# Mobile Home repairs and HUD certification



## Buelligan (Aug 27, 2020)

How many of you allow "repairs" or "renovations" to Manufactured Homes? We have been recently (last 5 years or so) stopped allowing any work beyond small cosmetic repairs to occur on any structure after 1976 with a HUD certification. We are working under the premise that a "Manufactured Home" constructed under the HUD Manufactured Housing Standards must be accepted as a "dwelling" regardless of compliance with IRC standards with the exception of installation requirements covered in the appendix.

We are fine with that, always have been, as I am sure most are. The problem is this. Our understanding of the HUD certification states that ANY modifications to the structure must be approved by the manufacturer and the DAPIA (3rd party federally approved inspection authority). Otherwise the "HUD certification" becomes null and void!

-With that said, does a structural modification, repair or any alteration to the structure, then render the structure out of HUD compliance, there for no longer a legal dwelling? (not cosmetic like paint, carpet or even cabinet replacement)
-Can the structure be recertified by a professional to the HUD standards?
-Can the structure be redesigned by a professional to IRC compliance?
-Since they are not covered "prescriptively" in the code, how and when do we require permits for  structural repairs and what "standards" do we apply?

When you do allow "repairs and renovations" to "mobile homes", what regulation do you apply?
For example window and door replacement? Subfloor replacement?, Roof truss repairs etc.? Most of what I see would not comply with and IRC requirements. I am concerned with allowing a mixture of standards and then rendering a structure non compliant with either standard.

We have seen quite a few of these situations recently and we are trying to find the proper path to deal with them. Seems to me that some of these "repairs/renovations" would exceed replacement costs in some cases. So why not just require replacement? Would there even be a path for this or not? We even had one stripped to the frame with a hack of lumber for complete rebuild!


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## Mark K (Aug 27, 2020)

At least in California mobile homes are regulated separate from buildings, thus I would assume the  building department is not involved.


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## Buelligan (Aug 27, 2020)

Mark K said:


> At least in California mobile homes are regulated separate from buildings, thus I would assume the  building department is not involved.



Thank you, unfortunately all dwellings in this county fall under our jurisdiction. So we need to figure out how and when we can let people repair and renovate these structures.


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## my250r11 (Aug 27, 2020)

Here the State deals with any MH repairs. I've been told that they require a certified engineer for MH to design changes to the structure. As for Additions if it is self supporting (as in if the home is repo'd the addition will stay behind), has its own service for power, and uses an existing door or window opening then the local AHJ deals with it. Only allowed to connect for weather proofing. Does this void the HUD cert. don't know. this is how it is done here.


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## ADAguy (Aug 27, 2020)

Ouch! a real conumdrum, what do hurricane and tornado states allow?


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## cda (Aug 27, 2020)

Buelligan said:


> How many of you allow "repairs" or "renovations" to Manufactured Homes? We have been recently (last 5 years or so) stopped allowing any work beyond small cosmetic repairs to occur on any structure after 1976 with a HUD certification. We are working under the premise that a "Manufactured Home" constructed under the HUD Manufactured Housing Standards must be accepted as a "dwelling" regardless of compliance with IRC standards with the exception of installation requirements covered in the appendix.
> 
> We are fine with that, always have been, as I am sure most are. The problem is this. Our understanding of the HUD certification states that ANY modifications to the structure must be approved by the manufacturer and the DAPIA (3rd party federally approved inspection authority). Otherwise the "HUD certification" becomes null and void!
> 
> ...







Not my area, but those look like total rebuild or remodel, and should meet either IRC or IBC.

To me it is not a manufactured home anymore. 


Do you allow new moblie homes to be set in your AHJ?


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## Sifu (Aug 27, 2020)

I have never permitted any structural changes to a MH unless evaluated/designed by an engineer.  Free-standing yes, attached but not supported by the MH maybe.  BUT I never even considered the question you pose.  Gotta be somebody inside HUD that can offer guidance....after they are the government!


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## Rick18071 (Aug 27, 2020)

I did a lot of work to my 780 sq. ft. mobile home. I attached a second mobile home, major structural, exterior and interior changes including roof trusses for a roof with a cathedral ceiling and a connected garage to it before the state had any building codes. More recently since codes have started here I had a architect design and got a permit for an addition and for a second floor over the garage and part of the old mobile homes.  The permit is 7 years old now and it's 90% done. No one came after me to extend the permit. My inspector is no longer in the area.

 Does this void the HUD cert. don't know and why should I care?

It now looks like a quarter million dollar house. Got 3,500 sq ft now.  I always need to show the tax man my 1972 mobile home title after they try to raise my taxes. Then they actually lower it because mobile homes depreciate in the mobile home blue book.


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## cda (Aug 27, 2020)

Rick18071 said:


> I did a lot of work to my 780 sq. ft. mobile home. I attached a second mobile home, major structural, exterior and interior changes including roof trusses for a roof with a cathedral ceiling and a connected garage to it before the state had any building codes. More recently since codes have started here I had a architect design and got a permit for an addition and for a second floor over the garage and part of the old mobile homes.  The permit is 7 years old now and it's 90% done. No one came after me to extend the permit. My inspector is no longer in the area.
> 
> Does this void the HUD cert. don't know and why should I care?
> 
> It now looks like a quarter million dollar house. Got 3,500 sq ft now.  I always need to show the tax man my 1972 mobile home title after they try to raise my taxes. Then they actually lower it because mobile homes depreciate in the mobile home blue book.




Work the system, and I guess living in the hills where no one can see you helps, and keeps the Still going.


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## ADAguy (Aug 27, 2020)

Rick18071 said:


> I did a lot of work to my 780 sq. ft. mobile home. I attached a second mobile home, major structural, exterior and interior changes including roof trusses for a roof with a cathedral ceiling and a connected garage to it before the state had any building codes. More recently since codes have started here I had a architect design and got a permit for an addition and for a second floor over the garage and part of the old mobile homes.  The permit is 7 years old now and it's 90% done. No one came after me to extend the permit. My inspector is no longer in the area.
> 
> Does this void the HUD cert. don't know and why should I care?
> 
> It now looks like a quarter million dollar house. Got 3,500 sq ft now.  I always need to show the tax man my 1972 mobile home title after they try to raise my taxes. Then they actually lower it because mobile homes depreciate in the mobile home blue book.



What does your insurance carrier say about replacement?


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## cda (Aug 27, 2020)

Kind of like taking a couple of shipping containers and building a house out of them

And city comes by and owner says it’s not a house,,, it is just a shipping container


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## Rick18071 (Aug 28, 2020)

ADAguy said:


> What does your insurance carrier say about replacement?


Nothing. I did have a clam once after I connected the two mobile homes and built the connected garage. A large amount of snow made the roof collapse. That's when I put the trusses and new roof on it with the insurance money.



cda said:


> Kind of like taking a couple of shipping containers and building a house out of them
> 
> And city comes by and owner says it’s not a house,,, it is just a shipping container



My title says a mobile home. I can't change it. The land is a official mobile home park and houses are not allowed.


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## cda (Aug 28, 2020)

Rick18071 said:


> Nothing. I did have a clam once after I connected the two mobile homes and built the connected garage. A large amount of snow made the roof collapse. That's when I put the trusses and new roof on it with the insurance money.
> 
> 
> 
> My title says a mobile home. I can't change it. The land is a official mobile home park and houses are not allowed.





Twilight Zone!!

Seems like once they go to far, it is no longer a mobile home and would fall under the I codes and your permitting process.


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## Buelligan (Aug 28, 2020)

my250r11 said:


> Here the State deals with any MH repairs. I've been told that they require a certified engineer for MH to design changes to the structure. As for Additions if it is self supporting (as in if the home is repo'd the addition will stay behind), has its own service for power, and uses an existing door or window opening then the local AHJ deals with it. Only allowed to connect for weather proofing. Does this void the HUD cert. don't know. this is how it is done here.


 Yes, we have seen and allowed this very scenario. As long as the "addition" is ENTIRELY self supporting and NO modification to the MH is done. Weather sealing must be done in a flexible manner to avoid mechanical connection. We do understand the need and try as best as we can to accommodate while staying within the bounds of intent. Which is why I am here. Thank you for your reply as it seems you are on the same page with our "additions" process. Very helpful.

While we are on the subject. The idea of adding the additional "dead load" of a second roof structure is another concern if we ever get another 3-4' of snow. Will that possible pancake one of these things? We have allowed a stand alone pavilion type structure only, as a potential roof replacement. I have seen a few large roof structures recently added to MH structures that have 2x3 walls sitting on a cantilevered floor supported by little angle iron "outriggers" to the steel beam. Not sure they are designed to handle all that.


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## e hilton (Aug 28, 2020)

Am i correct to assume that this discussion is referring to mobile homes and not modular homes.


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## jj1289 (Aug 28, 2020)

You should review Appendix E in the IRC which provides guidance for additions, alterations or repairs.  If structural modifications are made to the home they either have to be certified by HUD or prepared by a registered design professional. Below are excerpts from Appendix E of the 2018 IRC

*AE102.2 Additions, alterations or repairs*. Additions made
to a manufactured home shall conform to one of the following:
1. Be certified under the National Manufactured Housing
Construction and Safety Standards Act of 1974 (42 U.S.C. Section 5401, et seq.).
2. Be designed and constructed to comply with the applicable
provisions of the National Manufactured Housing
Construction and Safety Standards Act of 1974 (42
U.S.C. Section 5401, et seq.).
3. Be designed and constructed in compliance with the
code adopted by this jurisdiction.
Additions shall be structurally separated from the manufactured
home.
*Exception:* A structural separation need not be provided
where structural calculations are provided to justify the
omission of such separation.
Alterations or repairs may be made to any manufactured
home or to its building service equipment without requiring
the existing manufactured home or its building service equipment
to comply with all the requirements of these provisions,
provided that the alteration or repair conforms to that
required for new construction, and provided further that hazard
to life, health or safety will not be created by such additions,
alterations or repairs.
Alterations or repairs to an existing manufactured home,
which are nonstructural and do not adversely affect any structural
member or any part of the building or structure having
required fire protection, shall be made with materials equivalent
to those of which the manufactured home structure is
constructed, subject to approval by the building official.

*AE102.4 Existing occupancy.* Manufactured homes that are
in existence at the time of the adoption of these provisions
shall have their existing use or occupancy continued if such
use or occupancy was legal at the time of the adoption of
these provisions, provided that such continued use is not dangerous
to life, health and safety.
The use or occupancy of any existing manufactured home
shall not be changed unless evidence satisfactory to the building
official is provided to show compliance with all applicable
provisions of the codes adopted by this jurisdiction. Upon
any change in use or occupancy, the manufactured home shall
cease to be classified as such within the intent of these provisions.


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## my250r11 (Aug 28, 2020)

Buelligan said:


> While we are on the subject. The idea of adding the additional "dead load" of a second roof structure is another concern if we ever get another 3-4' of snow. Will that possible pancake one of these things? We have allowed a stand alone pavilion type structure only, as a potential roof replacement. I have seen a few large roof structures recently added to MH structures that have 2x3 walls sitting on a cantilevered floor supported by little angle iron "outriggers" to the steel beam. Not sure they are designed to handle all that.



Seen one where they used post and beam to support roof structure over the MH. Also one that they poured a footing and built a cripple wall under the existing exterior walls and the trusses set on top of existing walls. We didn't issue the permit for the cripple wall the state did. We did however issue the one for post and beam. We also issue placement permits in city limits where MH are allowed (Not in MH parks). We wait till the state signs off then we check for address, landings handrail etc. then give then a CO.


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## cda (Aug 28, 2020)

jj1289 said:


> You should review Appendix E in the IRC which provides guidance for additions, alterations or repairs.  If structural modifications are made to the home they either have to be certified by HUD or prepared by a registered design professional. Below are excerpts from Appendix E of the 2018 IRC
> 
> *AE102.2 Additions, alterations or repairs*. Additions made
> to a manufactured home shall conform to one of the following:
> ...





YOU GO,

That was my nonlegal thought:::



The use or occupancy of any existing manufactured home
shall not be changed unless evidence satisfactory to the building
official is provided to show compliance with all applicable
provisions of the codes adopted by this jurisdiction. Upon
any change in use or occupancy, the manufactured home shall
cease to be classified as such within the intent of these provisions.


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## ADAguy (Aug 28, 2020)

Very tricky and convoluted too. Hurricane lunched many of them.


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## cda (Aug 28, 2020)

ADAguy said:


> Very tricky and convoluted too. Hurricane lunched many of them.




That is why they call them 

“Mobile”


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## Rick18071 (Aug 31, 2020)

The state has nor adopted appendix E in the IRC



cda said:


> YOU GO,
> 
> The use or occupancy of any existing manufactured home
> shall not be changed unless evidence satisfactory to the building
> ...



There does not seem to be a legal way to change the title of the Mobile Home.


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## mtlogcabin (Aug 31, 2020)

When I was in Florida we permitted additions and roof overs on mobile and manufactured homes. The all had to be on there own individual foundations and structurally independent from the mobile/manufactured home and had to meet the building code. We also got permits for remodels and repairs and used the adopted building code as a "guide" 

Move to Montana and the local zoning code requires all new manufactured home installations to be installed on a permanent foundation and the state building codes prohibits us from permitting any work being done on the home itself. 

It is all in what you are comfortable with, and as far as voiding the certificate do you refuse to allow a used repaired or modified mobile/manufacture home be installed in your jurisdiction. I Fl it had to be 1976 or newer in Montana they can only be brand new homes unless they are going into a mobile home park.


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## ADAguy (Aug 31, 2020)

Wizard of "Oz" mobile.


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## Keystone (Aug 31, 2020)

Manufactured homes are designed as performance systems, when one part is affected all parts become affected.  With that said the only standard to rebuild would be the designer/company that originally built it. These homes have a chassis and can not be addressed in typical order. My answer “if the structure can be rebuilt to IRC standards”, no, but possibly engineering standards and most preferable the manufactures performance standard.


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## Rick18071 (Sep 1, 2020)

So what happens if the designer/company that originally built it is no longer in business and a tree fell on the mobile home causing structure damage?


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## Paul Sweet (Sep 1, 2020)

What would be wrong with replacing or sistering damaged lumber with the same size lumber?


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## Keystone (Sep 1, 2020)

Rick18071 said:


> So what happens if the designer/company that originally built it is no longer in business and a tree fell on the mobile home causing structure damage?



This does occur and we want to see every attempt to contact the originally designer or company that may have bought out or took over, otherwise it’s handled on a case by case basis and our office will make contact with Pa. DCED.


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## Keystone (Sep 1, 2020)

Paul Sweet said:


> What would be wrong with replacing or sistering damaged lumber with the same size lumber?



Form sistering basic components, I personally wouldn't take issue.issue permit and move on.


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## ADAguy (Sep 1, 2020)

Paul Sweet said:


> What would be wrong with replacing or sistering damaged lumber with the same size lumber?


I depends on how many and what they support.


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## Buelligan (Sep 3, 2020)

Thanks for all the input!



Paul Sweet said:


> What would be wrong with replacing or sistering damaged lumber with the same size lumber?



That is part of this inquiry. I believe that this is specifically prohibited with out approval from either the manufacturer/DAIPA (good luck with that), or recertified by professional designer/engineer.

Structural repair and modification that couldn't be "recertified" would then have to bring the entire structure up to IRC standards. That in and of itself could be more expensive than a replacement with a decent used unit. So while I agree that may seem reasonable, "reasonable" doesn't always stand up in court! Part of our job includes limiting any liability for the jurisdiction. So I am in search of a path to allow this in a way that protects all involved, should the unthinkable happen.


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## ADAguy (Sep 3, 2020)

Buelligan said:


> Thanks for all the input!
> 
> 
> 
> ...



should, would, will and may are all "possible"


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