Manufactured Home Construction and Safety Standards Act Reporting Requirements
Revision of a currently approved collection
No
Regular
06/12/2020
table that charts list comparision
Requested
Previously Approved
36 Months From Approved
01/31/2021
183,959
59,304
223,346
120,618
0
0
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.
US Code:
42 USC 5403
Name of Law: Construction and Safety Standards
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 HUDâs 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 HUDâs 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:
⢠Manufacturersâ engineersâ 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 HUDâs 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 partyâs inspections at each affected homeâs 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.
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:
(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;
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.
Supporting Statement A 2502-0253 20200408.docx
42 U.S.C. 5403.pdf
Manufactured Home Construction and Safety Standards Act Reporting Requirements