Manufactured Home Construction and Safety Standards Act Reporting Requirements

Forms and Documents

Document Name	Status
Supporting Statement A 2502-0253 20200408.docx Supporting Statement A	2020-04-08
42 U.S.C. 5403.pdf Supplementary Document	2019-06-28
24 CFR 3280.pdf Supplementary Document	2019-06-28
CFRs (24 CFR 3282) - Third Set.Relevant Provisions.docx Supplementary Document	2019-06-28

IC Document Collections

IC ID	Document Title	Status
27081	Manufactured Home Construction and Safety Standards Act Reporting Requirements	Modified

ICR Details

OMB Control No: 2502-0253	ICR Reference No: 201906-2502-002
Status: Received in OIRA	Previous ICR Reference No: 201706-2502-004
Agency/Subagency: HUD/OH	Agency Tracking No:
Title: Manufactured Home Construction and Safety Standards Act Reporting Requirements
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular	Date Submitted to OIRA: 06/12/2020

	Requested	Previously Approved
Expiration Date	36 Months From Approved	01/31/2021
Responses	183,959	59,304
Time Burden (Hours)	223,346	120,618
Cost Burden (Dollars)	0	0

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Abstract: The Federal Standards and Procedural Regulations require manufactured home producers to place labels and notices in and on manufactured homes and mandate State and Private agencies participating in the Federal program to issue reports. These Standards protect homebuyers' interests by requiring certain features of design and construction. In addition, information collected assists both HUD and State Agencies in locating manufactured homes with defects to ensure notification and/or correction by the manufacturer.

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Authorizing Statute(s): US Code: 42 USC 5403 Name of Law: Construction and Safety Standards
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
2502-AJ49	Proposed rulemaking	85 FR 5589	01/31/2020

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Manufactured Home Construction and Safety Standards Act Reporting Requirements

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ICR Summary of Burden

	Total Request	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	183,959	59,304	0	124,655	0	0
Annual Time Burden (Hours)	223,346	120,618	0	102,728	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Changing Regulations

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: This is a revision of a currently approved collection. For this submission of a revised information collection, HUD is making several adjustments to align with the final rule for addressing formaldehyde emissions requirements and regulations with HUD’s Standards and Enforcement Regulations. This submission also includes reflecting proposed revisions to the Standards and Regulations based primarily on the recommendations adopted by the Manufactured Housing Consensus Committee (MHCC), a consensus committee responsible for providing HUD recommendation to adopt, revise and interpret the Construction and Safety Standards. The MHCC was first established when the Act was amended in 2000 by the Manufactured Housing Improvement Act of 2000 (Pub. L. 106-569, approved December 27, 2000). Revisions include efforts to reduce regulatory burden by eliminating the need for manufacturers to obtain special approvals from HUD for certain construction design features and options such as two-story homes, carports, attached garages and CFM fan airflow efficiency. Various standards are being revised to reflect current construction practices used by the manufacturing housing industry and the home construction industry in general. Other changes define requirements for stairways, landings, handrails, guards and stairway illumination that would free manufacturers from having to follow various state and local requirements that vary from jurisdiction to jurisdiction and bring uniformity to manufactured home construction nation-wide. The rule also incorporates five new reference standards that are already standards used in the design, listing, and evaluation of the respective materials or component. Furthermore, under 24 CFR § 3282.14, manufacturers are required to engage in an Alternative Construction (AC) process to design and construct manufactured homes that incorporate innovations that have yet to be codified in HUD’s Construction and Safety Standards. After review of an AC request, HUD establishes specific terms and condition for use of the design through an AC approval letter. While the AC process serves a useful purpose, including encouraging the use of new technology in the construction of manufactured homes, the codification of certain design features can provide cost savings for manufacturers. Specifically, regulatory costs that are currently borne by the manufactured home manufacturer associated with preparing an AC request and maintaining the AC approvals include: • Manufacturers’ engineers’ preparation of designs, calculations, and or tests for aspects that do not conform with outdated building standards for past innovations that have become more commonplace but have not yet been incorporated into the Construction and Safety Standards; • Design Approval Primary Inspection Agency (DAPIA) review and approval of the designs, calculations, and or tests to be submitted on behalf of the manufacturers requesting HUD’s approval; • Preparation of a submission package for the AC request, including all designs, calculations, and tests to be sent to HUD for approval; • Lost opportunity costs and actual manufacturer and DAPIA staff time to respond to HUD throughout the review and approval process, that depending on the specific AC request may take as few as 30 days or as much as 6 months; • Time and travel associated with a third party’s inspections at each affected home’s site for every manufactured home built under an AC that requires a site inspection in order to verify conformance with specific terms and conditions of the AC approval including specific designs for completion; and • Maintaining and providing copies of AC-specific production reports, inspection reports, and other administrative burdens required to maintain the AC approval. See Supporting Statement question 15 for more information.

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Annual Cost to Federal Government: $1,299,462

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? No

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 06/12/2020

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