The dubiousness of CSA A270 and Z240 MH

[Dockonbay2024]

Currently cutting open a new build modular in Ontario that was constructed in a factory by Royal Homes Wingham. New to the world of factory constructed modular homes and quite shocked at the true lack of oversight or accountability. There is no comparison between having a municipal inspector check the build in stages vs the builder checking their own adherence to code as the build progresses. The ability to cover up flaws and damage and cut corners as you go makes it very hard to track down tears in the vapour barrier, insulation that was left out, walls not sealed etc etc. On top of that you can find out the applicable OBC and how it relates and even find out your Municipal Inspectors experience. Meanwhile because the Modular builders buy their compliance off the CSA it won't divulge any information on the modular builder, how they were when audited, if they were audited, who audited them etc etc.

If anything Modular builds hidden away in a factory lend themselves to even more oversight by the federal government than a conventional build, not less. How many Modular Home owners have no idea what the framework and internals of their houses are made of?

 

[steveray]

If anything Modular builds hidden away in a factory lend themselves to even more oversight by the federal government than a conventional build, not less. How many Modular Home owners have no idea what the framework and internals of their houses are made of?

All of them....but that goes for most stick built owners too...

 

[Dockonbay2024]

Perhaps but at least the inspector looked over the build in stages and the really obvious cutting corners, like putting up drywall to hide the missing insulation doesn't often occur. Or like leaving sealing tape off the Formular board because it's covered up by the siding. Because what homeowner would look at thermal signatures or remove a small portion of the siding to see how their modular was made. Amusingly enough the CSA has told us we have no right to ask if a modular builder was competent or knowledgable, basically anyone can apply and pay the money and become CSA approved. Literally zero quality assurance in Canada.

 

[Inspector Gadget]

My experience is counter to yours. I find the modular builders (in my area) are quite solid, and kilo-for-kilo, build better than a large portion of the stick-frame cowboys.

 

[Dockonbay2024]

My experience is counter to yours. I find the modular builders (in my area) are quite solid, and kilo-for-kilo, build better than a large portion of the stick-frame cowboys.

It's good to know that at least some homeowners aren't getting ripped off by the modular build industry. What it needs is a third party to audit them while they operate under CSA 277 and more accountability. So the homeowners can see if the modular builder has any knowledge training or experience in building modular homes, instead of just relying on their goodwill.

 

[Inspector Gadget]

It's good to know that at least some homeowners aren't getting ripped off by the modular build industry. What it needs is a third party to audit them while they operate under CSA 277 and more accountability. So the homeowners can see if the modular builder has any knowledge training or experience in building modular homes, instead of just relying on their goodwill.

I was under the impression CSA A277 did have auditing.... Perhaps I'm wrong in that view ....

 

[Dockonbay2024]

I was under the impression CSA A277 did have auditing.... Perhaps I'm wrong in that view ....

It has auditing but there is client confidentiality between CSA and the Modular builders. So the home owner has no idea when or even if auditing was done, what the results were, who did the auditing, were they qualified, were they truly third party removed or a brother of an employee at the building company. The utter lack of transparency is in complete contradiction to the HCRA claiming they are trying to prevent home owners getting ripped off.

 

[tmurray]

Every single unit constructed under CSA is inspected, however, it is inspected by someone employed by the manufacturer to CSA standards. CSA auditing is conducted, but it is not conducted on the actual construction. It covers the construction process.

The issues with this approach to inspection is that it obviously violates the third party inspector principle. How many of us would feel comfortable with a contractor inspecting their own work? Why is this OK for factory constructed buildings?

Secondly, the manufacturer's inspector largely is not certified to the same level as typical building officials. This creates questions as to the equivalency of the manufacturer's inspection regime to local AHJs.

For its part, Ontario is addressing this issue by requiring units to be inspected by the jurisdiction where the factory is (a first phase permit) approval of the first phase permit is required for the second permit to be issued at the destination jurisdiction.

Personally, I've detected obvious building code defects in brand new units being installed. I've discussed the issues with CSA and told them that if they cannot fix the problems with their process, I will write legislation that does.

 

[Dockonbay2024]

Every single unit constructed under CSA is inspected, however, it is inspected by someone employed by the manufacturer to CSA standards. CSA auditing is conducted, but it is not conducted on the actual construction. It covers the construction process.

The issues with this approach to inspection is that it obviously violates the third party inspector principle. How many of us would feel comfortable with a contractor inspecting their own work? Why is this OK for factory constructed buildings?

Secondly, the manufacturer's inspector largely is not certified to the same level as typical building officials. This creates questions as to the equivalency of the manufacturer's inspection regime to local AHJs.

For its part, Ontario is addressing this issue by requiring units to be inspected by the jurisdiction where the factory is (a first phase permit) approval of the first phase permit is required for the second permit to be issued at the destination jurisdiction.

Personally, I've detected obvious building code defects in brand new units being installed. I've discussed the issues with CSA and told them that if they cannot fix the problems with their process, I will write legislation that does.

We didn't have any inspector at our Modular build in the factory that I'm aware of.

As we take it back to the studs and try to understand how a modular home built under the umbrella of a Tarion Warranty can be so poorly assembled we have CSA telling us they decide what is considered acceptable for modular construction and there is no requirement for anything built under CSA certification to meet OBC code requirements. Basically CSA are a law unto themselves, they hand out certification, they get money in. It is imperative that local inspectors view modular builds at the factory at every stage. We were told "don't cut open the drywall, you won't like what you'll find underneath" Which shows where the modular industry is at.

 

[tmurray]

We didn't have any inspector at our Modular build in the factory that I'm aware of.

An on-site inspector is required for CSA certification. I don't know if you had one or not, and it sounds like you don't either. All I can say is what the CSA requirements are.

 

[Inspector Gadget]

An on-site inspector is required for CSA certification. I don't know if you had one or not, and it sounds like you don't either. All I can say is what the CSA requirements are.

Recognizing that some have had issues with this sort of thing, let's get down to the fundamental issue:

As building officials, what can we do if we think there's an issue? The CSA A277 standard is supposed to verify that a factory-assembled building meets the code requirements for the jurisdiction where the building is to be placed. Per the NBC note,
"However, it can often be difficult to determine whether a factory-constructed building complies with the Code once it has been delivered to the construction site because many of the wall, roof and floor assemblies are closed in and so their components cannot be inspected. CSA A277, “Procedure for Certification of Prefabricated Buildings, Modules, and Panels,” was developed to address this problem with regard to residential, commercial and industrial buildings. This standard describes a procedure whereby an independent certification agency can review the quality control procedures of a factory and make periodic unannounced inspections of its products. The standard is not a building code, only a procedure for certifying compliance of factory-constructed components with a building code or other standard. If a factory-constructed building bears the label of an accredited certification agency indicating that compliance with the National Building Code has been certified using the CSA A277 procedure, the accepting authority will have some assurance that the concealed components do not require re-inspection on site."

Emphasis mine.

Can we request the latest inspection reports per CSA A277?

In our corner of Canada, the provincial building regulation expressly exempts CSA A277/Z240 MH buildings from a framing inspection.

On the other end of the scale, that doesn't stop me from requiring a "pre-drywall" inspection for verifying insulation/vapour barrier.....