Lately CrossMod has been the talk of everyone in the modular housing industry BUT the new rules recently submitted to HUD could make that discussion a very small problem.
The Manufactured Housing Consensus Committee has submitted regulations allowing HUD manufactured home factories to begin building two story homes.
Yes, you heard that correctly! Two story HUD homes!
HUD proposes to add a definition in § 3282.2 for “attached accessory building or structure,” a term and definition recommended by the MHCC to address features including, but not limited to, attached garages and attached carports. HUD also proposes to amend § 3280.3 by clarifying the requirement that consumer manuals be in accordance with § 3282.207, in addition to general references to 24 CFR parts 3280 and 3282. Through this proposed rulemaking, HUD would also amend § 3280.11(d) by clarifying the location requirement of the certification label to each transportable section of a manufactured home. Specifically, the label must be installed on a permanent part of the exterior of the manufactured home section in a visible location as specified in the approved design. This provides for locating the certification label on transportable sections of multi-story homes that require that the label be located in an area that would cause it to remain visible after all work is completed in finishing the home at the home site.
Not only are they moving forward with that, they are proposing Stair geometry as part of a preemptive code. They will need this for the second floor.
HUD is proposing a new § 3280.114 to define requirements for stairways, landings, handrails, guards and stairway illumination. Without this provision in the federally preemptive Construction and Safety Standards, the inclusion of such features in a manufactured home are subject to the requirements of state or local jurisdictions having authority over the home site, including state and local inspections. By including these requirements in the Construction and Safety Standards, which are consistent with state and local building codes for other housing products and generally used in the design and construction of multi-story manufactured housing, HUD can ensure uniformity in designs and construction and provide cost savings through one uniform standard. Specifically, § 3280.114(a) would define requirements for stairway width, stairway treads and risers, including riser height and tread depth. This paragraph would also define requirements for stairway headroom, winders, spiral stairways, and circular stairways. Paragraph (b) of § 3280.114 would define requirements for stairway landing dimensions and locations of stairway landings.
I’m not finished yet!
Subpart K contains the right to build on zero lot lines meaning that two story manufactured homes can be used for duplexes and townhouses. New rules for roof assemblies are also included.
The following definitions are from Subpart K, found at the very bottom of the proposal:
Attached manufactured home. Two or more adjacent manufactured homes that are structurally independent from foundation to roof and with open space on at least two sides, but which have the appearance of a physical connection (i.e. zero lot line).
Fire separation wall. A wall of an attached manufactured home which is structurally independent of a wall of another attached manufactured home with a fire separation distance of less than three feet.
§ 3280.1003Attached manufactured home unit separation.(a) Separation requirements. Attached manufactured homes must be separated from each other by a fire separation wall of not less than 1-hour fire-resistive rating with exposure from both sides on each attached manufactured home unit when rated based on tests in accordance with ASTM E119-2005, Standard Test Method for Fire Tests of Building Construction and Materials (incorporated by reference, see § 3280.4). Fire resistance rated fire separation wall assemblies must extend from the foundation to the underside of the roof sheathing.
And to make matters worse for modular housing, there is no need for state approvals, the third parties will do all plan review.
CLICK HERE to read the entire proposed regulations









