Attached for your review and information is a copy of the National Fire Protection Association’s (NFPA) latest (July 2011) report on fire in manufactured homes, as well as a copy of self-explanatory August 3, 2011 letter sent by MHARR to NFPA president James Shannon, disputing the substance of this biased report, as well as the conflict of interest that is inherent in NFPA’s role as the Administering Organization (AO) of the Manufactured Housing Consensus Committee (MHCC), while it simultaneously acts as a chief proponent of residential sprinkler mandates.
The NFPA report, which selectively and arbitrarily manipulates generally positive statistics to present manufactured home fire safety in the worst possible light – contrary to the findings of a credible 1985 report by Foremost Insurance Company — was distributed to MHCC members on July 27, 2011, as the consensus committee prepares for further debate on the pending (but currently tabled) HUD-MHI proposals for a “where required/ as needed” federal fire sprinkler standard.
While the NFPA report, in fact, confirms the 1985 findings, that manufactured homes have a lower rate of fire and a lower rate of civilian fire injuries than other types of one or two-family homes, the report minimizes these and other statistics demonstrating the positive and beneficial impact of the current HUD fire safety standards, in order to present an overwhelmingly negative assessment of the fire safety of manufactured homes – all leading to the predictable conclusion that there is a “strong” case for fire sprinklers in manufactured homes.
Aside from reliance on flawed, incomplete and potentially misleading data, which the report itself acknowledges, both the substance of the NFPA report and its timing – given the nearly universal rejection of residential sprinkler mandates by state legislatures throughout the
nation – have rightfully renewed within the industry longstanding but never addressed questions as to why a special interest organization like NFPA, that is the publisher and proponent of codes that compete with the HUD standards, should be permitted to serve as the MHCC AO.
In addition, this transparent effort to promote fire sprinklers validates MHARR’s consistent position regarding this entire issue – that HUD should either preempt state and local fire sprinkler requirements that impact HUD Code manufactured homes based on the enhanced federal preemption of the Manufactured Housing Improvement Act of 2000, or stay out of the matter altogether. Even a limited “where required/as needed” federal sprinkler standard would ultimately expose the industry to the expansion of any such “limited” standard by HUD to a very costly across-the-board mandate under pressure from sprinkler advocates – a risk that the industry cannot afford, particularly under current circumstances.
As MHARR has maintained all along, the manufactured housing industry has always been a target for sprinkler proponents because they recognize that by requiring sprinklers nationally in HUD Code homes with one stroke of the pen, via a federal standard, they can then use that mandate for an entire class of homes as a precedent in their battles with state and local governments to adopt requirements for sprinklers in other types of housing. While NFPA, as a private organization, cannot be stopped from publishing such reports, those reports must be accurate and factually-based. With this report, moreover, the conflict of interest that is inherent in NFPA’s role as a sprinkler advocate while serving as MHCC AO, has once again been highlighted and needs to be carefully and thoroughly examined and considered by HUD.
By copy of this package and due to the importance of this issue, MHARR is advising other HUD Code industry members of this matter for their information and consideration.
cc: Other Interested HUD Code Manufacturers, retailers, communities and state associations
Manufactured Housing Association for Regulatory Reform
1331 Pennsylvania Ave N.W., Suite 508
Washington, D.C. 20004
Download the documents by clicking on below.