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Housing Types and Jurisdictional Authority

Over the years, various terms have been used to describe each type of factory-built structure. In addition, the Colorado Division of Housing, Housing Technology and Standards Section and the local jurisdiction each have specific authority over factory-built structures depending on the type of structure. The various factory-built building types have specific State and local jurisdiction authority as follows:

 

1. Trailer Home

 
 20's Trailer

The term defines homes built prior to the adoption of the American National Standards Institute (ANSI) Standard A-119.1 and was built to a variety of standards and codes. This collection of homes includes trailer coaches as pictured above. These homes have no specific labeling or other identification system. The Colorado Division of Housing, Housing Technology and Standards (HTS) Section has regulatory authority for these homes only through the Manufactured Housing Installation Program (MHIP). In Colorado, the local jurisdiction has complete authority over trailer homes including the acceptance of trailer homes for permanent occupancy and what code compliance is required.

 

2. Mobile Home

 
 Mobile Home Photo

The term mobile home is used widely to discuss a variety of factory-built residential structures. However, the term mobile home describes a specific type of manufactured housing that was built prior to 1976 and constructed to the American National Standards Institute (ANSI) A-119.1 Standard. Homes constructed to this standard may or may not have an identification label. Homes built in Colorado between 1971 and 1976 did receive a State of Colorado Mobile Home Certification Label to confirm code compliance at the time.

The Colorado Division of Housing, Housing Technology and Standards (HTS) Section has regulatory authority for these homes only through the Manufactured Housing Installation Program (MHIP). In Colorado, the local jurisdiction has authority over mobile homes based on the following;

  • The acceptance of unlabeled homes and the applicability of specific building codes to the unlabeled homes,
  • There is no preemption of local codes for this type of manufactured home,
  • Homes with a State of Colorado Mobile Home Certification Label must be accepted by the local jurisdiction. However, the local jurisdiction may require snow and/or wind mitigation measures.

 

3. Manufactured Home

 
 Manufactured Home

The term “manufactured home” is a specific reference to a U.S. Housing and Urban Development (HUD) labeled home. Manufactured homes are constructed to HUD construction standards and are identified through a labeling system (the HUD label). A manufactured home is a structure, transportable in one or more sections, which is eight body feet or more in width or four body feet or more in length, or when erected on site, is more than 320 square feet, is built on a permanent chassis and is designed to be used as a dwelling with or without a permanent foundation when connected to the required utilities.

The Colorado Division of Housing operates several programs concerning manufactured homes including the; Consumer Complaint Program, Manufactured Home In-Plant Inspection Agency Program, and the Manufactured Housing Installation Program (MHIP). Local jurisdictions in Colorado must follow specific regulations concerning their acceptance of manufactured housing units in their community. In addition, the manufacturer of these structures has several responsibilities concerning the quality and safety of the built product.

 

  • HUD Manufactured Home Verification
     

     HUD Label Example

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

There are three labeling methods used to identify HUD manufactured homes. The labeling methods are described in the Manufactured Home Construction and Safety Standards Part 3280. Part 3280.5 describes the Data Plate, Part 3280.6 describes the labeling of the home serial number and Part 3280.11 describes the Certification label and its attachment.



The first indication is a Red Certification Label. This label will have a label number. The first 3 letters designates the Inspection Agency for the unit. For example, COL means the unit was constructed in Colorado and inspected by the State of Colorado. This is similar for other states, for example; NEB for Nebraska, etc. If the unit was inspected by a third party agency then the letters would be for that company such as NTA for NTA Inc., TRA for T.R. Arnold and Associates, etc. The number is a sequential number for each label. This label number is listed on the Data Plate.

 

 Sample HUD data plate

 

The second and most important is the Data Plate.  The Data Plate is usually found near the main electrical panel or in a bedroom closet.  This form lists more information and should be required by the local jurisdiction.  The wind zone, thermal zone and roof load zone will be listed.  For units being set in Colorado the wind zone is I, the thermal zone is 3 and the roof load is Middle 30 PSF.  Units not meeting these requirements should not be set in Colorado. Professional Engineers may prescribe rework to retrofit a unit to the Colorado requirements and this should be reviewed and approved thru the local jurisdiction (case by case basis only) with assistance from the HTS Section as needed.

 

The third is the serial number. The serial number with manufacturer and the state where constructed will be stamped in the foremost cross member of the under floor frame and should be verified with the Data Plate. If the Data Plate/Certification Label is missing the information may be available from Institute for Building Technology and Safety (IBTS).  IBTS can be reached at  703-481-2010.

 

Local Jurisdiction for Manufactured Homes

 In Colorado, the local jurisdiction has limited authority over manufactured homes including the following;

  • HUD labeled homes preempt local jurisdiction building codes with the following two exceptions;
  • Snow load requirements. Local mitigation options include code compliance, snow shed(s), or a snow removal plan,
  •  Wind load requirements. Local mitigation options include code compliance and wind fence(s).
  • Local jurisdictions have authority over all repair, remodeling, and addition work related to HUD labeled homes after residential occupancy,

 A local jurisdiction, through a zoning ordinance, can require permanent foundations for HUD labeled homes installed on private property.

 

HUD Manufacturer Responsibilities for Manufactured Homes

HUD manufactured homes are constructed at factories across the country and are shipped to various states, including Colorado. The U.S. Department of Housing and Urban Development (HUD) has regulatory authority over the HUD manufactured home industry and assists the industry in meeting their responsibilities. The HUD manufactured home industry is responsible for the following; 

  • Full testing and inspection of all home floor sections,
  • Conducting investigations related to the scope of production defects, 
  • Notifying customers, IPIA(s), and HUD of potential life/safety and serious defects,
  • Inspecting all homes that may have a defect and making approved corrections,
  • Warranty repairs provided the home has been properly installed and maintained.

 

 

4. Factory-Built (Modular) Homes

 

 Modular home being installed

 The terms factory-built or modular homes describe a Colorado labeled factory-built residential structure that meets or exceeds the currently adopted codes in Colorado, including the 2009 International Energy Conservation Code (IECC). These homes are identified by a permanent, silver-colored label that is located in the kitchen sink cabinet of the home.

 State of Colorado Plate

 Factory-built or modular housing is custom designed and can be fabricated for both single-family and multi-family use. This type of construction has several benefits including shortened on-site construction time and robust quality control systems. 

 

The Colorado Division of Housing, Housing Technology and Standards (HTS) Section has several responsibilities in relation to the factory-built or modular housing industry as follows;

  • Enforcement of the construction codes as adopted by the Colorado State Housing Board,
  • Certification of in-state and out-of-state manufacturers,
  • Certification of third-party inspection agencies,
  • Approval of construction plans,
  • Completion of in-state factory inspections,
  • Completion of oversight inspections of out-of-state manufacturers.

 

Local Jurisdiction for Factory-Built homes

  •  In Colorado, the local jurisdiction has limited authority over factory-built or modular homes including the following;
  •  Colorado labeled Factory-built homes generally preempt local building code requirements,
  • Factory-built or modular homes must be designed for local snow and wind loads (design loads listed on insignia), and installed on a permanent foundation,
  • The local jurisdiction has authority over construction of the permanent foundation and any other site-built construction except for materials shipped loose by the factory. Site-built stairs should match the factory-built stair design,
  • Local jurisdictions have authority over repair, remodel, and addition work after the home has been occupied for residential use.

 

 Factory-Built or Modular Manufacturer Responsibilities

  •  Factory-built or modular manufacturers have the following responsibilities;
  • Certified manufacturers are responsible for fully inspecting and testing floor sections’
  • Responsible for conducting investigations related to the scope of production defects,
  • Responsible for inspecting all homes that may have a defect and making corrections,
  • Responsible for warranty repairs provided home has been properly installed and maintained.

 

 

5. Panelized (Pre-Fabricated) Homes

 
 Panelized
 

Panelized (pre-fabricated) homes are homes that are assembled on-site with factory assembled and third party approved assemblies. The Colorado Division of Housing, Housing Technology and Standards (HTS) Section has regulatory authority over panelized (pre-fabricated) only when the pre-fabricated assemblies are closed construction containing mechanical, plumbing, and/or electrical systems. In addition, some panelized (pre-fabricated) assemblies are certified and labeled by a third party testing organization such as United Laboratories (UL). The local jurisdiction has complete authority over panelized structures that are not approved by the Colorado Division of Housing.

 

 

 

 

6. Recreational Vehicles and Park Trailers
 

 RV Aqua Home

The Colorado Division of Housing, Housing Technology and Standards (HTS) Section regulated the recreational vehicle and park trailer industry through an inspection and labeling system from 1970 through 1999. Beginning in 2000, recreational vehicles (RV’s) and park trailers are inspected directly by the manufacturer. The local jurisdiction has complete authority over the permanent occupancy of recreational vehicles and park trailers. Jurisdictions and consumers should be aware that there are no minimum structural codes in the American National Standards Institute (ANSI) standard that governs these types of structures and the Colorado Division of Housing does not consider these structures to be appropriate for permanent residency.

 

7. Factory-Built, Non-Residential (Commercial) Structures

 

 FBNR Example

Factory-built, non-residential (commercial) structures can be used to provide almost any type of commercial structure including industrial, retail, and educational uses. This type of construction has several benefits including shortened on-site construction time and robust quality control systems. The terms Factory-built, non-residential (commercial) structures describe a Colorado labeled Factory-built, non-residential (commercial) structure that meets or exceeds the currently adopted codes in Colorado, including the 2009 International Energy Conservation Code (IECC).

 

These structures are identified by a permanent, blue-colored label that is located on the front exterior of each floor section. In addition, a green label (not shown) next to the blue label indicates HTS Section approval of design and/or construction modifications for that unit.


 

 FBNR Single Insignia

The Colorado Division of Housing, Housing Technology and Standards (HTS) Section has several responsibilities in relation to the factory-built, non-residential (commercial) structures industry as follows;

  • Enforcement of the construction codes as adopted by the Colorado State Housing Board,
  • Certification of in-state and out-of-state manufacturers,
  • Certification of third-party inspection agencies,
  • Approval of construction plans,
  • Completion of in-state factory inspections,
  • Completion of oversight inspections of out-of-state manufacturers.

 

Local Jurisdiction for Factory-Built Non-residential structures

In Colorado, the local jurisdiction has limited authority over factory-built, non-residential (commercial) structures including the following;

  • Colorado labeled Factory-built, non-residential (commercial) structures preempt local building code requirements,
  • Factory-built non-residential structures must comply with local snow and wind load requirements (design loads listed on insignia),
  • Installation of factory-built non-residential structures is the authority of the local jurisdiction.
  • Local jurisdictions have authority over repair, remodel, and addition work after the structure has been occupied for commercial use.

 

Factory-Built, Non-Residential (Commercial) Structure Manufacturer Responsibilities

Factory-built, non-residential (commercial) structure manufacturers have the following responsibilities;

  • Certified manufacturers are responsible for fully inspecting and testing floor sections’
  • Responsible for conducting investigations related to the scope of production defects,
  • Responsible for inspecting all homes that may have a defect and making corrections,
  • Responsible for warranty repairs provided home has been properly installed and maintained.
     

 

 

Links To:

Lists of Colorado Dealers, Inspectors, Installers and Manufacturers

List of Resolutions

Factory-Built Structures and Energy Codes Staff