Your Voice Matters: Feedback for TDLR's Industrialized Housing and Buildings Program

In March 2014, TDLR asked licensees and the public to share their ideas and experiences related to TDLR. People participated through face-to-face meetings around the state, on an online crowdsourcing website, through social media, and by email.

Participants were asked to answer four questions:

• What does TDLR do well?
• What can TDLR do better?
• What changes would you make to TDLR if you were king or queen for a day?
• Over the next five years, what major changes will affect the way you do business and the services we provide?

We used people’s responses to help us create our strategic plan.

Below you will find participants’ responses concerning TDLR’s Industrialized Housing and Buildings program.

What does TDLR do well?

• Asking industry for feedback
• Bulletins for building officials outlining their authority.
• Good job of making people aware of all the different meetings. I.e. advisory boards and posted agendas. From the top to the bottom, TDLR is always available to communicate with.
• Stand up for the industry with local officials.
• Strength of the program is widespread. Strong for years.
• TDLR support of programs at Legislative level.
• Very open and accommodating to industry's concerns and issues.
• Attentive people on the phone. Professional once you talk to a live person.
• Can call direct
• Communication with emails
• Fast response from TDLR on investigation (pool accident)
• Good communication
• Good guide on codes maintaining equivalency on industry
• Good website information
• Implemented the plan review process
• Lower fees
• Newsletters
• Online services
• Public outreach on the local level

What can TDLR do better?

• Educate locals that the inspectors are ICC certified
• More education for people/locals on what is modular and how differs from manufactured housing
• Multiple agencies with control over various aspects of project
• NJ - Adversarial attitudes between communities
• NJ, MD - Local authorities subjective attitude towards modular
• Switzerland requires 3d modeling of construction prior to construction
• An educated builder is a better builder. With the growing numbers of modular manufacturers in Texas the IHB could provide a valuable service and higher customer satisfaction by coaching Manufacturers. There are so many code references and differences with the HUD product, educating the manufacturer is of great value. Avoid expensive mistakes by preemptive courses in different areas of the IRC. Also, IHB structure and enforcement regulation discussion is something that could provide us with a better understanding of their functions.
• Texas is a national leader in the modular industry. Last year Texas stopped honoring other state labels on plans for used buildings. This is a counterproductive move for our industry. Some states have more stringent specifications than Texas such as snow loads and higher wind load ratings. The problem is not the used building, but the denial from Texas building officials to even consider the structure just because it does not have a Texas seal on the plans. That is a directive from TDLR that must be overturned. Building officials are trained in plan review. Let them review the drawings for used buildings by repealing the TDLR directive that all buildings have state of Texas seals.
• 60 out of 1000 pool companies in Houston with license
• ACR requires 1 licensee for every company. Needs be to a limit for how many people can work under that contractor license. (Ratio)
• Adoption of the most current codes (elevator) and building codes
• Annual elevator inspections – violations get conditional approval but owners don’t actually fix the violation. What happens when that same violation is there next year for that inspector? Require 3rd party re-inspection of those violations.
• Anybody can get an apprentice license. They use fake social security numbers to get the license.
• Apprentices are wiring houses with no journeymen around and inspectors won’t deal with it
• Better communication – maybe more people would show up to these meetings
• Better policing of borders
• CE for appliance installers is needed
• Communication is getting better. We can talk directly to AB.
• Customer service – I can’t get anyone to answer the phone and have to stay on hold for 45 minutes.
• Customers don’t want to use licensed people because they assume that licensed people cost more.
• Customers need to get involved to help prove a case, but the customers don’t want to deal with the complaint.
• Department should put restrictions on the Environmental license so that the contractors aren’t doing refrigeration work.
• Different interpretations by RAS (Registered Accessibility Specialists) on signage codes. Even when we ask Austin, we get different answers.
• DOL apprenticeship schools could be recognized as experience earned under a master electrician.
• Don’t lower the license fees, use that money to increase enforcement
• Double the amount of experience required for people who didn’t go through an apprentice program.
• Educate us on how to file a complaint. What does enforcement need?
• Electrical programs in prison systems. Can these guys get a license since they’ve been in prison?
• Enforce existing rules and have judges willing to assess fines.
• Enforcement – license fees apply to the operation of the department. We’re a self-sustaining entity except for enforcement. Fines and penalties go to the general fund, not back to the department. Legislature needs to rewrite funding mechanism so that a percentage of fines paid goes back to department to specifically fund enforcement.
• Enforcement. No enforcement in pool industry. Nobody gets licensed and we’re bid out of jobs.
• Exam is based on code only. Nothing there about internal wiring. It doesn’t test their knowledge about electricity.
• Give more OJT credit to apprenticeship programs. The hours of experience are the same if you went through the apprenticeship or not. No weight given to apprenticeship program.
• Have a ratio for electricians too (Apprentices to journeymen)
• Have someone just watch the distributors. Watch the trucks coming and going.
• Have to work for a master electrician to qualify for a journeyman license. People come from out of state and want to get a license but they didn’t work for a master because their state didn’t have a licensing program.
• Hire more state employees for elevator.
• Investigators don’t have enough time. Need more investigators. Need more enforcement.
• Liaison between local governments and the state (city building officials)
• Like to see a pool license that covers electrical, plumbing and boiler. Understand that’s going to be a harder exam. It will allow us to install or repair anything we need to without having to bring someone else in and increase the cost.
• Maintenance guys in apartment complexes don’t have to be licensed and they don’t know what they’re doing. When we come across that work we’re expected to fix it and sometimes have to hire an electrician to do it.
• Maintenance work should be limited to non-life safety issues.
• More face to face meetings
• More networking with other governmental agencies (workforce commission, IRS, etc.)
• More public outreach on the local level
• Much of the problem is taken care of if the supply houses can only sell to licensed contractors
• Need more enforcement in the Valley & south Texas
• Need more stings – especially in Houston (specifically in the pool industry)
• Need regional meetings
• On the job training – who’s doing the training?
• Only citizens should be able to get a license.
• People advertise as a handyman who are doing work that requires a license, but they don’t hold a license.
• People are advertising without license numbers (offering to perform)
• People are letting others use their license numbers.
• People doing oil field work are not policed or regulated in any way.
• Public outreach, public service announcements needed to educate consumers
• Raise the licensing fees to pay for more enforcement
• Ratio of journeymen to apprentices not defined at state level. Some cities do have ordinances specifying that ratio.
• Signage at entrance and exit of every retail location selling equipment telling customers who has to have a license to do work. The stores can advertise on the sign that they have a license.
• Some city inspectors work on buddy system. They’re not consistent from one inspector to the next.
• Supply houses should be required to verify that the purchaser has a license.
• Supply houses/distributors don’t want to enforce who has a license. They sell to everybody and don’t check to be sure they’re licensed.
• This is one thing that needs to be in Chapter 51 that applies to all of the licenses that TDLR regulates.
• Time limitations on apprentice license (6-7 years)
• Trucks should have the company name in addition to the license number. Inspectors don’t verify that the company name and license numbers match.
• Unlicensed activity. Supply houses are selling parts to unlicensed people.
• Until 2004, no licenses were required for people who worked in petrochemical plant. Master electricians didn’t go in to the refineries.
• Volunteer deputy stations in different regions to investigate and enforce the law
• Way to cross reference the master to the work he’s signing off on. W-2s maybe. Social security history, tax id number.
• We get outbid by unlicensed people.
• We need language similar to Auctioneer law that requires licensees to be US citizen or legal alien.
• We should issue licenses only to legal citizens.
• We volunteer to enforce for free
• We would volunteer people to set up the stings for you.
• What’s the benefit to levels of licensure? Anybody can be an apprentice for as long as they want. Why should I take the test at all and pay extra fees.
• Work with the industrial facilities and chemical plants to get them to value getting a higher level license

What changes would you make to TDLR if you were king or queen for a day?

• Anonymous complaint process so name not on the complaint, but there is a contact where TDLR can go back for more information
• Anonymous hotline
• Eliminate Limits on height of commercial buildings in statute (more than 3 stories)
• Get modular construction recognized in building codes as a type of construction
• Lease fleet reciprocity
• Manufacturing research grant through federal government that ensure products are safe
• MBI should have national housing codes that meet or exceed local codes
• Non-coded buildings able to come into TX in unincorporated areas
• Reciprocity with other modular programs
• 1 pool license for the whole industry that covers everything having to do with pools
• Any DOL approved apprenticeship program be approved to take the test – give you the experience under a master to meet the requirements. This would also apply to people trying to come in from out of state.
• Cities should have to require technical certifications for their inspectors
• City inspectors need to be licensed by TDLR
• Consistency in issuing permits at local jurisdiction level. Require jurisdictions to verify licensure before issuing permits and report violations to state.
• Don’t need to have regional meetings. There’s no need because we can have input through the website.
• Don’t want more regulation, but TDLR has got to be given more authority to do something. Their hands are tied. There is too much paperwork. Politicians don’t want people getting in trouble during election time. They need to stay out of it.
• Double the enforcement
• Federal fund to pay for the codes as they get enforced. We shouldn’t have to buy all the code books.
• Getting each county an enforcement agent or officer
• Have more people to police the work
• Houston fire department creating codes that don’t comply with ADA – we had to educate them
• I want to hear what TDLR thinks needs to be done
• Inspection authority for outside city limits
• Library of books for people to use – colleges
• Limit the amount of time someone can hold an apprentice license
• Require distributors to only sell to licensed people
• Signage at every retail location to educate consumers about the requirement for a license
• Some municipalities still have licensing programs and some people apply for those licenses because they can’t pass the background check for the state. Cities should be required to hold applicants to the same criminal history standards or city licensing programs should go away.
• TDLR deserves a raise
• TDLR should educate city officials and fire marshals about these and other requirements
• US citizen or legal alien required to be qualified for a license – have this for all industries

Over the next five years, what major changes will affect the way you do business and the services we provide?

• 2015 codes will include ADA accessibility requirements
• In Finland require 3d modeling of projects prior to construction, could spread to other countries
• LEED/Green Code/2012 and later International Energy Code requirements impact construction, for strategic purposes
• Modular as a type of construction in the model building codes
• Move to performance codes rather than prescriptive
• Throw away (temporary) manufacturing plants
• Book smarts allow someone to pass a licensing exam.
• Can the department assist contractors in participating in the discussion on the issues that impact the way do business? How do we give feedback on codes & efficiency standards?
• Closed book exams for appliance license too. Apprenticeship program not required.
• Compare ourselves with other industries that are growing and take the best they have to offer.
• DOL apprenticeship programs getting more recognition for the jobs they do – better education.
• Government regulations on efficiency standards affects the way I do business
• Have a practical portion to the exam for all the trades.
• High school kids need to worry about getting out of school and having a basic reading education so they can read the book and understand.
• How are you researching potential changes? Are you looking at what other states are doing? Are you benchmarking with other high economic development states?
• If the state can decide to not implement mandatory health insurance, can we also decide not to implement energy standards?
• If we can’t get a pool license, we need to be able to change sizing on motors
• Increased regulation and enforcement is a must
• Less government
• Move to closed book tests for Air conditioning. The test measures how well you can use the book, not how well you can work on an air conditioner.
• Panel or regional meetings to discuss code changes
• Retirees’ money doesn’t go as far.
• Tablets on job sites
• Technology is changing - equipment and computers
• Technology is making things faster – cutting processing times from days to hours

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