On August 16, MHI submitted comments to HUD opposing its proposed rule to establish new testing procedures for roof trusses. The proposed rule would, among other things, require all existing roof truss designs (approximately 1500) to be retested and recertified utilizing new, more time consuming and costly methods. MHI argued that the proposed procedures are unnecessary, and will increase costs to consumers with no demonstrated benefit. MHI and dozens of industry members and experts do not believe the proposed changes to the roof truss testing procedures will have any impact on performance.

MHI said that HUD’s rationale for the change is seriously flawed. According to HUD, its primary reasons for proposing new roof truss testing procedures is to make manufactured homes less susceptible to wind damage and reduce collateral damage to housing and other structures adjacent to manufactured housing. MHI said that the industry has a strong record for producing homes that withstand normal design and load requirements and there is no evidence to justify the additional testing procedures. MHI cited several government reports and studies confirming its assertion that homes built since 1994 (when the HUD Code was significantly revised to withstand high winds) have an excellent record of performance. MHI said that studies demonstrated that damage to homes, both site built and manufactured, during high winds was found to be roof shingles, roof sheathing, rather than faulty roof trusses.

MHI and the majority of its manufacturer members, roof truss supplier members and third party inspection agencies, submitted comments opposing the rule.

Click here to view MHI’s comments. Click here to view the proposed rule.

If you are a member and have questions, contact MHI Vice President of Regulatory Affairs Lois Starkey at lstarkey@mfghome.org.