A A M A A N A L Y S I S
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.
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
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
§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-
Standard for Utilization in
Manufactured Housing for Primary
Windows and Sliding Glass Door
loss of glass from the frame.
tions of how these items are treated
Performance requirements for by different certiﬁcation bodies.
mulled assemblies, referencing
Coatings performance per AAMA
Will HUD Take Action?
The 2012 editions of the AAMA
Standard Egress Window Systems
for Utilization in Manufactured
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
Housing Consensus Committee
Insulating glass unit requirements (MHCC) to HUD—a statutory Federal
updated to reference ASTM E2190 Advisory Committee charged with
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
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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