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Interpretations Request Input

Original Request

  • Request ID: 8472
  • Requested By: Steve Hicks
  • Requester E-Mail: smlhick@att.net
  • Code Version: 2017
  • Code: RESIDENT
  • Code Description:
  • Chapter: Chapter 4 Foundations
  • Section: R403.1.1, R403.1.6, R404.1.9
  • Topic: Manufactured Building (Modular home) foundation.
  • Question: Question # 1.) When using hollow isolated masonry piers foundation for a Modular home, does the foundation have to meet the same standards/requirements of the 2017 Florida Building Code (FBC) as for a conventionally built building? Question # 2.) Can an engineer construct and the building official approve a foundation using the standards/requirements for a HUD/FDOT manufactured building (Mobile home) foundation i.e.; Rows of dry stacked hollow masonry piers with wood cap block, with soil anchors, and ignore the standards/requirements set forth in Chapter 4 of the 2017 FBC to be utilized as a foundation for a modular home?
  • Comment: A manufactured building can't be treated any differently than a conventionally constructed (site build) building according to Florida Statutes (F.S.) Title XXXlll, Chapter 553. Section 553.38 (this statutes takes precedent over the Florida Building Code) states in part "Such local requirements and rules which may be enacted by local authorities must be reasonable and uniformly applied and enforced without any distinction as to whether a building is a conventionally constructed or manufactured building."

Existing Interpretations and/or Declaratory Statements Related to this request

Input Received:

1. Yes. Code does not have an exemption for modular homes. Section R101.2 provides the scope for the FBC-Residential.
2. Maybe. Up to the Jurisdiction - I personally feel that the foundation information needs to state it meets the current FBC. HUD/FDOT standards do not meet FBC, but meets the requirements found under Motor Vehicles Rule 15C-1 and 15C-2
PS. We have had this come up here in Gainesville and I argued this point.
Linda Patrick on 11/04/2020 at 3:54 PM
I agree with Linda on Question Number 1. On Question 2, an engineer can design a foundation as long as the design meets all the loads specified loads. The provisions of the FBC-B are prescriptive and an engineer can deviate from them with engineering design. Large deviations from the FBC-R, particularly in stated loads, merit thorough investigation during plan review.
Joseph Belcher on 11/04/2020 at 7:00 PM
Agree with both on question 1. I think they're kind of saying the same thing on question 2. The engineer has to design it to meet the FBC. If he can do it with stacked block and tie-downs, so be it. But it has to meet the FBC, not HUD/FDOT.
Tom Goldsbury on 11/05/2020 at 1:38 PM

Answer:

1. Yes. Code does not have an exemption for modular homes. Section R101.2 provides the scope for the FBC-Residential. 2. Maybe. An engineer can design a foundation as long as the design meets all the loads specified loads. The provisions of the FBC-B are prescriptive and an engineer can deviate from them with engineering design. Large deviations from the FBC-R, particularly in stated loads, merit thorough investigation during plan review.
On 11/20/2020 at 1:44 PM

Commentary:

For additional information regarding manufactured homes, please refer to FAC 15C-1 and 15C-2

Comments on Draft:

I agree with the answer. But deviations are subject to review.
Samuel Greenberg on 11/24/2020 at 6:48 PM
Looks like the best of both worlds
Linda Patrick on 11/25/2020 at 1:36 PM
I agree.
Joseph Belcher on 11/30/2020 at 3:07 PM
Publish Draft Interpretation