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Federal Register / Vol. 86, No. 7 / Tuesday, January 12, 2021 / Rules and Regulations
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as those necessary for multi-story or multi-level manufactured home floors or for stairs that are not inside the home but may be necessary for multi-level manufacturer designed and constructed porches designed and built in the home building factory as an integral feature of the manufactured home. Further, requirements for external or exterior stairs that provide entry and exit and are built at the home site are subject to state and or local authority and any such reference otherwise has been removed.
HUD modified the standards related to landings removing duplicative language, clarifying interior versus exterior provisions, and threshold height.
HUD also modified the standard regarding handrails to be consistent with requirements for handrails removal of ladder effect restriction identified in other building codes for other residential structures. However, HUD disagreed with comments that would have changed the load requirements for guard systems to apply only to guards above 42 inches above floor grade.
The changes effected by this rule are generally consistent with other residential codes enforced nationwide.
However, the load requirement of 20
pounds per square foot is significantly less than the load required by many states for similar guard systems.
After consideration of the public comments, HUD has not changed the stairway and landing illumination requirements from the proposed rule as commented by multiple commenters.
The requirements, as published, are consistent with state and local standards and compliance remains, as with all other standards, the responsibility of the home manufacturer. In section I. of the preamble to this rule, HUD clarified that all standards in this rule are not retroactive and apply only to newly constructed homes that enter the first phase or stage of production on and after the effective date of the rule.
Further changes, such as those proposed by some commenters, should be proposed for review by the MHCC so that consensus review of those proposed changes is made as envisioned by the Act. It is not appropriate for HUD to integrate these changes at the final rule stage.
Subpart C, Fire Safety 3280.209 Smoke Alarm Requirements One commenter recommended HUD
revise 3280.209, a section not addressed in the proposed rule. The commenter stated that HUD should add
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combination smoke and carbon monoxide alarms as acceptable devices just as they are in IRC sections R314.1.1
and R314.5.
HUD Response: HUD agreed with the commenter and made the corresponding change.
3280.211 Carbon Monoxide Detectors Some commenters supported incorporating carbon monoxide requirements into the Standards to protect consumer health and safety. One commenter noted that the MHCC made this recommendation in 2009 and HUD
should have adopted it some time ago.
One commenter suggested HUD
should revise 3280.211 to include specific location requirements like smoke alarms, instead of referencing the National Fire Protection Association NFPA Standard 720.
Some commenters stated that the proposed rules coverage of CO alarm requirements would be insufficient under the new 3280.211 in protecting occupants of manufactured housing because of its limited coverage. All manufactured housing should have CO
alarms and not just those with fuel-fired appliances, designed for installing attached garages, or designed for installation over basements. While the new 3280.211 would be consistent with occupancy-related installation requirements of IRC Section R315, these requirements provide no direct protection for occupants of manufactured homes except where coincident housing-related factors of installed fuel-fired appliances, designs for installing attached garages, or designs for installation over basements were relevant. Furthermore, the proposed 3280.211 requirements would not protect occupants where other sources such as use of portable heating appliances or from misuse of charcoal grills indoors both reflected in CO incident data following completion of manufactured housing installation and commissioning. Occupants of allelectric homes may be particularly vulnerable during periods of electrical outage. The comment provided instances of harm caused by carbon monoxide.
One commenter commended HUD for recognizing the importance of requiring carbon monoxide detectors consistent with the IRCs requirements. Through incorporation into the Construction and Safety Standards, HUD relieves local officials from conducting additional inspections and potential re-work post installation to comply with local requirements.
Another commenter stated that HUDs proposed carbon monoxide
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requirements should align more closely with similar requirements in other building codes, such as the IRCs.
Specifically, the commenters suggestions include: Specifying the required locations where carbon monoxide alarms must be installed for example, alarms should be required outside each separate sleeping area or in the immediate vicinity of any bedrooms; requiring interconnectivity between alarms, because when more than one alarm is installed in a home, the actuation of one alarm should activate all alarms; specifying how each alarm must be powered, because the homes electrical system should be the primary power source, with batteries as a secondary, reserve power source; and clarifying that the Standards would allow combination carbon monoxide and smoke alarms to keep pace with consumer demand. Another commenter 0023 also supported this change.
According to the commenter, HUD
should clarify that combination alarms are acceptable to ensure the industry continues to keep pace with consumer demand. The commenter also suggested amending 3280.209 to ensure the sections cross-reference each other.
Comment: Alarms versus Detectors.
Some commenters stated that the word detector should not be used and suggested using alarms to be consistent with other codes and striking the word detector wherever it occurs, because alarms and detectors are distinct concepts. Alarms are selfcontained, single, or multi-station sensing devices that detect a given event and sound an audible or visual alarm.
Detectors are sensing devices that must be connected to a separate alarm system, rather than self-contained systems. One commenter stated that standards do not include requirements for transmitting detection devices to an alarm control unit as would be necessary with detector devices. The commenter recommended removing the standard versions in specific code sections which are incorporated by reference in 3280.4, which will allow for simplified future updates and is a common practice for incorporating building code standards into regulations and laws. The commenter recommended removing the reference to ANSI/UL 2034, which may not be readily available and incorporate location requirements within this section.
HUD Response: HUD agreed with many comments and has modified the Construction and Safety Standards to address combination alarms, integration of specific location requirements, and removal of references to detector.

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