Two & a Half Years Later: Surviving the FEMA Aftermath

FEMA's inability to meet emergency housing needs is a national scandal. Victims of the

2005 hurricanes have lived in cramped, unsafe housing for more than two years. On February

14th, 2008, the Center for Disease Control (CDC) announced that thousands of people on the

Gulf Coast continue to live in FEMA-provided shelters that expose them to levels of

formaldehyde that are up to 40 times more than maximum permitted levels.1

One person has

died and many others have been injured by this prolonged exposure. This danger has been

known for over a year, yet people continue to live in these hazardous conditions.

Unfortunately, this debacle is part of a much larger problem. The roots of this lie in

FEMA's inability to manage procurements in a way that ensures high quality products at the

lowest cost to the taxpayer. The current Gulf Coast fiasco is directly traceable to a process

where FEMA purchased thousands of units worth hundreds of millions of taxpayer dollars using

a one-page specification (see HSFEHQ-05-Q-4000, "Request for Quotations," Sept 8, 2005). This

specification provided no guidance about its expectations for quality, and never specified

requirements for indoor air quality, fire safety, safety in high winds, energy efficiency (for

affordable energy bills), or countless other essential measures to ensure public safety and to

minimize overall project costs. This created a situation that allowed manufacturers to use the

cheapest, substandard materials available to construct inadequate homes for those in need.

Beyond the poor specifications, FEMA had no oversight into the quality control of the

procured units. They did not have direct representation in factories to continually inspect the

units, to inspect the process, and to audit the procurement process. Like the specification, this

resulted in the provision of substandard housing that has since been proven as unsafe for

occupancy.

Without drastic and fundamental changes to this plan, there is simply no guarantee that

FEMA won't repeat the same confused and poorly planned process that has scarred the gulf

coast for the past two years.

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According to the CDC the average formaldehyde level of indoor air is 10-20 parts per billion (ppb)

(http://www.cdc.gov/od/oc/media/pressrel/2008/r080214b.htm). The Agency for Toxic Substances and Disease Registry sets "minimal risk

levels" for chronic exposures at 8 ppb (http://www.atsdr.cdc.gov/mrls/index.html).

The average reading in the FEMA trailers was 77 ppb and highest reading in the FEMA trailers was 590 ppb (30-60 times the average indoor air

levels and 74 times the "minimal risk level").

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Thankfully, FEMA does not need to repeat these grievous mistakes in the future. A

process can be put in place today that will ensure that future disaster victims are be put in

attractive, energy-efficient, and (most importantly) safe housing quickly and inexpensively.

Additionally, provisions can be put in place so these temporary shelters can quickly be

converted to permanent homes on permanent foundations, replacing FEMA's disposable travel

trailer solution with a lasting contribution to the affordable housing stock post-disaster. This is a

major step, as a region's affordable housing stock is often the last to be rebuilt after a disaster,

and it houses the most diverse and vulnerable citizens.

This solution is realistic and possible, and has already been demonstrated. The state of

Mississippi was successful in replacing 2,000 travel trailers, moving the victims of Hurricane

Katrina and FEMA's negligence into safe housing under the Alternative Housing Pilot Program.

FEMA can learn from this model, and should immediately take the following four steps to

replace travel trailers with adequate homes, and should implement these strategies to properly

prepare for the next natural disaster. It is this investment in safety that will keep FEMA from

repeating the same scandalous mistakes:

1. PLAN for HOMES

FEMA should immediately prepare a full set of engineering drawings and specifications

for a range of 5,00-1,000 square foot homes that will meet standards for mobile homes

(24 CFR 3280, referred to as the HUD code) and common local building codes (the

International Residential Code - the IRC) when put on permanent foundations. This

"dual certification" allows for rapid deployment to any state under the federal HUDcode

program, and long-term use as permanent housing under the state's modular

programs. These designs should be relevant: designed for different climate zones, for

durability, for long-term use, and designed to be used as homes, not recreational

vehicles.

Most importantly, this work should be done by qualified professional engineers, not

FEMA staff. FEMA staff does not have the expertise, liability, or effectiveness to

implement alone. These engineers are licensed professionals, knowledgeable in the

relevant codes, the industry, and the everyday process of correctly building and

deploying homes. These engineers should certify that the designs meet all applicable

requirements for safety - including indoor air quality, fire safety, and resistance to

strong winds and earthquakes.

During an emergency the manufacturing facilities would be expected to be able to go

into production in less than a week. This would require the designs be industry ready,

tailored to industry production capabilities and practices.

These important steps were taken by the Mississippi Alternative Housing Program and

the professionals involved, and that project should serve as a prototype to build from.

The lessons learned from this program should be used to optimize the units for cost,

performance, and livability.

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2. BID for the BEST

When a natural disaster occurs, FEMA must be able to act immediately, and should not

have to negotiate housing procurement in a panic. With this in mind, a competitive bid

process for each of FEMA's designs must be done to allow for the fastest response

possible when the necessary time comes. This bid process should occur annually. This

will ensure the relevance and accuracy of quotes for each disaster, allowing FEMA and

the vendors to get the best pricing and units possible.

In addition to procuring units through annual competitive bidding, bids should only be

accepted on a plant by plant basis, rather than from companies or dealers. Each

manufacturer's bid should clearly outline plans for quality assurance. In the past, FEMA

purchased from dealers - not manufacturers - and ended up paying higher than

necessary prices for low quality units. By only accepting bids from the manufacturers

performing the work, manufacturers can be held directly accountable for the quality of

their end product, rather than allowing companies to run units in plants that have not

been inspected to the quality control standards in the proposed bids.

FEMA must also require in each quality assurance plan that a representative from the

engineering professional of record continually ensure that all units are produced to

specification, that any substitutions or changes are properly approved, and that

continually inspected to meet all applicable codes. The engineer of record becomes the

"third party", rather than an employee of the manufacturing firm or FEMA staff. This

outside accountability separates the oversight of quality assurance from the

manufacturer, whose best interest is in moving units through his production line quickly.

This will help insure the unit meets the design specification, and will properly balance

the ultimate responsibility for the unit's design and construction.

Again, the work should build on the designs already prepared by Mississippi Alternative

Housing Program and the professionals involved, taking lessons learned and optimizing

the units for cost, performance, and livability. That way, FEMA has price points to

evaluate whether the bids and the designs are competitive and relevant.

3. PROTOTYPE for SUCCESS

FEMA should not only seek bids from 15-20 manufacturing facilities (capable of

producing 15-20,000 units in 4 to 6 months), but the selected vendors should prototype

the units and be production ready in the event of an emergency. Each of the winning

bidders should be paid to produce at least three units to demonstrate that all vendors

can meet and exceed all performance requirements. The first unit can serve as a test,

where quality control and quality assurance can identify problem areas to correct. The

second unit will serve as an opportunity to fix these mistakes and solidify the

construction process, and the third unit will be kept at the manufacturing plant as a

reference standard. This should be done at each manufacturing location, and all vendors

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should be present so an understanding of effectiveness, expectations, and standards of

quality is established well before an emergency.

4. PROTECTING the homeowner through direct QUALITY ASSURANCE

FEMA must hire the engineer of record, not in-house staff, to be continually responsible

for working with each manufacturer during construction to ensure production quality.

This is primarily accomplished through a series of Quality Assurance protocols. The

engineer would need to be qualified HUD-inspector and an IRC home inspector to

ensure that the units comply with HUD-codes and the IRC. The engineer should also

have testing laboratory accreditation to ensure that all materials used comply with

specifications (i.e. have the ability to review, test, and approve materials).

The engineer would be responsible for approving the manufacturing methods of each

unit, ensuring quality control procedures are implemented, and must have the authority

to stop production if the manufacturer fails to meet, or deviates from set performance

expectations. The engineer must also have the responsibly to approve any changes,

modifications, and substitutions requested in case of supply or labor shortages. For

example, the major source of formaldehyde in current FEMA trailers comes from the

over use of materials with formaldehyde that should be regulated to CFR3280.308

(HUD's formaldehyde standard for wood panel products). The engineer of record must

have the authority to substitute alternative materials in situations such as this.

Like the bidding process, it is important that these measures are addressed annually. It

is necessary that this engineer learn from the past production and events every year to

re-evaluate the design and propose new standards and methods to implement next

year.

A similar process worked well in Mississippi by which the state designed, specified, bid,

prototyped, put into production, inspected, and deployed 2,000 units to date. Using this

method, FEMA would be able to react quickly to emergency needs for housing while getting the

best possible price for a high quality product each year.

These steps are much needed to fix what has become a dangerous problem and national

embarrassment. America cannot accept superficial changes or substitutions to FEMA's current

approach when fundamental revisions to a flawed process are necessary. Thankfully, these

crucial changes are simple and realistic.

Disaster victims face enough challenges. They shouldn't have to worry that their government is

exposing them to additional hazards in the housing it provides. With proper planning and good

management, the current Gulf Coast fiasco need never be repeated.

Visit: www.FAS.org