HUD Code Changes Summary and Reference Guide

Monday, January 13, 2025 3:41:29 PM

There has been a lot of talk over the past few months about the sweeping and significant HUD Code changes released back in September 2024. The rule changes comprise of 74 incorporated references within the HUD Code to other recognized standards and 16 new standards. The changes rolled out by HUD were both the culmination of industry supported recommendations, as well as some innovative new multi-unit (duplex, tri-plex and four-plex) allowances that are poised to be game changers in some markets.

As any member knows from reading many of our other posts whether it be about new tax laws (those were some barnburner posts, weren’t they) or mortgage regulations, we here at TMHA, on occasion, simply can’t help ourselves and must take a deep, uber-nerd level dive into new laws and regulations. We are working on finding better hobbies, but until then we will stick with this one.

So, let’s get into it. What exactly did HUD roll out or is going to roll out when many of the provisions become effecting in March of 2025?

The goal here is to provide a comprehensive breakdown with quick links, and some limited commentary on the changes. The rule itself also has some summaries and tables that are useful, but in its entirely the rule is 56 pages of three collum content.

For the full post on the new regulations (in a more readable version) you can visit the Federal Register post on September 16, 2024.

The effective date for these changes is March 17, 2025.

Part 3280 MH Construction and Safety Standards

Definitions:
1. Revising the definition for “Certification label”;
2. Adding, the definition for “Dwelling”;
  1. Dwelling “means any structure that contains one to a maximum of four dwelling units, designed to be permanently occupied for residential living purposes.”
  2. NOTE: This is a key definitional change that paves the way for multi-unit MH
3. Revising the definition for “Dwelling unit”; and
  1. Dwelling unit “means a single unit that provides complete independent living facilities for one or more persons, where the occupancy is primarily permanent in nature, including permanent provisions for separate living, sleeping, cooking, eating, and sanitation.”
  2. NOTE: This is a key definitional change that paves the way for multi-unit MH
4. Adding the definitions for “Multipurpose fire sprinkler system”, “Stand-alone fire sprinkler system”, and “Water resistive barrier”
Incorporation by reference – This includes 74 references to other standards to be included within the HUD-Code, which include references to standards like ANSI, IBR, AFPA, ASCE, etc.
Data Plate - Each dwelling unit of a manufactured home must bear a data plate affixed in a permanent manner near the main electrical panel or other readily accessible and visible location
More Definition Changes – Air, exhaust; Air outdoor; Exhaust system; Gross floor area; Habitable room; Laundry area; Mechanical ventilation; Nature ventilation; Supply system; and Ventilation
Light and ventilation – Each dwelling unit must have whole-house ventilation of at least 0.035 ft3/min/ft2 of interior floor space or its hourly average equivalent. Also standards for kitchens (exhausting 100 cfm to the outside of the home), bathrooms (exhausting 50 cfm to the outside of the home), optional ventilation provisions, and airflow ratings.
Exit; exterior doors – Each dwelling unit must have at least two exterior doors, the doors cannot be in the same room, and exterior doors must be at least a minimum 28 inch wide by 74-inch-high clear opening. All exterior sliding glass doors must provide a minimum 28 inch wide by 72-inch-high clear opening. At least one exterior egress door must provide a minimum of 32 inch wide by 74-inch-high clear opening and door seals and/or door stops are not permitted to reduce the opening.
Room requirements – Must have at least one living area with at least 150 sqft.
Hallways – Minimum horizontal dimensions of 28 – 30 inches (depending on MH specs), with additional laundry room requirements.
Galls and glazed opening - Glazing material must be capable of meeting the requirements of Consumer Product Safety Commission.
Sound transmission between multi-dwelling unit manufactured homes – Standards for walls, and floor/ceiling for multi-unit (duplex etc.) MH. Walls, partitions, floor/ceiling separation dwelling units must have sound transmission class (STC) of not less than 34 for air-borne noise when tested in accordance with ASTM E90. Floor/ceiling assemblies between stories separating dwelling units must have an impact insulation class (IIC) rating of not less than 34.
Flame spread limitation and fire protection - Exposed bottoms and sides of kitchen cabinets as required by § 204 except that non-horizontal surfaces above the horizontal plane formed by the bottom of the range hood are not considered exposed.
Kitchen cabinet protection – 5/16 gypsum board requirements for certain sides of exposed cabinets, and for range hood finish material.
Smoke alarms – Smoke alarms must meet UL 217 or UL 268, and must be labeled as such.
Carbon monoxide alarms – Carbon monoxide alares must meet UL 2034 and be labeled as such.
Fire sprinkler system requirements – Not required under the HUD-code, but when installed to meet consumer option or local requirements, 3280.214 provides the sprinkler (where required) standards. Including a Fire Sprinkler System Certificate affixed next to the data plate.
1. NOTE: fire sprinklers for MH are not required in Texas and local governments are preempted from mandating residential fire sprinklers in Texas under Texas state law.
Multi-dwelling unit MH (i.e. duplex, tri-plex, four-plex) – Units must be separated by wall and floors that have at least 1 hour fire resistance rating, with additional requirements for gypsum board, wall, attic, framing, through penetrations, membrane penetration, etc.
Draftstopping requirements - For multi-dwelling unit manufactured homes, when there is usable space both above and below the concealed space of a floor/ceiling assembly in multi-dwelling unit manufactured homes, draftstops must be installed so that the area of the concealed space does not exceed 1,000 square feet. Draftstopping must divide the concealed space into approximately equal areas. Additional provisions for assemblies enclosed by membranes.
General requirements (construction standards general) – Must conform to 3282.203 and 3282.361(c) and accepted engineering practices.
Materials – Aluminum, steel, wood, widows, fiberboard, fasteners, PVC, PP, etc. with references to acceptable national standards.
Structural design requirements – Welding specifications, roof designed for 20lbs per square foot of attic floor live load, attic design and accessibility, slope of joists and truss, and insulation depth.
Resistance to elements and use – Exterior wall Water Resistive Barrier requirements.
Vinyl and polypropylene siding used in MH – Vinyl siding must meet ASTM D3679 and polypropylene siding ASTM D7254; and installation requirements.
Windows, sliding glass doors, and skylights – Mandatory minimum compliance standards with national standards references, safety glazing, and certification required.
Egress windows and devices – Minimum egress widow requirements with national standard refences, minimum design loads, dimensions of 20” horizontal, 24” vertical, and clear opening at least 5’; with certification and evidence of certification.
Swinging exterior passage doors – Design and performance standards to national standard, references, allowable materials, and certifications.
Condensation and vapor retarders – Value Zone 2 and 3, ceilings must have a vapor retarder with a permeance of not greater than 1 perm as measured by ASTM E96/E96M, installed on the living space side of the roof cavity; any liquid applied vapor retarder must meet the same ASTM rating.
Heat loss certificate – Must be affixed to an interior surface of each dwelling unit that is readily visible to the occupant.
Comfort cooling certificate and information – Must affix a “Comfort Cooling Certificate” to an interior surface of each dwelling unit that is readily visible to the occupant; and the max AC capacity certified with ANSI/AHRI Standard 210/240 with Addenda 1 and 2.
Heat tape (if used) – Must include a statement in the installation instructions required by § 306(b), stating that if the heat tape or pipe heating cable is used, it must be listed or certified for its intended purpose.
Materials and appliances – Extensive list of materials standards with refences to national standards for pipe and fittings, rubber gaskets, plumbing components, plumbing fixtures, etc.
Plumbing fixtures – Shower compartment specifications, roll-in-shower specifications, and combination valves.
Hot water supply – Each dwelling unit must have a kitchen sink, and bathtub or shower provided with hot water supply.
Vents and venting – Max distance of fixtures from vent traps.
Air ducts and connectors – Revised definitions for Class 0 and Class 1.
Heating, cooling and fuel burning appliances/systems – Lists of multiple systems and appliances, such as furnaces, AC and heat pump appliances, clothes dryers, cook tops, smoke alarms, pip and fittings, air ducts and connectors, gas appliances, chimneys, fireplaces, etc. that are acceptable if they meet referenced national standards.
Gas piping – Minimum standards with refences for steel, wrought-iron, copper, and corrugated steel tubing, and connectors and joints standards used in gas piping.
Oil piping - Minimum standards with refences for steel, wrought-iron, copper, and corrugated steel tubing, and connectors and joints standards used in oil piping.
Heat producing appliances - All gas and oil-fired automatic storage water heaters shall have a recovery efficiency, E, and a standby loss, S, as described with the Table reference and conform to refence national standards.
Installation of appliances – Must install in accordance to the appliance manufactured requirements; solid fuel burning fireplaces and stoves standards, and water drip collection and drain pan must be install under each tank-type water heater or hot water storage tank that will drain to the exterior of the home.
Multiple appliance instructions or QR code - Operating instructions for each appliance must be provided with the homeowner's manual, and an additional copy of the operating instructions must be provided with each appliance unless the appliance is affixed with a permanent Quick Response (QR) Code.
Cooling Appliances – Minimum ratings and national standards for air conditioners, electric motor AC standards and ratings, heat pumps standards and rating, Electric motor-driven vapor compression heat pumps, and Gas fired absorption air conditioners.
Circulating air systems (supply ducts etc.) – Air ducts standards and acceptable materials, diameter and width specifications (see table), joints, seams, and fitting connections specifications.
Electrical conductors and arc-fault breakers – In addition of references NFPA standards, the use of arc-fault breakers under the NFPA 70, are only required for general lighting circuits. Smoke alarms installed on a dedicated circuit do not require arc fault protection. Wherever arc-fault breakers are provided, such use must be in accordance with NFPA 70. Wherever the requirements of these standards differ from NFPA 70, these standards apply.
Feeder assembly (definition) - Means the overhead or under-chassis feeder conductors, including the grounding conductor, together with the necessary fittings and equipment, or a power supply cord approved for manufactured home use, designed for the purpose of delivering energy from the source of electrical supply to the distribution panelboard within each dwelling unit.
Power Supply of Feeder Assembly – Power supply requirements, color-coded connectors, service equipment, grounding and red warning label on service equipment on need to ground electrodes etc.
Disconnecting means and branch-circuit protective equipment – Disconnecting means, panelboard, fuses/switch, circuit breakers, etc.
Branch Circuits Lighting Specs - The number of 15 or 20 ampere lighting circuits is based on a 3 volt-amperes per square foot times the outside dimensions of each story of each dwelling unit (coupler excluded) divided by 120 volts times the amperes.
Receptacle outlets – Must be installed to Article 406.3 of NFPA 70; and at least one receptacle outlet shall be installed outdoors. Additional outdoor receptacles must comply with Article 210.52(E)(3) of NFPA 70.
Lighting Fixture over bathtub or shower - Where a lighting fixture is installed over a bathtub or in a shower stall, it must be listed for wet locations.
Wiring methods and materials – General wiring specs for MH are NFPA 70, with outdoor or under-chassis line voltage that is exposed to moisture must be protected and suitable for wet conditions. Additional specific specification of outlet boxes and bracing requirements to secure a box fitting.
Electrical testing – Polarity checks must adhere to standards and Article 550.17 of NFPA 70; visual verification is acceptable for polarity check.
Option method for calculating lighting and appliance load - For manufactured homes served by single 3-wire 120/240 volt set of feeder conductors with an ampacity of 100 or greater. The total load for determining the feeder ampacity may be computed in accordance with the table (see rules for Table) instead of the method previously specified.
Attached manufactured homes unit separation (multi-unit) - Attached manufactured homes shall be separated from each other by a fire separation wall of not less than1-hour fire-resistive rating with exposure from both sides on each attached manufactured home unit when rated based on tests in accordance with ASTM E119

Part 3282 – Manufactured Home Procedural and Enforcement Regulations

Minor definition reference and reorganization.
Manufacturer reports for joint monitoring fees - The manufacturer must submit to the IPIA in each of its manufacturing plants, and to HUD, a monthly production report that includes the serial numbers of each manufactured home manufactured and labeled at that plant during the preceding month. The report must also include the date of manufacture, State of first location of these manufactured homes after leaving the plant, type of unit, number of dwelling units, and any other information required under this part. For all homes to be completed pursuant to subpart M of this part, the production report must also include a brief description of the work to be completed on site. The monthly report must be submitted by the 10th day of each month and contain information describing the manufacturer's previous month's activities.

Part 3285 – Model Manufactured Home Installation Standards

Added new Definitions – for “peak cap assembly” and “peak flip assembly”
Fireplaces and wood-stoves - When not provided by the home manufacturer, fireplaces and wood-stoves must be listed for residential use and must be installed in accordance with their listings.
Testing and certification for fire sprinkler systems (where required Not Applicable in Texas) – Requires a fire protection technician to test and certify all fire sprinklers and provide a report to the installer.
Water supply - Only heat tape or pipe heating cable listed and certified for its intended purpose is permitted for use, and the water system must be inspected and tested for leaks after completion at the site. The installation instructions must provide testing requirements that are in accordance with the piping manufacturer's instructions.
Exterior close-up – For hinged roof pitches less than 7:12, and design for peak cap or peak flip assembly components.

Part 3286 Manufactured Home Installation Program (this is for “default states” and does not apply to Texas)

DAPIA-approved installation instructions – Retailer must provide DAPIA-approved installation instruction to purchaser or lessee, any installation requirements that are different than the manufacturer designs must be prepared and certified by an engineer, when the retailer or manufacturer agrees to provide any set up in connection with the sale of the home, the retailer or manufacturer must provide to the licensed installer a copy of the approved installation instructions.
Installation license and maintaining licenses – An installer in a default state must have, and maintain insurance and either a surety bond or letter of credit, must provide proof of insurance and failure to maintain the insurance or bond can result in suspension or revocation of installers license.
Contract rights not affected for not arranging installation - Failure to arrange for an inspection of a home within 10 business days will not affect the validity or enforceability of any sale or contract for the sale of any manufactured home.