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Federal Register / Vol. 86, No. 7 / Tuesday, January 12, 2021 / Rules and Regulations
HUD change % to 38 inch in 3280.114a2i, and change % to 34 inch in 3280.114a2ii. This commenter also suggested changing Y2 to 12 inch in paragraph a5.
According to another commenter, the maximum riser height and minimum tread depth should be changed to 814
inches and 9 inches in 3280.114
a2i. HUDs proposed requirements would almost eliminate stairway designs that run parallel with the width of a traditional manufactured home.
This commenters rationale for the recommended change included giving manufacturers more flexibility when trying to balance the smaller form-factor of most homes with consumer demand for multiple stories.
HUD Response: Regarding riser height and tread depth, HUD reviewed several state building codes referenced in public comments and has made changes to riser height and tread depth consistent with those requirements found in many state building codes and in accordance with the comments received.
Comments: Interior and Exterior Stairs.
Several commenters stated that HUD
should clarify whether the requirements apply to stairs inside, or inside and outside, the home or commented on whether the requirements should apply to these different sets of stairs. One commenter stated that requirements for stairways and related design features should focus only on stairways placed inside the manufactured home, and the section title should be changed to Stairways Inside the Manufactured Home. Another commenter stated that the proposed changes to paragraph a2
addresses interior stairways and exterior stairways; the commenter suggested revising the proposal to address interior steps only. According to the commenter, states and local municipalities establish stair geometry to which first responders are already accustomed, and to require smaller riser heights and larger treads may create a hazard.
Another commenter supported the addition of language to define requirements for stairways, landings, handrails, guards, and stairway illumination, however, the commenter suggested the language should detail if it covers interior stairways, exterior stairways, or both.
WI and WY. The commenter also referenced a change to the Indiana Code; see Indiana Department of Homeland Security, Proposal for Code Change 43, IN.gov May 9, 2018 proposals 49 and 50, https www.in.gov/dhs/files/IRCC%27s%20
Final%20Approved%20Amendments%20
to%202018%20IRC%20Part%201%20%20Accepted%20by%20FPBSC%202-5-19.pdf.

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Another commenter suggested striking paragraph b2 in its entirety because it partially conflicts with paragraph b1, or, if HUD disagreed with striking b2, revising b2 as follows to streamline and clarify requirements: A landing or floor must be located on each side of an exterior doorway and the width of each landing must not be less than the door it serves.
The maximum threshold height above the floor or landing must be 112
inches. Given that paragraph b1
addresses interior stairways, doors, and landings with exception for certain basement applications, the commenter assumed that paragraph b2 must be intended for exterior applications, which is the basis for the suggested edits.
Two commenters suggested HUD
delete paragraph e2 entirely, since exterior stairs are not constructed within the building facility and more appropriately fit under the HUD Codes Model Manufactured Home Installation Standards. A commenter explained that exterior stairs would be subject to state and local building code and healthsafety requirements. If HUDs exterior illumination requirements conflict with state or local requirements, it would only cause confusion within the industry and may put consumers at risk.
Comment: Guard Rails.
Some commenters also suggested, for 3280.114d1, that the proposed load requirements only apply to guards more than 42 above the floor grade below, to prevent driving up housing costs without providing significant increased safety protection. When a manufactured home includes a porch or similar feature, once installed, it is usually between 30 and 42 inches above the lower floor, and there is no evidence of increased injury from a fall as a result of a guard failure that is 42 or fewer inches from grade. The commenters provided regulatory text edits, and stated that a 30-inch guard rail structural requirement would increase the cost of each single-section home with a modest porch by $500, or more for larger homes, which undermines HUDs efforts to preserve manufactured housing affordability.
The commenters further stated HUD
should remove the language regarding the horizontal rail restriction in paragraph d2, which HUD has not backed with a significant health-safety concern as justification and which would restrict designs and add unnecessary cost. This restriction is not found in the International Residential Code IRC, which only prohibits the passage of a four-inch sphere and would result in a restriction for manufactured
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home builders that does not exist for site-built home builders. One commenter stated that IRC Table R301.1.5 does not require the 200 pound concentrated load to be applied with any other loads and, therefore, the word not should be added after this load in the last sentence of paragraph d2ii. Another commenter agreed and added that this makes d2ii consistent with the last sentence in paragraph c5.
Comment: Lighting.
For 3280.114e1, one commenter stated that HUD should delete the requirement for artificial light to be not less than one-foot-candle at the center of treads and landing and require only a light above stairways and landings because the commenter was not aware of a test method. Another commenter suggested a prescriptive method to simplify compliance with interior stair lighting. Lumens required for a 3 feet wide x 9 feet vertical stair would be 3
feet x 11.67 feet x 1 foot-candle = 35
Lumens. One 60-watt incandescent bulb or 10-Watt A19 LED provides about 840
lumens which is more than adequate.
Another commenter recommended HUD add a prescriptive lighting standard as an alternative compliance option. The proposed illumination requirement of not less than one 1
foot-candle measured at the center of treads and landings creates a new test requirement, but it is unclear who is responsible for performing the test and assessing compliance. Without an explanation of the test parameters and how the test would be administered, the commenter was concerned this provision would be inconsistently enforced. As an alternative, the commenter recommended that HUD
introduce a minimum standard for illumination.
HUD Response: Generally, HUD
agreed with most comments and made changes to the standards for stairways including revisions to riser height and tread depth 3280.114a2, clarification of interior and exterior consideration 3280.114a and 3280.114b, provisions for landings 3280.114b, and handrails 3280.114c.
HUD also modified the standard in multiple places so that the text reflects HUDs regulatory authority for design and construction of the home and its lack of authority to regulate stairways that are designed by others and built at the homes site necessary for access and egress from the entry and exit points of the homes. HUD also disagreed with some commenters, as the requirements in 3280.112 only apply to stairways integral to the manufactured home, such
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