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What Is The HUD Code?
By George Porter
What is the HUD Code?, Well, it is just a building code, that's
all. In fact it may be the simplest building code ever to exist
except for some early Roman Emperor's rules on construction. The
HUD Code basically says that if you can prove to the Department
of Housing and Urban Development that you can design and build
a home that will perform to their regional standards for roof
load, wind resistance, thermal efficiency, safety and durability,
then you can attach a label to it that says this home meets the
HUD Code. Obviously there are several layers of bureaucracy involved
in all of this, but that's about all there is to it.
There are fines for failures to comply with the Code and they
usually start at about $1000. The early Roman Emperor's codes
also had penalties. Caesar's building code was also a performance
code but had no real details like the HUD Code. Simply put, if
the building had severe problems then the architects and engineers
that designed it were executed. This Roman law produced some fantastic
buildings, but it is probably a good thing that this extreme idea
for enforcement was abandoned.
This present day federal building code for our homes came out
of "The National Manufactured Housing Construction and Safety
Standards Act of 1974" and became federal law on June 15,
1976. There are two main parts to what we call the HUD Code. The
first part is called "Part 3280, Manufactured Home Construction
and Safety Standards". This concerns itself with the standards
that the home must perform to and conform with, this is the construction
part of the code. "Part 3282 , Manufactured home procedural
and Enforcement Regulations" is the second part of the code,
and it talks about who is in charge of looking over who's shoulder
to make sure the home complies with Part 3280. To make it as simple
as possible you could say that 3280 is how you build the home
and 3282 is how HUD makes sure you do it right
Construction and enforcement are the two basic parts of any
building code: however, all other types of building codes seems
to have something very important that we, under the HUD Code,
do not have. It is that all building officials and the most of
the general public understand these other codes. Go to any building
official and ask him about all the building codes that apply in
his town and he will produce a copy of a "stick" building
code. Ninety nine out of one hundred officials will say that their
town uses the BOCA, CABO, Southern Building Code, or some other
"conventional" building code. Only one in one hundred
will also say that because the HUD Code is a preemptive federal
building code, that it too, is one of the codes used in their
town. Most have never heard of it, and therefore have no idea
what it is, what it means, or how it works.
It is also good to remember that every town hall or courthouse
that contains these local building officials, also houses the
local zoning folks. Probably not one in five hundred zoning officials
is familiar with the HUD Code, and those that are know it has
something to do with "trailers, mobile homes or manufactured
housing." Whatever you call it, it's all the same to them.
To most zoning officials these things mean trouble at zoning hearings.
Citizens packing hearing rooms and hallways, scared there is going
to be a "trailer park" near them.
The average citizen doesn't understand the HUD Code either,
probably not one in a thousand could tell you anything about it.
What most citizens know is that sometimes these manufactured homes
have problems and none of the local building officials have a
clue as to what to do about it. These officials only deal with
"real" homes. The poor folks that buy these home have
a hard time getting it fixed because most of the local plumbers
and carpenters don't work on "those homes". This is
a large circle of ignorance. and it seems to begin with the apparently
nearly "secret" HUD Code. Is there a course in a local
school or college near you that you could attend to learn about
the HUD code? Of course not. What high school or college knows
about the HUD code? Not one in ten thousand!
Who can we turn to, to inform the world about this simple and
building code that has been nationwide law for twenty-two years?
Well, if you are reading this article then it should be you. It
has to be you, there is no one else as qualified or probably with
as much to loose. The world can live without the HUD Code, in
fact, sometimes most of the world seems to be either ignoring
it or trying to make it go away. Frankly, can we really blame
them? When was the last time you trusted something you knew absolutely
nothing about? If the world learns to live without the HUD Code
then it is going to be living without your role in the manufactured
housing industry as well. Not a good vision for the future!
If you had to, could you give a half hour talk to your local
Rotary Club on the HUD Code? Do you know someone in your town
who could? Do you have a copy of the HUD Code? Do you know where
to get one? If you have answered "no" to any or all
of these questions then you need to brush up on the our Code yourself.
- 1. Get the Parts 3280 and 3282 from your state manufactured
housing association or write: NCSBCS, 505 Huntmar Park Drive,
Suite 210, Herndon, Virginia 20170
- 2. Read the table of contents then read the parts that interest
you the most first. This will give you a feel for how this law
is written and what it tries to do. Most of the Code uses words
like "shall be designed to" or "shall be capable
of". The code doesn't really say how to build a home or
even out of what kind of materials, but it does say how it has
to perform. The manufacturer has to prove that it performs when
the home is finished or the HUD label cannot be affixed.
- 3. When you have read about one third of these two little
books containing about one hundred pages apiece you will start
to get the sense that there really is a lot of science in these
homes. The requirements are very specific, and there are many
levels of inspection in part 3282. Read about the DAPIA and the
IPIA. These are a pair of inspection agencies that oversee the
design and construction of all of our homes. These inspection
agencies are a major key to the manufacturers confidence to place
the label on the rear of the home certifying that this home conforms
to the HUD Code. You will become amazed at the details that a
factory deals with to build every single home. It should give
you some extra confidence in our product and what these homes
can be when the science of installation equals the science of
- 4. "The Wheel Thing" To the best of my knowledge
every structure ever built by man had most of its parts brought
to the site by wheels. When they built the pyramids they used
logs for wheels and the World Trade Center in New York City used
trucks. Wheels mean nothing other than transportation, period!
- 5. If I had to pick a characteristic of our homes that is
the most different from "old fashion conventional"
homes it would be the floor system not the wheels. The weakest
part of a conventional home's floor is the center of the span
between the two walls. The longer the span the larger the joists
have to be so they don't sag. Our floor joists are much smaller
(and therefore cheaper) because the longest span is between the
main beams of the frame of the home, usually a little over eight
feet. Our weakest point in the floor is the edges because there
is no real support at the perimeter of the home. The floor joists
alone hold the walls up unless they get some help from some extra
support. You could say our walls sit on diving boards and conventional
homes have trampolines for floors. The trick is of course to
make the trampoline so stiff it hardly bends at all and to do
the same thing with the diving boards. All conventional floors
sag over time, and all HUD Code home floors crown over time because
of plain and simple gravity. Ideally this sagging is so slight
as to not be noticed, but sometimes something causes them to
sag more than is acceptable.
- 6. If you have a sixteen foot conventional floor with a grand
piano in the center of it, one of three things must happen. #1,
the floor will sag under the extra weight; #2, the floor will
get extra support under it in the location of the piano and will
not sag; #3, the floor was originally designed to hold the extra
weight and will not sag with the piano on it. Suppose you had
a large upright piano next to the exterior wall that weighed
about the same as the grand piano? This is the strongest part
of the conventional floor because it is where it is supported
by the foundation and chances are that you would not have to
do anything extra.
- 7. Let's use the same scenario on a HUD Code Home. Suppose
the piano, pianist and candelabra weight 1500 lbs. and you put
them in the middle of a sixteen foot wide section of one of our
homes. What would you have to do? First of all the floor is tested
to hold 40 lbs. per square foot so as long as there was nothing
but this collection of weight in an area of a little over 6ft.
x 6 ft., 37.5 square feet to be exact, there is no problem. The
problem might come from the three legs of the piano and their
concentrated load on the floor. If the piano had wheels and the
part of each wheel touching the floor was 1/16 of an inch by1
inch then the surface area of each wheel is .0625 square inches.
Three wheels equal .1875 total square inches with 1500 lbs. total
weight or 8,000 lbs. per square inch. The HUD Code says that
all of our homes are tested to hold a 200 lb. load on a one inch
diameter disc with a deflection of no more than 1/8 of an inch
at its most critical point. Obviously this is not enough to hold
the big piano on it's wheels. If you increase the holding area
under each wheel by at least a 4x4 inch non-flexible pad and
make sure each leg is on a different floor joist you will probably
be OK. When you get to the sidewall of the same room you have
a different problem. The "diving board" floor joists
will bend under the large load so you will have to not only put
pads under the piano wheels but also install adequate supports
under the perimeter of the home in this area.
- 8. This is probably a lot more than you want to know about
floor loading. The real purpose here is to point out that the
HUD Code contains a lot of fine details and can answer nearly
every question about our homes. If you are in this business it
just might save you from making a large mistake some day. Plus
when you have customers with a piano or some other heavy piece
of furniture, you can help both yourself and them with your knowledge
of your industry.
- 9. One last point, can you imagine what happens when you
don't grade the lot properly and don't put down a vapor barrier
on the dirt under the home? The floor gets a little damp from
the humidity in the crawl space, and all this science and math
flies right out the window when the piano falls through the floor.
The most important thing that this industry needs to learn is
how to keep these homes in compliance with the HUD Code both
before and after the sale. This, of course, is accomplished by
proper installation. Proper installation is accomplished by doing
what it says in the directions that come with the home. The more
you know about the HUD Code, the more you realize how critical
are manufacturers instructions. Getting it right is the #1 greatest
asset for your future and getting it wrong will surely be your
We have a very good building code here and if we can just explain
it to the rest of the people in our towns and counties then they
will come to trust it as another acceptable way to build a home.
They will also understand how important it is to do certain things
that may be somewhat different from what they are used to. They
may even come to think of the HUD Code as just another way to
build a home, and that is all this industry will ever need to
drastically increase our market share of single family homes.