MHProNews has received press releases and statements/reports from and about the National Fire Protection Agency (NFPA) on the topic of fire safety in HUD Code manufactured housing. The differing press releases from MHI and MHARR are closely tied with the subject of fire sprinklers, preemption and the very nature of the Manufactured Housing Consensus Committee (MHCC). The NFPA has issued a correction on their report from last summer, including a statement that their report concludes that the rate of fire injury and the incidents of fires for manufactured home occupants is lower than for occupants of other single family homes.
“This report concludes what the industry and our customers have known all along. Manufactured homes are built with consumer safety considerations first and foremost, and manufactured homes are built to high quality, stringent standards to keep customers safe,” said Manufactured Housing Institute (MHI) President Thayer Long. MHI’s position also stated, “MHCC members also heard from industry representatives, including a third party inspection agency and several state regulators, that the current fire safety standards for manufactured homes are more stringent than for site built homes constructed to the International Residential Code (IRC). Flame spread, egress, and smoke detector requirements are three examples.” Click here to read the entire MHI press release.
The Manufactured Housing Association for Regulatory Reform (MHARR) resent a previous release, that took the NFPA to task for misstating the facts in their summer reports, and essentially called upon the NFPA to correct the errors in their report, which the the NFPA has now addressed.
MHI’s statement began with this sentence, “Last week, the National Fire Protection Association (NFPA) testified before a federal advisory committee that occupants of manufactured homes are no more likely to die from a fire in their home than occupants of other single family homes. ” This phrasing “federal advisory committee” (emphasis added in the above) has caused concerns in the past, as some MHCC members read the Manufactured Housing Improvement Act of 2000 (MHIA of 2000) not to have created a typical “federal advisory committee” at all. An informed source stated, “The 2000 law does say that the MHCC is an “advisory committee,” but then goes on to provide specific powers, authority and procedures for the MHCC that go far beyond those of run-of-the-mill federal advisory committees; powers that are extraordinary. HUD has sought to downgrade and ignore the unique role and powers of the MHCC by claiming that the MHCC is a run-of-the-mill advisory committee and by trying to shoehorn it into strict compliance with the Federal Advisory Committees Act, which generally governs the existence and procedures of federal advisory committees, but states that its provisions are super-ceded by more specific federal law – in this case the specific authority of the MHCC under the 2000 law. So, what we don’t want to conceded (is) that the MHCC is a typical or run-of- the-mill federal advisory committee. It is an advisory committee with a unique role and extensive, specific authority delegated directly by Congress.” Those powers are designed to make the MHCC a check on HUD’s regulatory authority, to keep the agency from imposing unrealistic, unduly burdensome or overly costly regulations on HUD Code manufactured home builders.
Downloads from the various parties are available at the links below. An Industry Voices Guest Blog post by long time MHCC member Doug Gorman on a related topic can be found at this link.
Manufactured Home Fires
MHARR letter to NFPA on its firestudy 8-3-2011
National Fire Protection Association July 2011
(Graphic credit: MHProNews)