Issue link: https://read.dmtmag.com/i/76207
MHARR Warns Against Private-Sector "Accessibility" Standards On June 18, 2012, the U.S. Architectural and Transportation Barriers Compliance Board (Access Board) published proposed accessibil- ity guidelines for Emergency Transportable Housing (ETH), including manufactured homes, provided to disaster victims by the Fed- eral Emergency Management Agency (FEMA) and other government agencies. The guidelines are based on theNovember 2008 recommenda- tions of an Access Board advisory committee comprised of representatives of disability rights organizations, affected federal agencies and ETH manufacturers, including the Manufac- tured Housing Association for Regulatory Re- form (MHARR). While written comments on the proposed guidelines are not due until August 17, 2012, the Access Board held a hearing on the guide- lines at its July 11, 2012 meeting in Washing- ton, D.C., and invited MHARR to testify based on its participation in the ETH advisory committee. In that testimony, MHARR stressed twomajor points concerning the guide- lines which, under theAmericans with Disabil- ities Act and the Architectural Barriers Act, apply only to ETH purchased, constructed or altered by federal government agencies, or with federal funds. First,MHARR voiced its support for the de- cision of the Access Board not to include a guideline addressing indoor air quality (IAQ), or "indoor environmental quality," which MHARR had opposed as a member of the Ac- cess Board Advisory Committee. Quite sim- ply, manufactured homes – unlike other types of ETH -- are already subject to stringent fed- eral formaldehyde standards that have been ef- fective in reducing the number of interviewing. 3.Make the prospect comfortable - provided comparable chair and writing space for the prospect to make any notes they may wish to make. 4. Sell yourself and your business - a good prospect will probably ask for background material on your com- pany. Be prepared to adequately explain the advantages of coming to work for your company. Provide any proof sources you may have to back up what you are telling the prospect. 5. Cover each and every question with all prospects -make sure you \ 22 cover all of the questions listed in these articles. You never know when the last question might provide information that makes the prospect unacceptable. 6. Use silence - silence after asking questions encourages even the most closed mouth prospect to talk. That's all the roomI have for thismonth. I will continue with these questions next month. Until then – GOOD SELLING! T J Grayson Schwepfinger is a nationally known speaker and member of the man- ufactured home Hall of Fame. He specializes in sales and sales management training and can be reached for comments or more information at his e-mail schwep1@aol.com or his phone 610 533 4969. formaldehyde-related complaints in manufac- tured homes to minimal levels. Thus, there is no need for any other guideline or criteria for manufactured housing. And, even more im- portantly, a guideline or criteria for manufac- tured housing different from the existing HUD standard could raise serious compliance issues for manufacturers that could negatively affect their participation in ETH programs. Second, MHARR warned the Access Board and HUD against any effort to extend the guidelines beyond the government sphere, stressing that although it has no objection the proposed guidelines as they relate to purchases of ETH by FEMA and other government enti- ties, it does not and would not support the im- position of the same guidelines as federal standards applicable to homes sold or leased to private sector purchasers because: (1) theHUD Code is a construction and safety code, not an accessibility code, such that HUD's regulatory authority is limited to issues involving life safety and structural integrity, and does not extend to accessibility; and (2) it would be inappropriate to increase the cost of manufactured housing across-the-board (by as much as $1,135.00 per single-section unit based on the Access Board's Regulatory Impact Analysis and possi- bly more when re-design, design approval and inspection costs are included) for features that most purchasers would not use and do not need, particularly when any and all accessibil- ity features needed or desired by private sector purchasers are available fromindustrymanufac- turers as design options. In addition to this testimony, MHARR will submit written comments addressing the pro- posed guidelines and willmake those comments available for the use of industry members that wish to submit their own separate comments. 7 YEARS WARRANTY COVERAGE "The Perfect Addition For Your Home Sales" Most Competitive & Comprehensive Program in the Manufactured Home Industry Coverage Available For: Manufactured / Modular / Park Model Homes Up to 7 Years Structure Coverage 7 Years Systems (Heating, A/C, Plumbing & Electrical) 7 Years Appliance Coverage Component Only Coverage Coverage Available for New & Pre-Owned Homes FHA/VA/HUD Coverage Offered Renewable Coverage Available HomeCarePlus A Complete Package Designed for Today's Homes Welcoming Former American Modern Manufacturer's, Lenders, Communities & Dealers E-Mail: diversifiedprofits@comcast.net No. 14 on Get It Quick Page For More Information Contact: Diversified Profits, Inc. (800) 851-3738 Office 651-458-2905 Fax AUGUST 2012 23 THE JOURNAL