On May 17, 2006, staff of the Department of Housing and Community Development held a “kickoff” meeting for the 2006 regulatory process with interested individuals and representatives of various organizations.  The purpose of this meeting was to explain and start the process that the Department and the Board of Housing and Community Development will be going through to review and up-date the building and fire regulations promulgated by the Board.  We anticipate the process will take 18 months or more, with the amended state regulations probably becoming effective in early 2008.  Some of you might be asking, “What does that have to do with me as a manufacturer, as a retailer, or as a contractor installing modular or manufactured homes?”  The short answer is, A LOT!

During this regulatory process the Board will be reviewing and likely amending most of its codes and regulations including the Uniform Statewide Building Code and the Industrialized Building Safety Regulations.  The Board will be comparing the 2003 editions of the International Codes that are currently referenced with the 2006 editions of the International Codes and will likely amend its regulations to reference the newer codes.  The International codes provide the technical requirements for the construction of buildings, including the plumbing, electrical and mechanical systems in the buildings.  Any person or company building modular homes will be subject to the new or amended requirements when the new Industrialized Building Safety Regulations become effective.  The new or amended requirements will have an effect on the work done on site for the installation of modular and manufactured homes by the contractors or retailers contracting for the installation of homes.

The administrative provisions in the Board’s regulations may be reviewed and amended during this process as well.  Administrative procedures may include issues such as the inspections that will be required for various types of work, what types of work are covered and not covered under the codes, who can make inspections, how the appeals procedures are initiated and carried out, and numerous other non-technical provisions in the regulations.  One issue of interest to the modular industry is a proposal to establish a recertification procedure in the Industrialized Building Safety Regulations.  This procedure will provide a mechanism for certifying and placing a Virginia Seal on modular buildings without Virginia Seals or with seals from other programs.

Why am I alerting you to the start of this process now when it’s not going to have a direct effect on you until sometime in 2008?  Because you have the opportunity to take part in the process by submitting recommended changes to the current or proposed codes and regulations or by reviewing and commenting on recommended changes submitted by others that may impact what you build and how you install the houses you build and sell.  You or a representative of VAMMHA can participate in any of the ad hoc groups looking at one of the Department’s regulations or certain issues within one of the regulations.  There will be at least two public comment periods – one for the submission of proposed changes and the second for public comments on the proposals received during the first comment period.  If you are involved with the regulatory process while the codes are being reviewed and amended, you’ll have a better understanding of why or what’s behind a change that you have to make in the design of your building or some of the materials and methods that are or were being used in the construction and the installation of your houses.

One of my first supervisors used to have a saying.  “If you don’t have time to do it right to start with, how are you going to find the time to correct it?”  I could paraphrase his comment and apply it to the regulatory process.  If you don’t have or take some time to keep up with the changes to the codes, how are you going to find the time to go back to your houses to change things that are no longer permitted by the new code or to add something that the new code now requires?

If you have any questions about getting involved in the regulatory process, you can call our office at (804) 371-7160 or contact me at Curtis.McIver@dhcd,virginia.gov by e-mail.