MBSA Reacts to Masachusettes Fire Chief’s Rants

Earlier this week I published another rant by the publicity seeking volunteer fire chief in Mass. against the entire modular home industry. Click here to read the article.

Today I received this email from Tom Hardiman, Executive Director of the Modular Building Systems Association telling me that he has written a letter to the Fire Engineering magazine which recently published the fire chief’s rant.  This is why is it super important to join together and stand enlighten those that don’t understand modular home construction.

Here is his email to me AND his yet to be published (if it ever will be) letter to the editor of Fire Engineering:

Gary (Modcoach),

Attached is my letter to the editor of Fire Engineering
Magazine in response and rebuttal of Kevin Gallagher’s recent anti-industry
story.  The editor said he would consider publishing my reply but I don’t
know if that will happen or not.  In any case, I wanted your readers to
know that the modular home association – Modular Building Systems
Association  – did in fact respond to this attack.

Thank you,

Tom Hardiman, CAE
Modular
Building Systems
Association

and here is his letter to the editor:

Bobby Dalton, Editor in Chief

Fire Engineering Magazine

Dear Mr. Dalton,

I am writing on behalf of the modular construction industry
to reply to the article written by Kevin Gallagher in your September 18, 2013
issue.  There are a number of issues I
would like to address, as Mr. Gallagher’s attacks on the modular industry go back
several years. 

In his article “Modular Concerns: Do We Have a Problem?” Mr.
Gallagher states at one point, “I do not know the answers to these questions,”
referring to his posed question of “Do we have a national fire problem with
modular homes?”  Later in his article, he
asks the question again, “Do we have a problem?”  This time his answer is an emphatic
“YES”! 

I am not an engineer, a fire fighter or a builder.  But I have a very simple question: What
evidence is there to show this problem really exists anywhere outside of Mr.
Gallagher’s mind?  He has made quite a
reputation for himself and found a topic that has generated a lot of interest.
Unfortunately for your readers and the attendees at his presentations, he
presents a totally unsubstantiated and biased opinion based on no real
evidence. He even states as much in the article when he says, “despite the
considerable effort of the (NFPA) library’s staff, we could not find any
literature on the topic of modular construction in general or fires in modular
structures in general.”   I would contend
the reason that no data exists on this specific “problem” is that the problem
doesn’t exist to the extent Mr. Gallagher leads you to believe.

Modular homes, unlike HUD Code manufactured housing, are
built to the same building codes as their traditional stick built
counterparts.  In most states, modular
homes are built to the International Residential Code or a state version
thereof.  There is no “modular home
code”  as modular construction is simply
a construction process, not a product. 
This process allows for a safer construction environment, a higher
degree of quality control, less material waste in our landfills and, yes, a
safer, more durable home than a site built structure.  And while there is research to show the
difference in risk levels between a stick built home and a “manufactured home”
(a.k.a. mobile home), that research  is
not relevant to code-built modular homes.

Mr. Gallagher cites differences in the modular construction
process that, according to him, lends these homes to a greater risk for fire
damage.  He references the interstitial
or void spaces in modular homes.  He
attempted to get this requirement changed in the 2009 IRC code development
cycle and again in the NFPA 5000. In both cases, Mr. Gallagher’s proposals were
rejected, with the NFPA citing “concerns with the reports presented in the
substantiation.”  

http://www.mass.gov/eopss/docs/dps/inf/public-comment/public-comment-draftstopping-con-mbsa.pdf

He was not able to convince his code development peers that
a problem exists, mainly because it does not. 
Despite his setbacks with NFPA and IRC, Mr. Gallagher insisted that the
modular industry conduct extensive and expensive tests to “prove our
innocence,” while continuing his personal campaign against the industry.  

His next target was the use of foam only ceiling assemblies.
In 2010, the modular industry hired an independent consultant to examine the
relative strengths of two different ceiling assemblies in a fire emergency:
ceiling panels installed with (a) foam adhesives only, and (b) a combination of
foam adhesives and mechanical fasteners.  This process yielded inconclusive
results and was stopped prior to the finalization of any written report, mainly
due to the downturn in the housing market. 
Acting conservatively, the industry did not challenge the new code
proposal in Massachusetts
pushed through by Mr. Gallagher, and now utilizes both foam adhesives and
mechanical fasteners for ceiling assemblies in all modular homes sold in the
state.  

 Mr. Gallagher has
been recognized and celebrated for his efforts and invited to speak at national
conferences on this issue.   However,
there simply is no substance behind his claims, and his entire argument is
based on what he says in the opening sentence of this article; “While standing
in front of a burning two-story residence in 2008…” Where is his evidence aside
from his “observations”?

Modular construction is not a new process as Mr. Gallagher
would have your readers believe.  In
1969, a 21-story hotel was built on the Riverwalk in San Antonio utilizing modular
construction.  That hotel is still safely
operating today.  Over the past five
years, the modular industry has constructed and installed more than five
million square feet of permanent housing and building space for the U.S.
Government, mainly within the Department of Defense.  The happiest place on Earth utilized modular
construction in 1971 when building two of their most popular resorts in Orlando.  How likely is it that a multi-billion dollar
corporation would risk its reputation and livelihood by housing families in
unsafe structures?  Neither would we as
an industry pose such risks to our customers.

Our industry is proud of the modular homes we build and will
continue to provide safe, code-compliant homes at competitive prices. Mr.
Gallagher has every right to share his opinions on the issue, but your readers
should know they are just his opinions and not based on any real evidence.  Further, they should seek information from a
variety of sources on the issue before reaching any conclusions. 

The Modular Building Systems Association is a non-profit
trade organization serving the modular home industry nationwide.  The Resources section of our website, www.modularhousing.com, is one such
place for information.  I thank you for
the opportunity to reply to Mr. Gallagher’s article and invite your readers to
contact our organization with any further questions about modular construction.

Sincerely,

Tom Hardiman, Executive Director

Modular
Building Systems Association