Replacing Windows in a Manufactured or Mobile Home

Windows in a manufactured home built since June 15, 1976 are governed by HUD’s Manufactured Home Construction and Safety Standards (24 CFR Part 3280), not by the residential code used for site-built houses. The two sets of rules differ in ways that matter for a replacement. HUD’s escape window needs at least 5 square feet of clear opening with its bottom no more than 36 inches above the floor, and primary windows must be certified for the wind loads the home was designed for.

Which rules apply to your home

If the home entered production on or after June 15, 1976, HUD’s code applies, and the certification label on each section confirms it.

• The HUD Code covers homes that entered the first stage of production on or after June 15, 1976 (24 CFR 3282.8). HUD notes that manufactured homes were formerly known as mobile homes.
• The certification label. HUD says every transportable section of a home built to its code carries a red certification label on the exterior.
• The data plate. Each home also has a data plate, fixed near the main electrical panel or in another readily accessible and visible place (24 CFR 3280.5). It lists the manufacturing plant, serial number, date of manufacture and the wind and roof load zones the home was designed for. It also states whether the home was equipped with storm shutters or other protective coverings for windows and doors.

Find the data plate before shopping. Its wind zone is the first thing a replacement window has to match.

The escape window rule under the HUD Code

Every room designed for sleeping needs at least one outside window or approved exit device that meets HUD’s egress standard, unless the room has its own exit door (24 CFR 3280.106). The requirements, from that section and 24 CFR 3280.404:

• Clear opening: at least 5 square feet.
• Dimensions: at least 20 inches of clear width and 24 inches of clear height.
• Sill height: the bottom of the window opening no more than 36 inches above the floor.
• Hardware height: locks, latches, handles, tabs and any screen or storm window devices that must be operated to get out no more than 54 inches above the floor.
• Normal operation: the window must open to the minimum dimensions without binding or tools. Windows that require removing the sash to reach the egress size are prohibited.
• Screens: integral rolled-in screens are not permitted in an egress window unless the window is hinged.
• Instructions: operating instructions must be attached to each egress window and marked “Do Not Remove.”

These numbers differ from the International Residential Code used for site-built houses, which asks for 5.7 square feet of opening (5 square feet at grade floor) and allows a sill up to 44 inches. A window chosen from a site-built-house guide may not meet HUD’s rule, and the reverse is also possible.

Wind zones and certified windows

HUD’s standard for windows in manufactured homes, 24 CFR 3280.403, requires them to be tested and certified at the design wind load of the home’s wind zone. A replacement that meets the same standard stays consistent with the home’s design. The requirements:

• Tested standard. Primary windows and sliding glass doors must comply with AAMA 1701.2 or the North American Fenestration Standard, AAMA/WDMA/CSA 101/I.S.2/A440.
• Wind loads. The exterior and interior pressure tests must be run at the minimum design wind loads for the home, as set in 24 CFR 3280.305.
• Certification label. Each window must carry a quality certification label from an independent certification body accredited to ISO/IEC 17065.
• Insulating glass. Sealed insulating glass must meet the Class C performance requirements of ASTM E774, and each glass unit must be permanently marked with the name of its manufacturer.
• Egress windows have parallel rules in 24 CFR 3280.404: the same wind-load testing and certification label, with AAMA 1704 added alongside AAMA 1701.2.

For homes built for Wind Zones II and III, manufacturers must design the walls around window and sliding glass door openings so that shutters or other protective covers can be installed. If they do not supply the covers, they must give owners instructions for at least one method of protecting those openings (24 CFR 3280.403 and 3280.404).

HUD also warns owners that a manufactured home should never be placed in a more restrictive wind, thermal or roof load zone than the one it was built for. Because window certification is tied to the home’s design wind loads, the wind zone on the data plate is the one a replacement window has to be rated for.

Safety glass in manufactured homes

HUD has its own list of hazardous locations that require safety glazing (24 CFR 3280.113). Among them:

• Doors: glazing in entrance and exit doors, sliding glass doors, storm doors and unframed side-hinged swinging doors.
• Tubs and showers: glazing in doors and fixed panels less than 60 inches above the floor that enclose bathtubs, showers, hot tubs, whirlpools and saunas.
• Beside doors: glazing within 12 inches of a door’s edge, measured horizontally, and within 60 inches of the floor, in the same plane as the door.
• Large, low panes: glazing within 36 inches of a walking surface when a single panel exceeds 9 square feet, its bottom edge is less than 19 inches above the floor, and its top edge is more than 36 inches above the floor.

Safety glazing here means material that meets the Consumer Product Safety Commission standard, 16 CFR Part 1201, or ANSI Z97.1. The CPSC standard itself excludes glazing used in mobile homes (16 CFR 1201.1); HUD’s list covers them instead.

Alterations, permits and warranties

HUD’s homeowner guidance warns that any significant change, such as an addition or a structural alteration, may require local permits and could take the home out of compliance with the HUD Code. HUD advises consulting the appropriate state, county or local agency before making such a change.

Enlarging a window opening in an exterior wall is the kind of change to raise with that agency before work starts.

On warranties, HUD notes that changes to the home could affect the manufacturer’s warranty, and that it does not require manufacturers to offer a warranty at all. If a home is still under warranty, HUD says the manufacturer’s authorization may be required for repairs.

For complaints, HUD’s advice is to contact the retailer first, then send a written list of problems to the retailer, manufacturer and installer. Problems that stay unresolved go to the State Administrative Agency that runs the federal program in the state, or to HUD in states that have no such agency.

When to bring in a professional, and what to ask

A contractor who works on manufactured homes should start from the data plate, not from a standard window catalog. Questions to ask:

• Is the replacement window certified to AAMA 1701.2 or AAMA/WDMA/CSA 101/I.S.2/A440 at the design wind load for my home’s wind zone, and will it carry the certification label?
• For bedroom windows: will the new unit give at least 5 square feet of clear opening, 20 inches wide and 24 inches high, with the sill no more than 36 inches and the hardware no more than 54 inches above the floor, without removing the sash?
• Which openings need safety glazing under HUD’s list, and will those panes be marked?
• Does the job change any opening size? If so, which state or local agency reviews it?
• Will the work affect my manufacturer’s warranty, and have you checked with the manufacturer if the home is still covered?
• For Wind Zone II or III homes: does the installation keep the shutter provisions working?

Photograph the data plate and the HUD label before work starts and keep the new windows’ certification labels on file.