MODEL # 98-23
Return to Technology Task Force Page
CUSTOMER ASSISTANCE IN MANUFACTURED HOMES
STATE OF OREGON
EXECUTIVE SUMMARY
Jurisdiction Statistics:
Regulatory Areas:
PROBLEM:
Industry Regulation - Manufactured Homes
The State of Oregon wanted to develop an agency to regulate the manufactured homes industry that would have enough power to resolve issues on behalf of homeowners, dealers, manufacturers, suppliers, installers, and local jurisdictions.
SOLUTION:
The U.S. Department of Housing and Urban Development approved the Oregon Building Codes Division (BCD) to serve as the State Administrative Agency (SAA), or regulatory body for the manufactured housing industry in Oregon. Under this authority, the Building Codes Division operates the state's Customer Assistance Program.
DESCRIPTION:
The Oregon Customer Assistance Program is extensively involved in the manufactured housing industry. The program itself encompasses five individual programs that operate within this circle. At the hub of the circle is the State Administrative Agency (SAA), which is a federally approved state program responsible for carrying out the state plan of enforcement of the Federal Manufactured Housing Construction and Safety Standards Act of 1974. This Act, in addition to Oregon statutory and administrative rule, gives the Building Codes Division and the customer assistance program its authority to operate.
The five sections within the program have been created to provide a means of ensuring that the provisions of the Act and statutes are being followed. Each section has a different responsibility within the manufactured housing industry. As each program branches out from the central authority, they ultimately join in their goal of providing safe and durable housing. The five sections within the overall program are the Consumer Assistance Program, the Installation Monitoring Program, the Dealer Lot Monitoring Program, the Manufacturers Regulation Oversight Program, and the Manufacturers Standards Oversight Program. These are all directed from one central point but each program has individual coordinators responsible for effective operation.
Consumer Assistance Program. Responds to individual consumer requests for assistance. As problems arise with particular homes, owners, dealers, manufacturers, or other involved parties may request assistance from this section. The assistance may be in the form of providing information, conducting inspections and investigations, requiring repairs, and mediating solutions. This section also deals with inspections of old homes and homes damaged by transportation or acts of nature.
Installation Monitoring Program. Monitors installations as well as the activity of the Oregon State University installation monitoring program. University inspectors monitor installations throughout the state and provide training and technical assistance to installers and jurisdictional inspectors. The BCD's role in this is to provide technical assistance, training, and require repairs and installations as necessary. This section is the main contact point for any installation related issue.
Dealer Lot Monitoring Program. Responsible for assuring that the dealerships within the state comply with state and federal regulations concerning placement, alteration, service work, and record keeping. Equally important is the role the program takes in providing information and a communication link within the industry. This communication and partnership is essential for effective resolution of issues.
Manufacturers' Regulation Oversight Program. This SAA portion of the customer assistance program is primarily responsible for assuring that the manufacturers comply with the record keeping requirements of the federal regulations. The records must reflect how serious a problem is with a particular home and whether that same problem may also affect other homes. Inspections are done quarterly at each manufacturing facility, and more often if situations arise which merit closer investigation. There is also interaction with SAAs of other states and HUD to ensure that homes being transported into or out of different states are also equally regulated.
Manufacturers' Standards Oversight Program. Focuses on in-plant operations. Staff members routinely audit processes within the factories to assure compliance. The audits focus on either specific details or general operation procedures. Specific focus is from information gathered from a variety of sources that indicates a possible failure to comply or failure in a selected part. The general overview is intended to ensure that the factory is operating within their own manuals and assembling the homes to comply with their approved design. The BCD in-plant inspection process is also audited.
In the course of operations, as each section becomes involved in a situation, there is usually a link which involves another section. As the investigation or corrective process is put into place, other sections also become involved. With the involvement of the sections, identification of the problem, cause, correction, follow-up and prevention are all linked under one program.
Hometrac Database. The Customer Assistance Program utilizes the Hometrac Database, a computer system designed to catalogue information concerning customer problems with manufactured homes in a single, easily accessible location. When the information is received by the program's staff, it is entered into the Hometrac system. The system tracks by manufacturer, dealer, and serial number. The information can come from any source, proven or not, and primarily comes from consumer complaints, manufacturer and dealer records, and actual field investigations. The problem ID numbers are a selection from the Housing and Building Technology CCTS program as well as some assigned numbers for the Oregon installation standard.
Once placed into the database, the data can be retrieved in a format that indicates the number of homes entered, the number of times a specific category was entered, the percent of occurrence is within an expected rate.
It is very important to note that the data entered is only from homes with reported problems. In addition, the data is also information that has not necessarily been proven. It may reflect repairs that are a result of some other failure that caused the reported problem. An example would be decking that was entered because it was replaced, but the replacement was caused by a plumbing leak. Although this method of recording represents a more harsh view of the house, it reflects the extent of damage caused as well as the degree of repairs being completed in the field.
The reason for entering homes only with recorded repairs in addition to recording everything is twofold. First, it alerts the SAA to look more closely into categories which show an unacceptable percent of involvement. Once a category is deemed excessive, an in-depth investigation can be initiated. By entering only involved homes and using the most revealing information, the SAA can be confident that the data reflects as much as possible. Second, since the database comes from several different sources, it is important to maintain consistency. The information entered comes from sources which involve only homes with problems as well as random searches which may include files with no repair data on file. Since every home built is not logged, the true reflection would not be evenly measurable.
RESULTS:
The Consumer Assistance Program has shown a steady increase in activity since 1990. This increase grew significantly during 1995, and continued in 1996 despite a small drop in production and imports. This growth is in part due to record production numbers of 1995 and the overall growth since 1993. In addition to the volume, the main increase in activity is a result of the efforts of the division to become an integral part of the industry. Included in the program submission are two reports outlining the activity in each field that the program serves.
The dealer lot monitoring program has made significant progress in gaining the support and confidence of the dealer network. Referrals from dealers have increased as well as dealerships requesting assistance. The installation monitoring program has also increased the division's exposure. Building officials and installers alike are contacting the division requesting interpretations, training, and field inspections.
Consumer assistance cases have shown a very significant increase. All of this can be related to the division's visibility. Owners are asking for help much sooner than in the past. The types of complaints remains about the same. Most of the problems reported are of cosmetic nature. The code violations reported generally are equally divided in responsibility among the installer, manufacturer, and dealer. Another trend seems to be more cases involving older homes.
EVALUATION BY STREAMLINING COMMITTEES:
Advantages
Limitations
The Streamlining Committees designated this program as a streamlined model without modifications. The Committees did comment that industry support is crucial to the success of the program. If fees are increased to cover the costs of operation, industry must value the merits of the program or they will not stand for the fee increase.
IMPLEMENTATION:
The Oregon Building Codes Agency was designated by HUD as State Administrative Agency to comply with the state plan of enforcement of the Federal Manufactured Housing Construction and Safety Standards Act of 1974. This Act, in addition to Oregon statutory and administrative rule, gives the Building Codes Division and the consumer assistance program its authority to operate. Manufacturers, dealers, installers, building officials, and the housing association contributed ideas to the BCD in developing this program.
FOR MORE INFORMATION OR ASSISTANCE IN CONSIDERING THE USE OF THIS MODEL, PLEASE CONTACT:
Tom Nicolai
Building Codes Division
P.O. Box 14470
Salem, OR 97309
Phone: (503) 373-7243
FAX: (503) 378-1358
Or NCSBCS STAFF:
Carolyn Fitch
National Conference of States on Building Codes and Standards
505 Huntmar Park Drive, Suite 210
Herndon, VA 20170
Phone: (703) 437-0100
FAX: (703) 481-3596
Email: cfitch@ncsbcs.org