In a release to the Daily Business News on MHProNews, the Manufactured Housing Association for Regulatory Reform (MHARR), is pressing the Department of Housing and Urban Development (HUD) to repeal the use of their “Formaldehyde Health Notice.”
MHARR’s statement says in part that they opposed the “baseless discrimination against HUD Code manufactured homes with respect to formaldehyde emissions and related mandates…” because “…there is no legitimate basis whatsoever, for exempting site-built homes, but not manufactured homes from the definition of a “finished good…”
Their full release is as shown below.
MHARR SUPPORTS PROPOSED REPEAL OF HUD “FORMALDEHYDE HEALTH NOTICE”
APRIL 16, 2019
TO: MHARR MANUFACTURERS
MHARR STATE AFFILIATES
MHARR TECHNICAL REVIEW GROUP (TRG)
FROM: MHARR
RE: MHARR SUPPORTS PROPOSED REPEAL OF
HUD “FORMALDEHYDE HEALTH NOTICE”
The Manufactured Housing Association for Regulatory Reform (MHARR), in comments filed with the U.S. Department of Housing and Urban Development on April 16, 2019 (copy attached), has voiced its support for the proposed repeal of the red “Formaldehyde Health Notice” required to be “prominently displayed” in every HUD-regulated manufactured home (but not other types of homes) since 1984, pursuant to 24 C.F.R. 3280.309. The repeal of the “Health Notice on Formaldehyde Emissions” mandate is part of a broader HUD-proposed rule, which – as required by the Formaldehyde Standards for Composite Wood Products Act of 2010 – would conform HUD manufactured housing standards concerning formaldehyde standards, testing and labelling with standards adopted generally by the U.S. Environmental Protection Agency (EPA) for composite wood products in accordance with that law.
While MHARR has long advocated the repeal of the HUD formaldehyde notice as a discriminatory imposition on manufactured homes constructed with the same materials as other types of homes not subject to any such mandate, and specifically called for the repeal of the HUD “Health Notice” in 2013 comments to EPA, the proposed repeal of the HUD “Health Notice,” in and of itself, does not end the longstanding practice of baseless discrimination against HUD Code manufactured homes with respect to formaldehyde emissions and related mandates. Rather, that pattern and practice is continued with the EPA standards (and the parallel HUD proposed standards) insofar as HUD-regulated manufactured housing is designated as a “finished good,” and therefore subjected to certain related regulatory requirements, while site-built homes are expressly exempted from the definition of a “finished good” contained in EPA’s 2016 final rule on formaldehyde standards. As MHARR noted then, and continues to press with relevant agencies and federal officials, there is no legitimate basis whatsoever, for exempting site-built homes, but not manufactured homes from the definition of a “finished good,” particularly when no such exemption was contained in EPA’s original proposed formaldehyde rule.
Accordingly, while MHARR supports the repeal of the discriminatory HUD “Formaldehyde Health Notice,” it continues to strongly object to EPA’s blatant double-standard – and continuing discrimination against manufactured housing – with respect to the “definition of a “finished good” and formaldehyde mandates related thereto.
In the event that you wish to comment individually on this matter, please feel free to reference or quote MHARR’s attached comments.
cc: HUD Code Industry Manufacturers, Retailers and Communities
Manufactured Housing Association for Regulatory Reform (MHARR)
1331 Pennsylvania Ave N.W., Suite 512
Washington D.C. 20004
Phone: 202/783-4087
Fax: 202/783-4075
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Submitted by Soheyla Kovach to the Daily Business News for MHProNews.com.
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