Thursday, October 8, 2015

A Code Inspector's Comment Could Change Our Industry Forever

Yesterday I received the following comment to an article I published on July 28,2015 talking about the problems local code inspectors cause in the modular home construction process.
“I'm a code inspector, and stumbled upon this conversation as I was researching how to deal with this issue. I work in a large city with all the ICC 2012 codes in place. We don't get many modular projects, but we've had a few and they might be picking up (it's hard to tell). 
It seems to me that the challenge is that we're not going to be able to see a lot of the underlying construction of the house. Some people have suggested a trip to the factory, but I'm not really sure that resolves things, since it just offers a look at operations that day, not the construction of the module under consideration.
 Furthermore, and while admittedly early in my process, I can't even tell what certifications or inspections a quality modular builder undertakes. I see the HUD manufactured housing requirements, are those considered the baseline? Do most manufacturers do ISO certification or anything else? It could be useful to develop a guide for inspectors helping to frame the issues: I'd recommend not some treacle about how great they are, but an actual guide to their strengths and weaknesses and what an inspector should look for. Our devils are all in the details. You write it, I'll read it.”
Signed KW
I see his/her point about in-factory workmanship, in-factory inspections of critical components and the code inspectors problem of not being able to see inside the walls. That is why the modular housing industry uses third party inspection services; to ensure that what is built in the factory meets or exceeds all Federal, state and local building codes.

But that may not be enough for local code inspectors who have to personally sign off on the house before the new homeowner takes possession and I really can’t blame them.

Did his comment boil this whole “local inspector vs modular home builder” battle down to its most basic problem? That’s up to you to decide.

What I really found most interesting was this line in his comment:
“It could be useful to develop a guide for inspectors helping to frame the issues: I'd recommend not some treacle about how great they are, but an actual guide to their strengths and weaknesses and what an inspector should look for. Our devils are all in the details. You write it, I'll read it.”

Could it be as simple as getting a group of code inspectors, factory people, third party inspectors, a few state code regulators and of course, modular home builders together, sitting down and creating a standard that all local code inspectors refer to when a modular house is sent into their jurisdiction?

Since your comment started this whole thing, I would like to ask “KW” to contact me and together we could begin to put your suggestion into motion. Two or three people from each segment of the process should be able to begin the process and who knows, we may all learn a lot about our industry’s present status and how to make our future brighter.

If you would like to volunteer to help with putting together an “actual guide to their strengths and weaknesses and what an inspector should look for”, simply contact me and if I get enough interest I will organize an initial meeting with the help of the MHBA. 

I’m willing to do it, are you willing to help?


Tom Hardiman said...

Good grief! What role or responsibility does the local code inspector have to learn his or her own job!? Thirty five states have administrative programs that include quality control, inspections, reviews, and approvals. Frankly its not the local AHJ's job to see the "underlying" construction - its the state's (and often through the 3rd party). Asking if the HUD requirements are the baseline? Develop a guide? All 35 states that have a program have a guide already.

This tells me that many locals are still clueless when it comes to modular construction and we have a LOT more education and outreach to do, not new forms, guides, or processes.

He says "you write it and I'll read it." Tell me what state he's in and I'll send him the guidelines.

Brian Flook said...

Coach, sounds like sour grapes and lack of training to me. It's like suggesting the new car you purchased from Lexus can't pass inspection because the local mechanic didn't see it built? Really. It is likely true that he has seen few examples of mod/system product, but that doesn't change the situation. The mod industry has and adheres to strict codes that are state regulated. The industry builds the most structurally sound homes in the country.

What we have isn't an inspection problem, it is an identity problem and a nationwide communication problem. I am - and have been for over 10 years - confident that the future of homebuilding belongs to the systems industry. We need leadership and marketing to make that happen. We need to change how the world sees us. Perhaps we need to consider the local audience more and do some educating.

Coach said...

I agree with both Tom and Brian. The state agencies do try to educate their local code people and in some instances are quite successful. Now put yourself in the code inspector's shoes when the first modular home ever comes into his jurisdiction. He or someone in his office reviewed the factory plans and issued a permit. Now the home is on his inspection calendar and it has already been set and weathered in.

Does he know enough about strapping, tie-ins, etc to say that the house was properly set. He/She wanders through the house and are told they can't inspect anything done in the factory. Why? they ask. Well, because most of it is covered up. They just have to take someone else's word for it, someone they never met is overriding their inspection authority.

In order to make inroads into a bigger share of the new home market, we as an industry have to reach out to the very bottom of the food chain, the local inspector in each municipality and educate them about modular third party inspections, what that means and then get them to buy into the modular concept. Not an easy job or for the faint of heart.

We've never worked at educating this group of people that can make or break a good set and a great home. We leave this job up to the states which may or may not give a rat's a** if the local inspectors truly understand a very small number of modular homes compared to all the site built homes they inspect on a daily basis.

Therefore I still believe we need to begin putting together a program to educate the local code inspector.

Anonymous said...

Good grief....we were having this conversation 20 years ago. I am retired and thought all of this had been sorted out with the visibility efforts on the part of the manufacturers providing trips for inspectors to the plants and county by county education of the various inspectors. On many occasions, our plant paid for trips to our production facility for the inspectors to see the actual construction of a project whose very nature generated concerns such as multifamily and commercial structures. They liked to see that fire stopping was properly executed. We never had an issue at the site. Bankers and insurance partners were also invited in. I do not agree with anyone that would say the manufacturers are not doing enough to calm the fears of inspectors, zoning boards, and first time builders. Currently, I know of no lives lost in a modular structure due to code/design issues. Inspectors! Get on the ball and educate yourself. The info is out there for you. The horse has been led to the water so to speak.

Stevehbgpa said...

Coach wrote, “put yourself in the code inspector's shoes, when the first modular home ever comes into his jurisdiction…”

The Coach is entirely correct. It doesn’t do the industry any service to take offence to this code officials questions. He is obviously not informed as to the specifics of the modular regulatory program in his state. As he said, “we don't get many modular projects [in his jurisdiction], but we've had a few and they might be picking up.”

We know there is a substantial regulatory programs in place in every state where modular homes are licensed and shipped. However, this code official, and I suspect many others are not aware of how the program works. Particularly in states, or localities where not a lot of modular homes have been sold in the past.

Generally each state reviews modular plans, either through a third party evaluation agency or by the state’s own plan review department. The plans are stamped by an engineer licensed in that state (usually the licensed third party doing the plan review for that state).

When the home is in production in the factory, the state has approved a quality control program for each manufacturer and has licensed third party inspectors to be in the factory reviewing the manufacturer’s quality control (QC) program to insure that each part of the manufacturing process is being performed in accordance with the manufacturers QC program and that the houses are being constructed in accordance with the approved plans and to the code for the state where that particular home will be finally sited. If the third party inspector or the manufacturers QC manager identifies a home that has a defect or is not in compliance with the approved plans, not only is that home “red tagged,” buy an audit is conducted to insure that other homes were not completed with the same defect. If a manufacturer consistently has problems in complying with the state approved quality control program and adhering to the approved plans, the frequency of inspections is increased.

It always bothers me when someone says, (usually to a local building inspector) that the local inspector is “not allowed to inspect the inside of the house.” This is completely untrue. Not only is the local inspector allowed to inspect the inside of the house and the work performed in the factory, he is required to inspect that work. The only thing the local inspector is prohibited from doing is any inspection that requires the destruction of the house. So, it is important for the local code official to understand that the work he cannot see has already been inspected in the factory.

In the final analysis, it’s a matter of educating the local code official, who is just trying to do his job, so that he understand that the construction he cannot see when the house is delivered and set has already been inspected in the factory and he can concentrate of the work he can see and the installation and finish of the home. Years ago, as the modular home business continued to increase in the northeast and we had a lot of problems with local inspector who were not aware of how the inspection process worked, we did some education programs for code officials. Perhaps more of that needs to be done. If all we do is take the attitude that it’s the state’s fault that the code officials are not informed as to how modular homes are regulated, while that may or may not be true, it’s our industry that will have the problem, on the day of the set, when it’s not going to be possible to call up the state and ask them why they are not doing their job.

Steven R. Snyder, Esquire
“Legal Counsel to the Modular Industry”

635 Glenbrook Drive
Harrisburg, PA 17110
(717) 975-7799 Voice and Text
Fax: 717-526-2044