Let’s be clear. For years, not only manufactured housing, but other forms of housing had formaldehyde. The health notices that were required in manufactured homes were arguably discriminatory. Science says there can be more formaldehyde in parts per million (PPM) in the normal person’s breath than there used to be in the components going into manufactured homes, or other forms of site-built conventional housing.
That doesn’t mean that for a tiny minority that it wasn’t a potential issue. It just means that it was arguably unfair to place a notice in manufactured homes that were not also placed in other forms of construction too. After all, the emissions came from components that went into conventional housing, as well as manufactured homes.
That said, that small level of formaldehyde has been dropping due to changes made possible by free enterprise and advances by firms in the production supply chain.
With those quick backdrops, tonight’s report from the Manufactured Housing Association for Regulatory Reform is another piece of potentially good news from HUD. Here’s what the Washington, D.C. based MHARR told the Daily Business News on MHProNews earlier today. Note, the illustrations are by MHProNews, not MHARR.
MARCH 22, 2019
TO: MHARR MANUFACTURERS
MHARR STATE AFFILIATES
MHARR TECHNICAL REVIEW GROUP
RE: HUD PROPOSES RULE TO ADOPT EPA FORMALDEHYDE STANDARDS — ELIMINATE FORMALDEHYDE “HEALTH NOTICE”
The U.S. Department of Housing and Urban Development (HUD), in the March 22, 2019 edition of the Federal Register, has issued a proposed rule that would amend the Federal Manufactured Housing Construction and Safety Standards (24 C.F.R. 3280) and Procedural and Enforcement Regulations (24 C.F.R. 3282) to incorporate formaldehyde emission controls and related certification requirements previously adopted by the U.S. Environmental Protection Agency (EPA) pursuant to the Formaldehyde Standards for Wood Products Act of 2010. HUD’s action implements a directive in that law, requiring HUD to update its manufactured housing formaldehyde standards to ensure consistency with the EPA standards, within 180 days of the enactment of the EPA standards.
Given the statutory nature of this mandate, MHARR, in comments before the Manufactured Housing Consensus Committee (MHCC), at its October 25-27, 2016 in-person meeting, and in separate regulatory reform comments pursuant to Trump Administration Executive Orders 13771 and 13777, submitted to HUD in June 2017 and February 2018, specifically called on the Department to repeal the red formaldehyde “health notice” currently required by section 3280.309 of the federal manufactured housing standards. Emphasizing that the new EPA requirements apply to composite wood building materials across-the-board, and that “manufactured homes utilize the same construction materials as site-built and other types of homes,” MHARR stated that the “discriminatory requirement [for] each manufactured home [to] prominently display” the red formaldehyde “health notice,” must be repealed.
And now, based on MHARR’s position on this matter, HUD is planning, as part of its March 22, 2019 proposed rule, to eliminate this red formaldehyde “health notice” which has been a subject of significant controversy – and a discriminatory impediment to the industry and its growth – for over three decades.
Comments on HUD’s proposed rule must be submitted by April 22, 2019. MHARR, as usual, will submit comments in advance of the deadline, which may be cited by other interested parties. This matter, in addition, will be addressed at MHARR’s upcoming Board of Directors meeting.
cc: Other Interested HUD Code Industry Manufacturers
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This is consistent leadership on the production side of association engagement. Where is there a similar level of engagement by the Manufactured Housing Institute (MHI) on post-production issues? Why do even pro-MHI sources tell MHProNews, for example, that Arlington, VA based MHI at last report had not contacted or engaged the latest city to announce that it wanted to ban manufactured housing?
Watch for a special report planned for the next few days. If you haven’t already made plans to attend the 2019 Tunica Manufactured Housing Show, come but make sure you are there Thursday afternoon, March 28th, for a special event. That’s manufactured home “Industry News, Tips, and Views Pros Can Use,” © where “We Provide, You Decide.” © ## (News, analysis, and commentary.)
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