A A M A A N A L Y S I S  
rrinka@aamanet.org  
HUD Regulates Manufactured Housing  
But Will Agency Adopt AAMA’s Updated Standards?  
B Y R I C H A R D R I N K A  
or decades, regulations govern- and by extension 3280.305c). Air leak- housing fenestration began in 1983).  
ing the construction of manu- age, at a maximum of 0.5 cfm per Content also needed to be added to  
factured housing units have square foot, is required for windows qualify for ANSI accreditation of the  
been communicated by the U.S. and 1.0 cfm per square foot for swing- certification program, which provides  
Department of Housing and Urban ing doors, as tested per ASTM E283 at HUD-recognized third-party evidence  
Development (HUD) in the form of its a 1.57 psf pressure differential. Water of conformance with CFR 3280.  
F
Manufactured Housing Construction penetration for windows, when tested  
It is important to remember that  
and Safety Standards, 24 CFR 3280. at a 2.86 psf test pressure per ASTM testing for product certification is  
These include the following standards E547, must not be evident beyond the required to be done per the older ver-  
directly related to doors and windows: innermost surface. Water penetration sions of the standards (AAMA 1701.2-  
§3280.403, Standard for Windows for doors is tested at zero differen- 95; 1702.2-95; and 1704-85), which  
and Sliding Glass Doors Used in tial pressure, when water is applied HUD §3280 continues to reference  
Manufactured Homes;  
per ASTM E331. AAMA 1704-95 adds even though updated versions exist.  
§3280.404, Standard for Egress dimensional and operating force Many of the third-party standards and  
Windows and Devices for Use in requirements for windows intended test methods referenced within these  
Manufactured Homes;  
§3280.405, Standard for Swinging  
to serve as emergency egress devices. older editions have also been retired  
There have been updates to all of or have newer editions. Following  
Exterior Passage Doors for Use in these documents, without changes obsolete test methods could also pose  
Manufactured Homes. to the basic requirements, which are problems for laboratories in main-  
Criteria and test methods for com- reflected in the 2017 editions. Added taining their ISO/IEC 17025 accredi-  
pliance with these regulations are in the just-released 2017 editions are: tation. Ignoring the newer provisions  
addressed, respectively, by:  
A safety drop test in which the related to mulled units, drop testing,  
glazed sash is allowed to “free fall” extrusion coatings and dual windows  
without suffering broken glass or can create inconsistent interpreta-  
AAMA  
1701.2-95,  
Voluntary  
Standard for Utilization in  
Manufactured Housing for Primary  
Windows and Sliding Glass Door  
Units;  
loss of glass from the frame.  
tions of how these items are treated  
Performance requirements for by different certification bodies.  
mulled assemblies, referencing  
AAMA  
1704-95,  
Voluntary  
AAMA 450.  
Coatings performance per AAMA  
Will HUD Take Action?  
The 2012 editions of the AAMA  
Standard Egress Window Systems  
for Utilization in Manufactured  
Housing; and  
AAMA  
Standard for Utilization in  
Manufactured Housing for  
Swinging Exterior Passage Doors.  
2603, 2604 and 2605 for aluminum standards have been recommended  
extrusions or AAMA 613, 614 or 615 for adoption by the Manufactured  
1702.2-85,  
Voluntary  
for PVC.  
Housing Consensus Committee  
Insulating glass unit requirements (MHCC) to HUD—a statutory Federal  
updated to reference ASTM E2190 Advisory Committee charged with  
and E2189.  
Dual windows are also now HUD secretary on the revision and  
covered. interpretation of HUD’s manufactured  
There have been nuances of home construction and safety stan-  
providing recommendations to the  
What’s in the Standards?  
AAMA 1701.1-95 and 1702.2-95 call  
for basic air/water/structural (AWS) the program that evolved as it was dards. Final adoption is still pending,  
performance in a similar manner that being administered, and subjective however, and there is no indication  
NAFS specifies AWS criteria for sire- decision-making that needed to be that HUD will adopt the 2012 (or 2017)  
built structures, specifying structural codified, especially in the context of versions any time soon, if at all.  
testing to 25 psf wind loading (or at changing product certification rules  
y
optional higher pressures for coastal as codified in ISO/IEC 17065-2012 RichardRinkais the certification manager for  
high wind areas, identified as Zones (vs. ANSI Z34.1, which was in effect the American Architectural Manufacturers  
II and III under HUD CFR §3280.403b when certification for manufactured Association in Schaumburg, Ill.  
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