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The classification of a converted school bus

Introduction

School bus conversion appeared during the past 10 years as a way of permanent living in a market where housing has been shaken by different economic, political and environmental events. The tsunami of 2004, the crash of 2007 and international tensions regarding the climate change have clearly developed a tendency for affordable housing, yet comfortable, yet modern, yet owned as an asset to invest in a kind of life focused on social progress. School bus conversion has been a response to settle families in a new way of life as an owner of the home and a tenant on the land. Most conversions are DIY projects and most of them are converted on a tiny budget with home made blueprints. This kind of home-made conversion created a vacuum where none of the existing regulations apply. 

To understand the regulations and the way they can impact the design of a school bus, I have compared the definitions provided by NFPA, ANSI and HUD. This post will give you a very short description of those regulations that I develop in the "Guideline to Convert a School Bus". This guideline version-1 will be available by 04/24/2019 here on my blog and on Amazon. You can receive a free copy for a limited time by subscribing to the newsletter :









Definitions in the law


In NFPA 1192, 3.352, a Recreational Vehicle (RV) is:
a vehicle or slide-in camper that is primarily designed as temporary living quarters for recreational, camping, or seasonal use; has its own motive power or is mounted on or towed by another vehicle; is regulated by the National Highway Traffic Safety Administration as a vehicle or vehicle equipment; does not require a special high-way use permit for operation on the highways; and can be easily transported and set up on a daily basis by an individual.

A Recreational Vehicle can be labeled as a "Model RV Park" if it fulfills the requirements of ANSI-119.5. In ANSI A-119.5-15 of 2009, a Recreational Vehicle is:
a vehicular type unit primarily designed as temporary living quarters for recreational, camping, travel or seasonal use, that either has its own motive power, or is mounted on, or towed by another vehicle. The basic entities are camping trailer, fifth wheel trailer, motor home, travel trailer and truck camper.
A converted school bus is classified as a "motor home" by DMV. In the definition of "motor home", ANSI A-119.5-15 of 2009 refers to NFPA 1192 2008 edition. Unfortunately, the NFPA 1192 provided on the website of https://www.nfpa.org, does not provide any definition for "motor home". 

In a Notice of February 8, 2016, HUD brings a limitation to the term of Recreational Vehicle. You will find the annotated document in my eBook.
...by including a requirement that units claiming the ANSI A119.5—15 exemption prominently display a notice stating that the unit is designed only for recreational use, and not as a primary residence or permanent dwelling.
Recreational vehicles are not subject to this part, part 3280. A recreational vehicle is a
factory built vehicular structure designed only for recreational use and not as a primary residence or for permanent occupancy, built and certified in accordance with NFPA 1192— 15 or ANSI A119.5—09 consensus standards for recreational vehicles and not certified as a manufactured home
The National Manufactured Housing Construction and Safety Standards Act of 1974 1 (Pub. L. 93—383, approved August 22, 1974) (42 U.S.C. 5401—5426) (the Act) authorizes HUD to establish and amend the Federal Manufactured Home Construction and Safety Standards (the Construction and Safety Standards, or Standards). When originally enacted, the Act covered mobile homes, defined as “a structure, transportable in one or more sections, which is eight body feet or more in width and is thirty—two feet in length.” Consequently, structures measuring less than 256 square feet were excluded from the definition of mobile home under the Act.
A recreational vehicle is a vehicle, regardless of size, which is not designed to be used as a permanent dwelling, and in which the plumbing, heating, and electrical systems contained therein may be operated without connection to outside utilities and which are self-propelled or towed by a light duty vehicle.” 
In 1980, the Housing and Community Development Act of 1980 (Pub. L. 96— 399, approved October 8, 1980) amended the definition of “mobile home” in the Act by striking out “eight body feet or more in width and thirty- two body feet or more in length” and substituting “in traveling mode, is eight body feet or more in width or forty body feet or more in length or, when erected on site, is three hundred twenty or more square feet.” The Housing and Community Development Act of 1980 also added a provision to the Act that exempted from the coverage, “any structure which meets all the requirements of this paragraph [42 U.S.C. 5402(6)] except the size requirements and with respect to which the manufacturer voluntarily files a certification required by the Secretary and complies with the standards established under this title.”

(...) HUD proposed removing the exemption for certain recreational vehicles from its Procedural and Enforcement regulations. HUD stated that it had received numerous comments from the manufactured housing industry and from the public criticizing the exemption, and that the exemption had been difficult to apply. HUD also stated that it proposed establishing a procedure under which manufacturers of units which meet the definition of manufactured home except for the size requirements may bring their units under the jurisdiction of the Act by providing for a certification. HUD stated that the proposed certification would be easy to comply with and place a minimal burden on the manufacturer.
HUD received numerous comments, however, which were critical of the proposal to do away with the recreational vehicle exemption. As a result, relying on a conference report on the 1980 amendments that directed HUD to consider a more flexible standard for smaller manufactured homes (such as park models) whose square footage is between 320 and 400 square feet, HUD continued the exemption but expanded it to its current form. Specifically, HUD determined that recreational vehicles were exempt from HUD’s Manufactured Home Construction and Safety Standards and its Procedural and Enforcement Regulations if a unit is:
(1) Built on a single chassis;
(2) 400 Square feet or less when measured at the largest horizontal projections;
(3) Self—propelled or permanently towable by a light duty truck; and
(4) Designed primarily not for use as a permanent dwelling but as temporary living quarters for recreational, camping, travel, or seasonal use.
In 1988, HUD issued guidance to clarify the method for measuring a unit to determine whether it qualified as a recreational vehicle under HUD’s exemption. In interpretative bulletin A—1—88,2 HUD stated that “measurements shall be taken on the exterior of the home. The square footage includes all siding, corner trim, including storage space, and area enclosed by windows, but not the roofing overhang.”


Conclusion 1

If the converted school bus is used as a seasonal living quarter, it is a Recreational Vehicle. In this condition, ANSI and NFPA standards apply. If the converted school bus is used at a permanent dwelling, it is a Manufactured Home and the HUD standards apply.

Manufactured homes are homes built as dwelling units of at least 320 square feet in size with a permanent chassis to assure the initial and continued transportability of the home. All transportable sections of manufactured homes built in the U.S. after June 15, 1976 must contain a certification label. The label certifies that the manufacturer has built the home in accordance with HUD's Manufactured Home Construction and Safety Standards (the Standards). The Standards covers Body and Frame Requirements, Thermal Protection, Plumbing, Electrical, Fire Safety and other aspects of the home, published under 24 CFR Part 3280.
Enforcement of the HUD Standards
The Department has approved 15 State and private third party agencies to conduct inspections of the manufacturer’s production facility at various stages of the construction process. Some of the third party agencies also approve a manufacturer’s home design to ensure the plans are consistent with the HUD Standards. These agencies are known as a Primary Inspection Agency (PIA). There are two types of PIAs: Design Approval Primary Inspection Agencies (DAPIA) and Production Inspection Primary Inspection Agencies (IPIA). Manufacturers contract directly with a State or private third party agency and pay for the design review and home inspection services. Manufactured home retailers also have certain responsibilities to assure that only homes meeting the standards are sold to the general public.
In other words, a converted school bus which is used as permanent dwelling must meet the HUD standards and tag their "Manufactured Home" with a HUD label.


About "Manufactured Homes"

To understand the difference between a "Recreational Vehicle" and a "Manufactured Home", it is important to understand why regulations are made. They are designed to protect the public against fire, accidents and the emergence of social dysfunction that would result in poor quality life, the emergence of classes and struggles. Standards are made to protect the public against the habits of poverty where struggle and hardship becomes a norm that anchors poor quality life such a way that social progress no more exist. Hardship can happen. Struggles can happen. Events can happen in a life that drives people into poverty but poverty is not a status. It is a short term passage when somebody is driven down and it is supposed to be a passage only because we live in a human society where the society has to play a role. The role of the society is to take the people who are driven down to bring them into a better world, and this world, to be able to work properly, needs to meet standards.

HUD has defined standards that generally would describe an acceptable way of living in a home to be safe, to be secure, to work and function properly for cooking, sleeping, having hobbies, educating children, having friends, pets, activities, being able to clean, organize and maintain the house on a budget that meets also reasonable standards for being able to pay the home, the food and the bills. Whether the home is a school bus or a in-site building does not really make any difference as long as the minimum standards of living are met, and those standards are meant to increase the quality of life.

When "Manufactured Homes" meet certain requirements, the HUD is able to help finance the loan for buying the "Manufactured Home". One of those requirements involve anchoring the Manufactured Home on solid foundations, but this requirement is framed exclusively to define which kind of Manufactured Home can receive financial support. Some Manufactured Homes will receive financial support while other Manufactured homes will not. More generally, when a home is anchored on solid foundations, it will receive financial support from HUD to purchase. When the Manufactured Home is not anchored on solid foundations, it is still a Manufactured Home but it is not eligible to financial support. In the Notice of February 8, 2016, HUD gives a definition of a Manufactured Home:
2. In § 3280.2, revise the definition of “Manufactured home” to read as follows:
Manufactured home means a structure, transportable in one or more sections, which in the traveling mode is 8 body feet or more in width or 40 body feet or more in length or which when erected on-site is 320 or more square feet, and which is built on a permanent chassis and designed to be used as a dwelling with or without a permanent foundation when connected to the required utilities, and includes the plumbing, heating, air-conditioning, and electrical systems contained in the structure. This term includes all structures that meet the above requirements except the size requirements and with respect to which the manufacturer voluntarily files a certification pursuant to § 3282.13 of this chapter and complies with the construction and safety standards set forth in this part. The term does not include any recreational vehicle as specified in § 3282.15 of this chapter.
Calculations used to determine the number of square feet in a structure will include the total of square feet for each transportable section comprising the completed structure and will be based on the structure’s exterior dimensions measured at the largest horizontal projections when erected on site. These dimensions will include all expandable rooms, cabinets, and other projections containing interior space, but do not include bay windows. Nothing in this definition should be interpreted to mean that a manufactured home necessarily meets the requirements of HUD’s Minimum Property Standards (HUD Handbook 4900.1) or that it is automatically eligible for financing under 12 U.S.C. 1709(b).

Conclusion 2

All Manufactured Homes, rather they are with or without permanent foundations, which are used as a permanent dwelling must meet HUD standards. This is the complete online version of the "MANUFACTURED HOME CONSTRUCTION AND SAFETY STANDARDS". You will find in the "Guideline to Convert a School Bus"  detailed description and explanation of the text to meet those standards in a school bus conversion. Register now to receive a free copy of the book. This offer is limited to only people who register before the publication :








TABLE OF CONTENT


  • Forewords
  • About the Author
  • Introduction
  • Why to buy a school bus
  • How to buy a school bus
  • Limitations
  • Unlimitations
  • Fixed costs
  • Know your school bus
  • Preparation
  • Rules and regulations
  • Definition of the project
  • How to finance your conversion
  • Design
  • How to choose your equipment
  • Security
  • Organization
  • Construction
  • Keeping records
  • Documenting your project
  • Insurances
  • Long term investment
  • Painting
  • Decorating
  • Outdoors
  • Sustainability
  • Social perspectives
  • Political impact
  • How to live permanently in a school bus
  • Self-estime
  • Conclusion

About tiny homes

School bus conversions are frequently labeled as "tiny homes" and the question that generally emerges on forum is "which code applies?"

On NFPA, I found a "tiny home facts sheets" that sums up all the aspects of a tiny home:
a tiny home is typically a single-family home, generally 400 square feet or less, that is intended as a permanent, non-transitory occupancy. (...) Tiny homes are built in different ways, and it is important to identify the types of tiny homes that fall within the scope and application of building codes or related regulations. Many tiny homes include features or attributes of the following: 
  • Recreational vehicles 
  • Manufactured homes 
  • Modular dwellings 
  • Site-built dwellings 
In fact, this text is not correct because the Recreational Vehicles are only temporary and shall be excluded from the tiny home description. A tiny home is a Manufactured home, 400 square feet or less, a modular dwelling or a site-built dwelling.

On a note, NFPA refers to a white paper called "applying building codes to tiny home" dated March 2017.

For the most part, a tiny home is just that — it is a single family dwelling on a very small scale. The tiny home community often states that the size of a tiny home is 400 square feet or less. But this threshold is subjective. There is no formal definition for tiny homes in nationally recognized building codes. 
Tiny homes are dwellingsA dwelling is considered by building codes to be used as a non transient occupancy for the purposes of living, which includes sleeping and cooking. Dwellings are not for transient use, where occupants unfamiliar with the building will stay temporarily, such as a hotel room. Dwellings are therefore generally subjected to the same building code regulations as any other home unless specifically exempted. Those working to enforce code provisions on tiny homes may have difficulties because the nature of tiny homes introduces features that challenge conventional code requirements. 
(...) Codes are adopted and enforced by jurisdictions to provide a minimum level of safety to protect building occupants and property. Their intent is to minimize dangers to life and property. These regulations protect against many risks associated with the purpose and use of buildings. The safety goal of building codes is to reduce the probability of injury or death from fire, structural failure, and building use
(...) For the purposes of these guidelines, a tiny home is intended for permanent and non-transitory occupancy or residency. Also for the purposes of these guidelines, tiny homes are not attached to multiple units and would not be configured or used as a bunkhouse.
(...) There is one issue when following regulations for recreational vehicles (RVs). The U.S. Department of Housing and Urban Development (HUD) requires RVs to be only “temporary living quarters,” and tiny homes often are intended to be permanent homesRegardless, tiny homes taking this form are not regulated by building codes. As RVs, they more likely must comply with other state or federal regulations.
(...) Building codes require that a building be classified with an occupancy. See NFPA 5000 Section 1.7.6.2.1 and IBC Section 302.1. Tiny homes are separate buildings intended for non-transient living purposes. The occupancy that building codes establish for an occupancy for residential living is a dwelling unit: in NFPA 5000 the occupancy is a one- and two-family dwelling; in the IBC/IRC it is an R-3 occupancy. 
Tiny homes are single-family dwellings, and under this occupancy description the building code will regulate them. A dwelling is defined as a building provided with permanent provisions for sleeping, cooking, eating, living, and sanitation. Tiny homes are not accessory structures, as considered by building codes. Accessory structures is a term used in building codes to refer to structures accessory and incidental to a building on the same lot. This means that an accessory structure is not for primary use. A dwelling, no matter what the size, is a primary use and a permanent, habitable occupancy. Accessory structures would more commonly be a shed or detached garage. 
 In the "Guideline to Convert a School Bus", I describe all the rules applicable to tiny homes.




Conclusion 3

A converted school bus may be a tiny home if the occupancy is permanent by a single family. When the occupancy is only temporary, then the rules of regulations of Recreational Vehicles apply which I describe in the "Guideline to Convert a School Bus".

Why follow the rules?

This document about MANUFACTURED HOME FIRES describes with graphs and pictures the difference between a home following the HUD standards and a home which does not. Following the standards drops the risks by more than 50% just only on fires. In the Guideline to Convert a School Bus", I explain the other incidences on a daily basis to prevent domestic accidents, thief, depression, cancer, expenses, etc.... Don't forget to subscribe to receive a limited-time free copy of the book.



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About E.B

Eima BLANK is a designer and a rewarded entrepreneur who started a career as an ethnographer in 1992, was graduated in architecture in 1995 and is now experiencing her passions as a carpenter and a craft woman. She has directed wood construction projects from 2010 to 2015. She is the author of several books and studies about wood construction and the economy of forestry. She has also won several concourses for her innovations on wood and fabric construction. Her drawings entered an army museum for her sarcastic humor, she has a model house in another museum and she is a member of the ADAGP and the ARS for the management of her artist and designer rights. She is also an occasional cartoonist, what she carries on her smile.
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