As previously reported by MHARR, the Government Accountability Office (GAO) released a report on October 24, 2012 regarding ventilation in HUD Code manufactured homes and specifically the issue of separation between air intakes and exhaust vents, which, under the current HUD standards, must be separated by a minimum of three feet. The report questions the three foot separation standard, noting that “industry standards for site-built homes have required a greater distance for many years.” The underlying concern, as stated by the report summary, is that the “exhaust of an improperly operating furnace combined with unique wind conditions could, in rare cases present a risk of carbon monoxide exposure.” (Emphasis added). The report recommends that HUD: (1) “develop an appropriate method to test and validate the performance of the ventilation system as part of the HUD certification process” and (2) “reassess the assumptions” for its “whole house ventilation specification, working with the MHCC.”
Now, in accordance with the report and the process specified and required by the Manufactured Housing Improvement Act of 2000, HUD is bringing this standards matter to the MHCC for its review and recommendations. In a January 10, 2013 communication with MHCC members through the MHCC Administering Organization (AO), HUD forwarded the GAO report and its two recommendations to MHCC members for their “consideration and appropriate action.”
On one level, it is noteworthy that HUD, in bringing this issue to the MHCC, is acting as it should under the 2000 reform law and deserves credit for complying with the process established by law for addressing a matter involving an assessment and possible modification of an existing standard. At the same time, though, the industry will need to carefully monitor and participate in the ensuing MHCC proceedings (to the extent possible given the restrictions that HUD has placed on participation, including the exclusion of collective national industry representatives) to ensure – as much as possible — that they remain focused on the specific issue of vent separation for what GAO acknowledged would be “rare” instances of possible exhaust in-venting, and not become a free-for-all on the vague, subjective and ill-defined issue of “indoor air quality” based on loose phrasing within the GAO report, especially given the recent history of this matter before the MHCC.
In advance of MHCC consideration of this issue, MHARR will contact manufacturers to seek relevant information and will provide input to the MHCC as necessary and appropriate under the circumstances.
Manufactured Housing Association for Regulatory Reform (MHARR)
