fastening and anchoring
systems), and its components and cladding materials (including, but not
limited to, roof trusses, wall studs, exterior sheathing, roofing and
siding materials, exterior glazing, and their connections and
fasteners) shall be designed by a Professional Engineer or Architect to
resist:
(A) The design wind loads for Exposure C specified in ANSI/ASCE 7-
88, ``Minimum Design Loads for Buildings and Other Structures,'' for a
fifty-year recurrence interval, and a design wind speed of 100 mph, as
specified for Wind Zone II, or 110 mph, as specified for Wind Zone III
(Basic Wind Zone Map); or
(B) The wind pressures specified in the following Table:
Table of Design Wind Pressures
------------------------------------------------------------------------
Wind zone II Wind zone III
Element design wind design wind
speed 100 MPH speed 110 MPH
------------------------------------------------------------------------
Anchorage for lateral and vertical
stability (See Sec. 3280.306(a)):
Net Horizontal Drag1, 2:............ \3\39 PSF \3\47 PSF
Uplift\4\:.......................... \5\-27 PSF -32 PSF
Main wind force resisting system:
Shearwalls, Diaphragms and their
Fastening and Anchorage Systems1, 2 39
PSF 47
PSF
Ridge beams and other Main Roof
Support Beams (Beams supporting
expanding room sections, etc.)..... -30 PSF -36 PSF
Components and cladding:
Roof trusses\4\ in all areas;
trusses shall be doubled within 3'-
0'' from each end of the roof...... \5\-39 PSF \5\-47 PSF
Exterior roof coverings, sheathing
and fastenings\4\,\6\,\7\ in all
areas except the following......... \5\-39 PSF \5\-47 PSF
Within 3'-0'' from each gable
end (overhang at end wall) of
the roof or endwall if no
overhang is provided........... \5\-73 PSF \5\-89 PSF
Within 3'-0'' from the ridge and
eave (overhang at sidewall) or
sidewall if no eave is provided \5\-51 PSF \5\-62 PSF
Eaves (Overhangs at Sidewalls)...... \5\-51 PSF \5\-62 PSF
Gables (Overhangs at Endwalls)...... \5\-73 PSF \5\-89 PSF
Wall studs in sidewalls and
endwalls, exterior windows and
sliding glass doors (glazing and
framing), exterior coverings,
sheathing and fastenings\8\:....... 48
PSF 58
PSF
Within 3'-0'' from each corner
of the sidewall and endwall.... .............. ..............
All other areas................. 38
PSF 46
PSF
------------------------------------------------------------------------
NOTES:
1The net horizontal drag of 39 PSF to be used in calculating
Anchorage for Lateral and Vertical Stability and for the design of
Main Wind Force Resisting Systems is based on a distribution of wind
pressures of +0.8 or +24 PSF to the windward wall and -0.5 or -15 PSF
to the leeward wall.
2Horizontal drag pressures need not be applied to roof projections when
the roof slope does not exceed 20 degrees.
3+ sign would mean pressures are acting towards or on the structure; -
sign means pressures are acting away from the structure;
sign means forces can act in either direction, towards or away from
the structure.
44. Design values in this ``Table'' are only applicable to roof slopes
between 10 degrees (nominal 2/12 slope) and 30 degrees.
5The design uplift pressures are the same whether they are applied
normal to the surface of the roof or to the horizontal projection of
the roof.
6Shingle roof coverings that are secured with 6 fasteners per shingle
through an underlayment which is cemented to a 3/8'' structural rated
roof sheathing need not be evaluated for these design wind pressures.
77. Structural rated roof sheathing that is at least 3/8'' in thickness,
installed with the long dimension perpendicular to roof framing
supports, and secured with fasteners at 4'' on center within 3'-0'' of
each gable end or endwall if no overhang is provided and 6'' on center
in all other areas, need not be evaluated for these design wind
pressures.
8Exterior coverings that are secured at 6'' o.c. to a 3/8'' structural
rated sheathing that is fastened to wall framing members at 6'' on
center need not be evaluated for these design wind pressures.
(2) Wind loads--zone designations. The Wind Zone and specific wind
design load requirements are determined by the fastest basic wind speed
(mph) within each Zone and the intended location, based on the Basic
Wind Zone Map, as follows:
(i) Wind Zone I. Wind Zone I consists of those areas on the Basic
Wind Zone Map that are not identified in paragraphs (c)(2)(ii) or (iii)
of this section as being within Wind Zone II or III, respectively.
(ii) Wind Zone II.....100 mph. The following areas are deemed to be
within Wind Zone II of the Basic Wind Zone Map:
Local governments: The following local governments listed by State
(counties, unless specified otherwise):
Alabama: Baldwin and Mobile.
Florida: All counties except those identified in paragraph
(c)(1)(i)(C) of this section as within Wind Zone III.
Georgia: Bryan, Camden, Chatham, Glynn, Liberty, McIntosh.
Louisiana: Parishes of Acadia, Allen, Ascension, Assumption,
Calcasieu, Cameron, East Baton Rouge, East Feliciana, Evangeline,
Iberia, Iberville, Jefferson, Jefferson Davis, LaFayette, La Fourche,
Livingston, Orleans, Plaquemines, Pointe Coupee, St. Bernard, St.
Charles, St. Helena, St. James, St. John the Baptist, St. Landry, St.
Martin, St. Mary, St. Tammany, Tangipahoa, Terrabonne, Vermillion,
Washington, West Baton Rouge, and West Feliciana.
Maine: Hancock and Washington.
Massachusetts: Barnstable, Bristol, Dukes, Nantucket, and Plymouth.
Mississippi: George, Hancock, Harrison, Jackson, Pearl River, and
Stone.
North Carolina: Beaufort, Brunswick, Camden, Carteret, Chowan,
Columbus, Craven, Currituck, Dare, Hyde, Jones, New Hanover, Onslow,
Pamlico, Pasquotank, Pender, Perquimans, Tyrrell, and Washington.
South Carolina: Beaufort, Berkeley, Charleston, Colleton,
Dorchester, Georgetown, Horry, Jasper, and Williamsburg.
Texas: Aransas, Brazoria, Calhoun, Cameron, Chambers, Galveston,
Jefferson, Kenedy, Kleberg, Matagorda, Nueces, Orange, Refugio, San
Patricio, and Willacy.
Virginia: Cities of Chesapeake, Norfolk, Portsmouth, Princess Anne,
and Virginia Beach.
(iii) Wind Zone III.....110 mph. The following areas are considered
to be within Wind Zone III of the Basic Wind Zone Map:
(A) States and Territories: The entire State of Hawaii, the coastal
regions of Alaska (as determined by the 90 mph isotach on the ANSI/ASCE
7-88 map), and all of the U.S. Territories of American Samoa, Guam,
Northern Mariana Islands, Puerto Rico, Trust Territory of the Pacific
Islands, and the United States Virgin Islands.
(B) Local governments: The following local governments listed by
State (counties, unless specified otherwise):
Florida: Broward, Charlotte, Collier, Dade, Franklin, Gulf, Hendry,
Lee, Martin, Manatee, Monroe, Palm Beach, Pinellas, and Sarasota.
Louisiana: Parishes of Jefferson, La Fourche, Orleans, Plaquemines,
St. Bernard, St. Charles, St. Mary, and Terrabonne.
North Carolina: Carteret, Dare, and Hyde.
(iv) Consideration of local requirements. For areas where local
building code requirements exceed the design wind speed requirements of
these standards, the Department will consider the adoption through
rulemaking of the more stringent requirements of the State or local
building authority.
(3) Snow and roof loads. * * *
(iii) Eaves and cornices shall be designed for a net uplift
pressure of 2.5 times the design uplift wind pressure cited in
Sec. 3280.305(c)(1)(i) for Wind Zone I, and for the design pressures
cited in Sec. 3280.305(c)(1)(ii) for Wind Zones II and III.
(4) Data plate requirements. The Data Plate posted in the
manufactured home (see Sec. 3280.5) shall designate the wind and roof
load zones or, if designed for higher loads, the actual design external
snow and wind loads for which the home has been designed. The Data
Plate shall include reproductions of the Load Zone Maps shown in this
section, with any related information. The Load Zone Maps shall be not
less than either 3\1/2\ in. by 2\1/4\ in., or one-half the size
illustrated in the Code of Federal Regulations.
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(d) Design load deflection. (1) When a structural assembly is
subjected to total design live loads, the deflection for structural
framing members shall not exceed the following (where L equals the
clear span between supports or two times the length of a cantilever):
Floor--L/240
Roof and ceiling--L/180
Headers, beams, and girders (vertical load)--L/180
Walls and partitions--L/180
(2) The allowable eave or cornice deflection for uplift is to be
measured at the design uplift load of 9 psf for Wind Zone I, and at the
design uplift pressure cited in paragraph (c)(1)(ii) of this section
for Wind Zones II and III. The allowable deflection shall be (2 x Lc)/
180, where Lc is the measured horizontal eave projection from the wall.
(e) Fastening of structural systems. (1) 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 specified in this part.
(2) For Wind Zones II and III, roof trusses shall be secured to
exterior wall framing members (studs), and exterior wall framing
members (studs) shall be secured to floor framing members, with 26 gage
minimum steel strapping or brackets or by a combination of 26 gage
minimum steel strapping or brackets and structural rated wall sheathing
that overlaps the roof and floor. Steel strapping or brackets shall be
installed at a maximum spacing of 24'' on center in Wind Zone II and at
a maximum of 16'' on center in Wind Zone III. The number and type of
fasteners used to secure the steel straps or brackets or structural
sheathing shall be capable of transferring all uplift forces between
elements being joined.
* * * * *
8. Section 3280.306 is amended by revising paragraphs (a)
introductory text and (b); adding a heading for paragraph (c)
introductory text; revising paragraphs (c) (1) through (3) and (d)
through (g) to read as follows:
Sec. 3280.306 Windstorm protection--support and anchoring systems.
(a) Provisions for support and anchoring systems. 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 tiedown system. The dead load of the structure may be used to
resist these wind loading effects in all Wind Zones.
(1) * * *
(b) Contents of instructions. (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.
(2) For anchoring systems, the instructions shall indicate:
(i) The minimum anchor capacity required;
(ii) That anchors should be certified by a professional engineer,
architect, or a nationally recognized testing laboratory as to their
resistance, based on the maximum angle of diagonal tie and/or vertical
tie loading (see paragraph (c)(3) of this section) and angle of anchor
installation, and type of soil in which the anchor is to be installed;
(iii) That ground anchors should be embedded below the frost line
and be at least 12 inches above the water table; and
(iv) That ground anchors should be installed to their full depth,
and stabilizer plates should be installed to provide added resistance
to overturning or sliding forces.
(v) That anchoring equipment should be certified by a registered
professional engineer or architect to resist these specified forces in
accordance with testing procedures in ASTM Standard Specification
D3953-91, Standard Specification for Strapping, Flat Steel and Seals.
(c) Design criteria. * * *
(1) The minimum number of ties provided per side of each home shall
resist design wind loads required in Sec. 3280.305(c)(1).
(2) Ties shall be as evenly spaced as practicable along the length
of the manufactured home, with not more than two (2) feet open-end
spacing on each end.
(3) Vertical ties or straps shall be positioned at studs. Where a
vertical tie and a diagonal tie are located at the same place, both
ties may be connected to a single anchor, provided that the anchor used
is capable of carrying both loadings, simultaneously.
(4) * * * * *
(d) Requirements for ties. Manufactured homes in Wind Zone I
require only diagonal ties. These ties shall be placed along the main
frame and below the outer side walls. All manufactured homes designed
to be located in Wind Zones II and III shall have a vertical tie
installed at each diagonal tie location.
(e) Protection requirements. Protection shall be provided at sharp
corners where the anchoring system requires the use of external straps
or cables. Protection shall also be provided to minimize damage to
siding by the cable or strap.
(f) Anchoring equipment--load resistance. Anchoring equipment shall
be capable of resisting an allowable working load equal to or exceeding
3,150 pounds and shall be capable of withstanding a 50 percent overload
(4,725 pounds total) without failure of either the anchoring equipment
or the attachment point on the manufactured home.
(g) Anchoring equipment--weatherization. Anchoring equipment
exposed to weathering shall have a resistance to weather deterioration
at least equivalent to that provided by a coating of zinc on steel of
not less than 0.30 ounces per square foot of surface coated, and in
accordance with the following:
(1) Slit or cut edges of zinc-coated steel strapping do not need to
be zinc coated.
(2) Type 1, Finish B, Grade 1 steel strapping, 1-1/4 inches wide
and 0.035 inches in thickness, certified by a registered professional
engineer or architect as conforming with ASTM Standard Specification
D3953-91, Standard Specification for Strapping, Flat Steel, and Seals.
* * * * *
9. Section 3280.403 is amended by revising paragraphs (b) and (e)
introductory text and by adding new paragraph (f), to read as follows:
Sec. 3280.403 Standard for windows and sliding glass doors used in
manufactured homes.
* * * * *
(b) Standard. By January 17, 1995, all primary windows and sliding
glass doors shall comply with AAMA Standard 1701.2-1985, Primary Window
and Sliding Glass Door Voluntary Standard for Utilization in
Manufactured Housing, except that the exterior and interior pressure
tests for components and cladding shall be conducted at the design wind
loads required by Sec. 3280.305(c)(1).
* * * * *
(e) Certification. Except as otherwise indicated in paragraph (b)
of this section, by January 17, 1995, all primary windows and sliding
glass doors to be installed in manufactured homes shall be certified as
complying with AAMA Standard 1701.2-1985 and design wind pressures
specified in Sec. 3280.305.
* * * * *
(f) Protection of primary window and sliding glass door openings in
high wind areas. For homes designed to be located in Wind Zones II and
III, manufacturers shall design exterior walls surrounding the primary
window and sliding glass door openings to allow for the installation of
shutters or other protective covers, such as plywood, to cover these
openings. Although not required, the Department encourages
manufacturers to provide the shutters or protective covers and to
install receiving devices, sleeves, or anchors for fasteners to be used
to secure the shutters or protective covers to the exterior walls. If
the manufacturer does not provide shutters or other protective covers
to cover these openings, the manufacturer must provide to the homeowner
instructions for at least one method of protecting primary window and
sliding glass door openings. This method must be capable of resisting
the design wind pressures specified in Sec. 3280.305 without taking the
home out of conformance with the standards in this part. These
instructions must be included in the printed instructions that
accompany each manufactured home. The instructions shall also indicate
whether receiving devices, sleeves, or anchors, for fasteners to be
used to secure the shutters or protective covers to the exterior walls,
have been installed or provided by the manufacturer.
10. Section 3280.404 is amended by revising paragraphs (b) and (e)
and by adding a new paragraph (f), to read as follows:
Sec. 3280.404 Standard for egress windows and devices for use in
manufactured homes.
* * * * *
(b) Performance. By January 17, 1995, egress windows including
auxiliary frame and seals, if any, shall meet all requirements of AAMA
Standard 1701.2-1985, Primary Window and Sliding Glass Door Voluntary
Standard for Utilization in Manufactured Housing and AAMA Standard
1704-1985, Voluntary Standard Egress Window Systems for Utilization in
Manufactured Housing, except as otherwise indicated in
Sec. 3280.403(b).
* * * * *
(e) Certification of egress windows and devices. Except as
otherwise indicated by paragraph (b) of this section, by January 17,
1995, egress windows and devices shall be listed in accordance with the
procedures and requirements of AAMA Standard 1704-1985 and design wind
pressures specified in Sec. 3280.305.
(f) Protection of egress window openings in high wind areas. For
homes designed to be located in Wind Zones II and III, manufacturers
shall design exterior walls surrounding the egress window openings to
allow for the installation of shutters or other protective covers, such
as plywood, to cover these openings. Although not required, the
Department encourages manufacturers to provide the shutters or
protective covers and to install receiving devices, sleeves, or anchors
for fasteners to be used to secure the shutters or protective covers to
the exterior walls. If the manufacturer does not provide shutters or
other protective covers to cover these openings, the manufacturer must
provide to the homeowner instructions for at least one method of
protecting egress window openings. This method must be capable of
resisting the design wind pressures specified in Sec. 3280.305 without
taking the home out of conformance with the standards in this part.
These instructions must be included in the printed instructions that
accompany each manufactured home. The instructions shall also indicate
whether receiving devices, sleeves, or anchors, for fasteners to be
used to secure the shutters or protective covers to the exterior walls,
have been installed or provided by the manufacturer.
11. Section 3280.405 is amended by adding paragraph (f), to read as
follows:
Sec. 3280.405 Standard for swinging exterior passage doors for use in
manufactured homes.
* * * * *
(f) Protection of exterior doors in high wind areas. For homes
designed to be located in Wind Zones II and III, manufacturers shall
design exterior walls surrounding the exterior door openings to allow
for the installation of shutters or other protective covers, such as
plywood, to cover these openings. Although not required, the Department
encourages manufacturers to provide the shutters or protective covers
and to install receiving devices, sleeves, or anchors for fasteners to
be used to secure the shutters or protective covers to the exterior
walls. If the manufacturer does not provide shutters or other
protective covers to cover these openings, the manufacturer must
provide to the homeowner instructions for at least one method of
protecting exterior door openings. This method must be capable of
resisting the design wind pressures specified in Sec. 3280.305 without
taking the home out of conformance with the standards in this part.
These instructions must be included in the printed instructions that
accompany each manufactured home. The instructions shall also indicate
whether receiving devices, sleeves, or anchors, for fasteners to be
used to secure the shutters or protective covers to the exterior walls,
have been installed or provided by the manufacturer.
PART 3282--MANUFACTURED HOME PROCEDURAL AND ENFORCEMENT REGULATIONS
12. The authority citation for part 3282 is revised to read as
follows:
Authority: 42 U.S.C. 5424; 42 U.S.C. 3535(d).
13. Section 3282.362 is amended by revising paragraphs (c)(3)(i)
(E) and (F) and adding a new paragraph (G), to read as follows:
Sec. 3282.362 Production Inspection Primary Inspection Agencies
(IPIAs).
* * * * *
(c) * * *
(3) * * *
(i) * * *
(E) Reference to the roof load zone and wind load zone for which
the home is designed and duplicates of the maps as set forth in
Sec. 3280.305. This information may be combined with the heating/
cooling certificate and insulation zone map required by Secs. 3280.510
and 3280.511. The Wind Zone Map on the Data Plate shall also contain
the statement:
This home has not been designed for the higher wind pressures
and anchoring provisions required for ocean/coastal areas and should
not be located within 1500' of the coastline in Wind Zones II and
III, unless the home and its anchoring and foundation system have
been designed for the increased requirements specified for Exposure
D in ANSI/ASCE 7-88.
(F) The statement:
This home has ____ has not ____ (appropriate blank to be checked
by manufacturer) been equipped with storm shutters or other
protective coverings for windows and exterior door openings. For
homes designed to be located in Wind Zones II and III, which have
not been provided with shutters or equivalent covering devices, it
is strongly recommended that the home be made ready to be equipped
with these devices in accordance with the method recommended in the
manufacturers printed instructions.
(G) The statement: ``Design Approval by'', followed by the name of
the agency that approved the design.
* * * * *
Dated: January 4, 1994.
Nicolas P. Retsinas,
Assistant Secretary for Housing--Federal Housing Commissioner.
[FR Doc. 94-825 Filed 1-13-94; 8:45 am]
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