Issue: DS2013-013. The Petitioner, Mr. Robert Lorenzo, of the Department of Business and Professional Regulation, Manufactured (Modular) Building Program staff, is requesting clarification of the inspection process for storage sheds that are not designed for human habitation and have a floor area of 720 square feet (67m²).

The Petitioner’s question is as follows:

Question: Can storage sheds that are not designed for human habitation and have a floor area of 720 square feet (67m²) and built by an approved manufacturer in the Manufactured Building Program be inspected as finished buildings in the yard for shipping.

Background:

1. Reference to Florida Building Code, Building, Chapter 4, Section 428.(3); 428.3.2.1

2. The Petitioner is a staff with the authority having jurisdiction over the manufactured buildings program. The Department (of Business and Professional Regulation, Office of Codes and Standards) has delegated its inspection authority to particular third-party inspectors who agree to inspect manufactured buildings in accordance with the Code. The Department monitors the performance of manufacturers and third-party agencies utilizing the services of an independent contractor who performs spot checks of plans and site visits.

3. The Department has a monitoring report submitted by the monitor stating that inspection records show the inspector has been inspecting finished buildings in the yard for shipping.

4. The Third Party Agency has provided information stating that of the 437 storage sheds which have received insignias, 89 were inspected. Inspecting 89 of the 437 sheds will provide an inspection rate of 20.36%. Of the 89 inspections, 60 were performed in the yard, providing a 13.7% inspection rate of sheds inspected in the yard. That would leave 29 sheds inspected in the plant, which would amount to 6.66% inspected in the plant.

5. The Florida Building Code, Building, Section 428.3 Inspections indicates that Inspection of installation of manufactured buildings and construction activities, conducted at the site of the installation shall be conducted pursuant to Chapter 1 hereof. Inspections during the manufacturing process shall be conducted by those agencies as follows:

428.3.1 Inspections shall be conducted at the manufacturing facility by an appropriately licensed representative of an agency selected by the manufacturer. The inspections shall be to ensure that the buildings are being manufactured in compliance with the applicable codes and the approved plans. Once an agency has inspected a manufactured building, the manufacturer shall not seek to have the building inspected by another agency, nor shall any agency inspect a building that has already been inspected by another agency unless the subsequent inspection is at the direction of the department or unless the building or modification thereto is being inspected for recertification by the department.

428.3.2 At a minimum, a certified agency shall meet the criteria in Sections 428.3.2.1 through 428.3.2.4.

428.3.2.1 With regard to manufactured buildings, observe the manufacture of the first building built subsequent to the plan approval from start to finish, inspecting all subsystems (electrical, plumbing, structural, mechanical or thermal) thereof. Continual observation and inspection of the manufacturing process shall continue until the agency determines the implementation of the manufacturer’s quality control program capabilities, in conjunction with application of the approved plans and specifications, result in a building that meets or exceeds the standards adopted herein. Thereafter, the agency shall inspect each module produced during at least one point of the manufacturing process and shall inspect a minimum of 75 percent of the subsystems (electrical, plumbing, structural, mechanical or thermal) or 20 percent of storage sheds that are not designed for human habitation and have a floor area of 720 square feet (67 m2) or less manufactured pursuant to the approved plan. Where a production line does not provide the subsystem percentages of inspections prescribed, in a single inspection, additional inspections shall be performed until prescribed percentages of installed subsystems are inspected.

428.3.2.2

With regard to components, observe the manufacture of the first unit assembled subsequent to the plan approval, from start to finish, inspecting all subsystems thereof. Continual observation and inspection shall continue until the agency determines the implementation of the manufacturer’s quality control program in conjunction with application of the approved plans and specifications and the manufacturer’s capabilities result in a component that meets or exceeds the codes and standards adopted herein. Thereafter, the agency shall inspect not less than 20 percent of the manufactured building components and 75 percent of the subsystems in the inspected component.

428.3.2.3

During each inspection, the agency shall verify the manufacturer’s inplant quality control program is working as set forth in the approved quality control manual.

428.3.2.4

Should work stop on a particular module or component for a period of two months, reinspection shall be required.

428.3.3

When an agency discovers a deviation from the code or the approved plans which creates or threatens to create an imminent life safety hazard, all buildings or components which have progressed through that stage of production since the agency’s previous inspection shall be inspected to ensure the absence of that deviation, and the agency shall immediately notify the manufacturer and the department in writing. Any building or component exhibiting the deviation shall be brought into conformance with the applicable code and the approved plans by the manufacturer within thirty days of notification of the deviation by the agency. The corrective action must be left available for reinspection by the agency.

Staff recommendation:

Answer: No. For the subject in question, storage sheds that fall within the 20 percent of those storage sheds that are required to be inspected as per Section 428.3.2.1 are required to be fully inspected during the manufacturing process.