Monitoring_and_Inspection_Services_PowerPoint__FINAL.pdf

MANUFACTURED HOUSING

MONITORING SERVICES

INDUSTRY DAY

Office of Manufactured Housing Programs

January 24, 2013

PURPOSE OF TODAY’S EVENT

• Provide interested prime contractors with an overview of HUD’s Office of Manufactured Housing Programs requirements for the anticipated acquisition of manufactured housing monitoring services.

• Respond to questions from perspective vendors regarding the monitoring and support services needed by the program office.

• Conduct market research.

Program Description

• The National Manufactured Housing Act of 1974, as amended in 2000, established the authority and framework for the preemptive Federal Standards and the Regulations used to enforce the Standards that are in use and effect today.

• The Act authorized HUD to regulate the design and construction of all new manufactured housing.

• The HUD Program is funded by label fees collected from manufacturers and by supplemental Congressional appropriations (needed due to declining production levels and reduced income collected in recent years).

• The Federal Manufactured Housing Program is administered exclusively from HUD Headquarters in DC (no support provided by HUD’s field offices)

• Program support is provided by private and state agency partners accepted by HUD.

• Contractor services are used to assist HUD in monitoring and assessment of performance of Private and State Agency partners.

Program Description

• Approximately Eight (8) million HUD Code Manufactured Homes have been built since the Program’s inception in 1976.

• In Calendar Year 2012, there were 55,000 HUD Code homes produced, comprised of 85,000 transportable sections.

HUD Code Production Levels

• THE HUD standards define a manufactured home as:

“A STRUCTURE, TRANSPORTABLE IN ONE OR MORE SECTIONS, WHICH IN THE

TRAVELING MODE IS EIGHT BODY FEET OR MORE IN WIDTH OR FORTY BODY

OR MORE IN LENGTH OR WHEN ERECTED ON SITE IS 320 OR MORE SQUARE FEET,

WHICH IS BUILT ON A PERMANENT CHASSIS AND DESIGNED TO BE USED AS A

DWELLING WITH OR WITHOUT A PERMANENT FOUNDATION WHEN CONNECTED

TO THE REQUIRED UTILITIES, AND INCLUDES THE PLUMBING, HEATING, AIR

CONDITIONING, AND ELECTRICAL SYSTEMS CONTAINED IN THE STRUCTURE…”

• THE HUD standards and regulations do not apply to modular or factory-built housing or self propelled recreational vehicles.

What Is A Manufactured Home?

Example Of A Single Wide Home

Example Of A Double Wide Home

• The National Manufactured Housing Construction and Safety Standards Act gives HUD authority to:

– Establish pre-emptive manufactured home construction and safety standards

– Determine whether manufactured homes comply with the standards

– Conduct inspections and investigations necessary to enforce the standards

– Contract with separate and independent organizations to carry out monitoring and inspection work

Manufactured Home Act

The Manufactured Housing Program, established by the National Manufactured Housing

Construction and Safety Standards Act, is a nationwide program established to protect the quality, safety, and affordability of manufactured homes through the enforcement of the Federal Manufactured Home Construction and Safety

Standards established by HUD.

Program Purpose

• 24 CFR 3280

Nationally Preemptive Manufactured Home Construction and Safety Standards

• 24 CFR 3282

Manufactured Home Procedural and Enforcement Regulations

Standards & Regulations

• 24 CFR 3285

Model Manufactured Home Installation Standards

• 24 CFR 3286

Manufactured Home Installation Program

• 24 CFR 3288

Manufactured Home Dispute Resolution Program

Other Standards & Regulations

• Production and Retail Stakeholders

– Manufactured Home Builders

• Currently about 50 corporations with 120 production facilities

– Manufactured Home Retailers

• About 2,000 retailers with about 4,000 locations

– Supply Chain

• Product and component suppliers, installers, etc.

Industry Stakeholder Overview

• About 10 million manufactured home owners

• 22 million Americans live in manufactured homes

• In 2011, manufactured housing accounted for:

– 71% of all new homes sold under $125,000

– 50% of all new homes sold under $150,000

– 30% of all new homes sold under $200,000

• Manufactured housing industry is an important economic engine, accounting for about 75,000 jobs

National Program & Industry Impacts

All Agencies/partners must be accepted by HUD:

• Design Approval Primary Inspection Agencies (DAPIA)

– Review and approve building plans and Quality Assurance Manuals /

Manufacturers contract with DAPIAs for design services provided

– 6 Agencies (5 private, 1 unit of state government)

• In Plant Primary Inspection Agencies (IPIA)

– Oversee implementation and effectiveness of quality assurance programs /

Manufacturers contract with IPIAs for In-plant inspection services provided.

– 15 Agencies (5 private, 10 units of state government)

• State Administrative Agencies (SAA)

– Handle consumer complaints and oversee manufacturer actions within their state related to remedial actions/SAAs are paid by HUD for enforcement services provided.

– 37 Agencies (All units of state government)

HUD Regulatory Partners

Primary objective of the monitoring services needed by the Program is assessment of the performance of these agencies to assure manufacturer compliance to HUD Standards and Regulations. This will require comprehensive knowledge of HUD Standards and Regulations to provide the monitoring oversight required.

Five Principal Tasks:

– Project Management Task

– IPIA Monitoring Task

• Evaluation and assessment of 15 entities through work at

120 facilities

• Tracking and monitoring of certification label sales and all home production/shipments (55,000 homes in 2012)

– DAPIA Monitoring Task

• Design library of nearly 7 million building plans

• Evaluation and assessment of 6 entities

– SAA Assessment Task

• Assessment of 37 state agencies

– Other Services Task PM IPIA DAPIA

SAA Other

DAPIA

IPIA

PM

Overview of Tasks

Monitoring Service to be Provided Activities

Develop work plan to accomplish each principal task

Prepare detailed monthly activity reports to monitor progress and status of each principal task.

• Plans relating available budget to resources and contract requirements/ deliverables

• Monthly Reporting

• Monthly Meetings

Provide a security plan that will maintain office and data in a secure manner.

• Maintain office space and safeguard data in accordance with the approved plan.

• Separate work functions from other activities

As directed, coordinate and provide information or resource support and assistance with other program contractors

• Attend coordination meetings as required by HUD.

• Information sharing and reporting

Program Management Tasks

Provide technical assistance, materials, procedures, and regulatory information to program partners

• Attend meetings/events

• Technical assistance and training for regulatory partners

Program Management Tasks

IPIA Monitoring Task

Develop and implement uniform audit procedures to collect and analyze data necessary to monitor and assess IPIA performance

• Maintain audit procedures

• Collaborate with and brief stakeholders

Develop and coordinate monitoring teams made up of qualified personnel including staff provided by State Administrative Agencies (SAAs)

Integrate qualified state personnel on monitoring teams

• Coordinate with stakeholders

• Develop and implement agreements with participating states

• Planning and Scheduling

• Technical training

Conduct quality assessment audits at manufacturer locations and on retailer lots for evaluating IPIA performance at each facility

• Planning and Scheduling

• Data collection/analysis

• Performance monitoring and measurement

• Report compilation

IPIA Monitoring Task

Production and distribution of labels to IPIAs

Verify label fees are collected and reported, determine program payments to states, and ensure home production and shipment information is reported

Track and report label fees generated through HUD’s sale of certification labels

• Provide a sufficient quantity of labels on a timely basis

• Data collection and analysis

• Prepare data reports and grant paperwork for distribution of funds paid to states

• Track documentation and compile reports of home production and shipment

Conduct overall Agency audit with IPIA leadership and management

Assess whether each in Plant Inspection Agency (IPIA) has adequately carried out regulatory responsibilities

• Data collection /analysis

• Report compilation

• Provide recommendations

Maintain a library of DAPIA approved manufacturer designs and quality assurance manuals

• Index incoming designs and manage design library

• Data collection/analysis

Develop uniform procedures to be followed by contractor staff to collect and analyze data necessary to monitor and assess DAPIA performance

• Implement design review procedures

• Collaborate with and brief stakeholders

Conduct review of manufacturer’s DAPIA approved engineered designs and supporting calculations and test data and quality assurance manuals

• Planning and Scheduling

• Data collection/analysis

• Performance monitoring and measurement

• identify engineering deficiencies and standards non-compliances

• Report compilation

• Coordinate with stakeholders

DAPIA Monitoring Task

Conduct audit with Agency leadership and management and develop written performance assessment reports with actionable recommendations

Assess whether Design Approval Primary Inspection Agencies (DAPIAs) have adequately carried out regulatory obligations

• Data collection /analysis

• Performance monitoring and measurement

• Report compilation

• Provide recommendations

DAPIA Monitoring Task

SAA Assessment Task

Conduct audit with SAA leadership and management and review records for complaint handling and enforcement necessary to develop written performance assessment reports

Conduct records reviews at manufacturer locations to collect data on whether manufacturer records are in compliance with regulations, and to assess performance of state agencies as applicable

Assess whether State Administrative Agencies (SAAs) have adequately carried out regulatory obligations

Conduct reviews of new or modified plans submitted by applicant states

• Planning and Scheduling

• Data collection/analysis

• Performance monitoring and measurement

• Coordinate with stakeholders

• Planning and Scheduling

• Data collection/analysis

• Performance monitoring and measurement

• Report compilation

• Coordinate with stakeholders

• Provide recommendations

• Report compilation

• Provide recommendations

• Data analysis

• Coordinate with stakeholders

• Report compilation

Other Support Services

Assist HUD in the review of special and complex design and alternative construction requests from manufacturers

• Conduct research, review designs and instructions

• Collect/analyze data

• Provide recommendations

• As directed, assist with follow-up monitoring and assessment activities

• Conduct on-site inspections to verify manufactured homes completed on-site per approval requirements

Conduct special investigations and studies (technical and non-technical) including data analysis

Conduct post disaster inspections and studies

Conduct studies and technical investigations of any Standard, Regulation or program related issue as required by HUD.

• Collect/analyze data

• Coordinate and meet with stakeholders

• Compile reports

• Develop guidance and provide recommendations

Contracted Service Activities

Respond to Freedom of Information Act requests

Research and provide relevant documentation maintained for monitoring and inspection purposes

• Data collection /analysis

• Prepare documentation

• Compile reports

Review, assess, and provide recommendations to Program Office on acceptance or rejection of applications from a state or organization to be accepted as a new Program Partner (DAPIA, IPIA, SAA)

• Data analysis

• Coordinate with stakeholders

• Report compilation and recommendations

Coordination with other HUD contractors • Attend meetings

• Provide reports

• Provide data and other information

Maintain a log of disputes and unresolved issues referred to HUD that have resulted from monitoring and inspection activities

• Collect/analyze data

• Coordinate and meet with stakeholders

• Compile reports

• Develop guidance and provide recommendations

As directed, provide expert testimony and engineering support at administrative proceedings including hearings

Participate in government committee meetings

Provide technical support at HUD meetings of program partners (DAPIAs, IPIAs, SAAs), meetings of the Manufactured Home Consensus Committee or at meetings of Federal or State Government Agencies

• Data analysis

• Prepare technical support materials

• Attend and participate in meetings

• Compile information and provide reports

• Recommendations

QUESTIONS