May 2013

Performance Criteria for Monitoring Manufacturers and Third Party Inspection Agencies

State of Colorado Division of Housing

COLORADO DIVISION OF HOUSING PROCEDURES FOR MONITORING MANUFACTURERS AND THIRD PARTY INSPECTION AGENCIES

The performance of all Factory-Built manufacturers and third party inspection agencies will be monitored by the Colorado Division of Housing to determine if they are fulfilling their responsibilities as required under the Division’s Factory-Built programs. The effectiveness of manufacturer quality control programs and third party inspection monitoring activities will be verified by the Colorado Division of Housing through performance audits that will include sampling inspections of units produced in and shipped to Colorado. These procedures are for factories where CDOH is not the IPIA, but also may be used as a guide for factories where CDOH is the IPIA.

A.

Quantitative Analysis The analysis of manufacturer quality control and third party monitoring is based on the sampling inspection scores. The assumption behind the oversight inspection is that there should be zero defects on each unit. As deviations are found, they are given a weight numerical score, based on the severity of the code violation. The weighted categories are as follows: Summary of Inspection

Administrative Fire and Life Safety Major Frame Frame Roofing Plumbing Electrical Major Electrical Mechanical Major Mechanical Accessibility Energy

B.

[ [ [ [ [ [ [ [ [ [ [ [

Points ] x 1 = ___________ ] x 5 = ___________ ] x 4 = ___________ ] x 1 = ___________ ] x 1 = ___________ ] x 1 = ___________ ] x 1 = ___________ ] x 3 = ___________ ] x 1 = ___________ ] x 3 = ___________ ] x 1 = ___________ ] x 1 = ___________

Frequency of Oversight Inspections

The weighted scores are tracked over time by manufacturer, inspection agency, and for the industry as a whole using statistical control charts. Trends of compliance or lack of compliance can be readily identified using this method. Data collected from the past fiscal year has established the parameters for determining the frequency of inspections.

C.

Qualitative Analysis

Analysis of manufacturers and third party inspection agencies puts an emphasis on identifying systematic failures to conform that show a pattern of poor quality control. For example, in the Factory-Built Residential Program, a manufacturer on routine status has 4-inspections. The inspection score on all 4 totals 18-points. If 8 of the points are due to one Fire/Safety Nonconformance and one serious electrical deviation, this may indicate that more inspections are needed. In a different scenario, a total score of 18 may not be acceptable due to repeats of the same violation on each inspection. Even though the quantitative measure is acceptable, the larger pattern of deviations must be considered.

D.

Scheduling of Oversight Inspections

The administration and planning of on-site oversight inspections is a somewhat complex task compared to inspection factories on a routine basis. The manufacturer must notify the Division of Housing of the completion and shipping date for al Colorado units. Ideally, the name of the dealer, the owner, final destination, and detailed directions would be provided, but the manufacturer does not always have this information. It typically requires three to four contacts by the Division to have some certainty of where and when a unit will be available for inspection. In addition, the limited number of Division inspectors and the need to effectively use the inspector’s time by ensuring multiple inspections in an area, further complicates scheduling for timely inspections. Having an inspector make a 200 mile trip for a single inspection is avoided whenever possible.

The average scores and distribution around these averages were used to set the control limits. The Factory-Built Residential and Non-Residential Programs are evaluated separately because Residential Buildings tend to be more complex than Non-Residential Buildings and therefore yield different results.

1.

Factory-Built Residential Program

The industry-wide average weighted score of Colorado units is 12-points, with an upper control limit of 18-points and a lower limit of 3-points.

Certification A minimum of five consecutive units inspected with no Fire/Safety violations and a score of 9 or less with insignias affixed by the Division inspector at the conclusion of the certification inspections.

Reduced No Fire/Safety violations and a score of 0 to 9 points; inspections of 5% of Colorado homes selected at random.

Routine A score of 10 to 16 points; inspections of 10% of Colorado homes selected at random.

Additional A score of 17 to 24 points; the next consecutive units are inspected. All 3-units must score 16 or less with on Fire/Safety violations to return to routine status. Failure to return to routine status will result in the manufacturer being placed on increased frequency status.

Increased A score of 25 or more points; the next 5 consecutive units are inspected. All 5-units must score 16 or less with no Fire/Safety violations to return to routine status. Failure to return to routine status will result in the confiscation of insignias and require recertification of the manufacturer and third party inspection agency.

Recertification A minimum of three consecutive units with no Fire/Safety violations and a score of 9 or less with insignias affixed by the Division inspector at the conclusion of the recertification inspection.

2.

Factory-Built Non-Residential Program

The industry-wide average weighted score of Colorado units is 9-points, with an upper control limit of 16-points and a lower limit of 1-points.

Certification A minimum of five consecutive units inspected with no Fire/Safety violations and a score of 6 or less with insignias affixed by the Division inspector at the conclusion of the certification inspections.

Reduced A score of 0 to 6 points; inspections of 5% of Colorado units selected at random.

Routine A score of 7 to 12 points; inspections of 10% of Colorado units selected at random.

Additional A score of 13 to 19 points; the next 3 consecutive units are inspected. All 3-units must score 12 or less with on Fire/Safety violations to return to routine status. Failure to return to routine status will result in the manufacturer being placed on increased increase frequency status.

Increased A score of 20 or more points; the next 5 consecutive units are inspected. All 5-units must score 12 or less with no Fire/Safety violations to return to routine status. Failure to return to routine status will result in the confiscation of insignias and require recertification of the manufacturer and third party inspection agency.

Recertification A minimum of three consecutive units with no Fire/Safety violations and a score of 6 or less with insignias affixed by the Division inspector at the conclusion of the recertification inspection.

MHIP Oversight Inspection Review Score Sheet Manufacturer’s Name: ___________________________________________________ ID#: _________________ Location: ______________________________________________________________ Inspector: ___________________________ Date of Inspection: _________________ MHIP#: ____________________

PA#: _________________

Summary of the Inspection

Points:

Administrative

[ ] x 1 = ____________________

Life & Fire Safety

[ ] x 5 = _____________________

Frame

[ ] x 1 = ____________________

Major Frame

[ ] x 3 = _____________________

Roofing

[ ] x 1 = ____________________

Plumbing

[ ] x 1 = _____________________

Electrical

[ ] x 1 = ____________________

Major Electrical

[ ] x 3 = _____________________

Mechanical

[ ] x 1 = ____________________

Major Mechanical

[ ] x 3 = ____________________

Energy

[ ] x 1 = _____________________

Total Points___________________

NON-Residential Modification Facility Oversight Inspection Review Score Sheet Manufacturer’s Name: ___________________________________________________ ID#: _________________ Location: ______________________________________________________________ Inspector: ___________________________ Date of Inspection: _________________ MF#: ____________________

PA#: _________________

Summary of the Inspection

Points:

Administrative

[ ] x 1 = ____________________

Life & Fire Safety

[ ] x 5 = _____________________

Frame

[ ] x 1 = ____________________

Major Frame

[ ] x 3 = _____________________

Roofing

[ ] x 1 = ____________________

Plumbing

[ ] x 1 = _____________________

Electrical

[ ] x 1 = ____________________

Major Electrical

[ ] x 3 = _____________________

Mechanical

[ ] x 1 = ____________________

Major Mechanical

[ ] x 3 = ____________________

Accessibility

[ ] x 1 = _____________________

Energy

[ ] x 1 = _____________________

Total Points___________________

Residential Oversight Inspection Review Score Sheet Manufacturer’s Name: ___________________________________________________ ID#: _________________ Location: ______________________________________________________________ Inspector: ___________________________ Date of Inspection: _________________ FB#: ____________________

PA#: _________________

Summary of the Inspection

Points:

Administrative

[ ] x 1 = ____________________

Life & Fire Safety

[ ] x 5 = _____________________

Frame

[ ] x 1 = ____________________

Major Frame

[ ] x 3 = _____________________

Roofing

[ ] x 1 = ____________________

Plumbing

[ ] x 1 = _____________________

Electrical

[ ] x 1 = ____________________

Major Electrical

[ ] x 3 = _____________________

Mechanical

[ ] x 1 = ____________________

Major Mechanical

[ ] x 3 = ____________________

Accessibility

[ ] x 1 = _____________________

Energy

[ ] x 1 = _____________________

Total Points___________________

Non-Residential Oversight Inspection Review Score Sheet Manufacturer’s Name: ___________________________________________________ ID#: _________________ Location: ______________________________________________________________ Inspector: ___________________________ Date of Inspection: _________________ FBNR#: ____________________

PA#: _________________

Summary of the Inspection

Points:

Administrative

[ ] x 1 = ____________________

Life & Fire Safety

[ ] x 5 = _____________________

Frame

[ ] x 1 = ____________________

Major Frame

[ ] x 3 = _____________________

Roofing

[ ] x 1 = ____________________

Plumbing

[ ] x 1 = _____________________

Electrical

[ ] x 1 = ____________________

Major Electrical

[ ] x 3 = _____________________

Mechanical

[ ] x 1 = ____________________

Major Mechanical

[ ] x 3 = ____________________

Accessibility

[ ] x 1 = _____________________

Energy

[ ] x 1 = _____________________

Total Points___________________