“Baseless Discrimination Against HUD Code Manufactured Homes”

BaselessDiscrminationAgainstHUDCodeManufacturedHomesMHARRDailyBusinessNewsMHProNews

In a release to the Daily Business News on MHProNews, the Manufactured Housing Association for Regulatory Reform (MHARR), is pressing the Department of Housing and Urban Development (HUD) to repeal the use of their “Formaldehyde Health Notice.”

MHARR’s statement says in part that they opposed the “baseless discrimination against HUD Code manufactured homes with respect to formaldehyde emissions and related mandates…” because “…there is no legitimate basis whatsoever, for exempting site-built homes, but not manufactured homes from the definition of a “finished good…”

Their full release is as shown below.

MHARRNEWSheaderDailyBusinessNewsMHProNews

MHARR SUPPORTS PROPOSED REPEAL OF HUD “FORMALDEHYDE HEALTH NOTICE”

 

APRIL 16, 2019

 

 

TO:                 MHARR MANUFACTURERS

                        MHARR STATE AFFILIATES

                        MHARR TECHNICAL REVIEW GROUP (TRG)

 

FROM:           MHARR

 

RE:                 MHARR SUPPORTS PROPOSED REPEAL OF 

HUD “FORMALDEHYDE HEALTH NOTICE”

The Manufactured Housing Association for Regulatory Reform (MHARR), in comments filed with the U.S. Department of Housing and Urban Development on April 16, 2019 (copy attached), has voiced its support for the proposed repeal of the red “Formaldehyde Health Notice” required to be “prominently displayed” in every HUD-regulated manufactured home (but not other types of homes) since 1984, pursuant to 24 C.F.R. 3280.309.  The repeal of the “Health Notice on Formaldehyde Emissions” mandate is part of a broader HUD-proposed rule, which – as required by the Formaldehyde Standards for Composite Wood Products Act of 2010 – would conform HUD manufactured housing standards concerning formaldehyde standards, testing and labelling with standards adopted generally by the U.S. Environmental Protection Agency (EPA) for composite wood products in accordance with that law.

 

While MHARR has long advocated the repeal of the HUD formaldehyde notice as a discriminatory imposition on manufactured homes constructed with the same materials as other types of homes not subject to any such mandate, and specifically called for the repeal of the HUD “Health Notice” in 2013 comments to EPA, the proposed repeal of the HUD “Health Notice,” in and of itself, does not end the longstanding practice of baseless discrimination against HUD Code manufactured homes with respect to formaldehyde emissions and related mandates.  Rather, that pattern and practice is continued with the EPA standards (and the parallel HUD proposed standards) insofar as HUD-regulated manufactured housing is designated as a “finished good,” and therefore subjected to certain related regulatory requirements, while site-built homes are expressly exempted from the definition of a “finished good” contained in EPA’s 2016 final rule on formaldehyde standards.  As MHARR noted then, and continues to press with relevant agencies and federal officials, there is no legitimate basis whatsoever, for exempting site-built homes, but not manufactured homes from the definition of a “finished good,” particularly when no such exemption was contained in EPA’s original proposed formaldehyde rule.

Accordingly, while MHARR supports the repeal of the discriminatory HUD “Formaldehyde Health Notice,” it continues to strongly object to EPA’s blatant double-standard – and continuing discrimination against manufactured housing – with respect to the “definition of a “finished good” and formaldehyde mandates related thereto.

In the event that you wish to comment individually on this matter, please feel free to reference or quote MHARR’s attached comments.

cc: HUD Code Industry Manufacturers, Retailers and Communities

Manufactured Housing Association for Regulatory Reform (MHARR)

1331 Pennsylvania Ave N.W., Suite 512

Washington D.C. 20004

Phone: 202/783-4087

Fax: 202/783-4075

###

 

That’s this morning’s edition of manufactured home “Industry News, Tips, and Views Pros Can Use” © where “We Provide, You Decide.” © ## (News, analysis, and commentary.)

 

ManufacturedHousingProNewsMHProNewsConfidentialTipsDocumentsNews
To report a news tip, click the image above or send an email to iReportMHNewsTips@mhmsm.com – To help us spot your message in our volume of email, please put the words NEWS TIP in the subject line.

Your link to industry praise for our coverage, is found here.

For the examples of our kudos linked above…plus well over 1,000 positive, public comments, we say –Thank You for your vote of confidence.”

We Provide, You Decide.” © ## (News, analysis and commentary.)

(Image credits and information are as shown above, and when provided by third parties, are shared under fair use guidelines.)

Submitted by Soheyla Kovach to the Daily Business News for MHProNews.com.

ManufacturedHomeIndustry#1HeadlineNewsMHProNews
To see a sample of our emailed news update, click here. To sign up for the factory-built home industry’s #1 headline news, click here or the graphic above.

2) To pro-vide a News Tips and/or Commentary, click the link to the left. Please note if comments are on-or-off the record, thank you.

3) Marketing, Web, Video, Consulting, Recruiting and Training Re-sources

SoheylaKovachDailyBusinessNewsMHProNewsMHLivingNewsSubmitted by Soheyla Kovach to the Daily Business News for MHProNews.com. Soheyla is a managing member of LifeStyle Factory Homes, LLC, the parent company to MHProNews, and MHLivingNews.com.

mas kovach mhpronews shopping with soheyla .jp

Get our ‘read-hot’ industry-leading 

get our ‘read-hot’ industry-leading emailed headline news updates

Scroll to Top