Division VI, Part 1, contains the rules and regulations which
are to apply to all factory-built structures which are not specifically
included in Part 2 of this division.
(1)
Authority to promulgate
rules. Provisions contained within all sections of Part 1 are
authorized under Iowa Code section
103A.9.
(2)
Scope and applicability.
The provisions contained within Part 1 shall apply to the following:
a. Plan evaluation, manufacture, inspection,
and installation of "modular factory-built structures," of closed-type
construction and of open-type construction for those manufacturers who have by
option chosen to have their building component, assembly or system considered
to be closed construction.
b.
Approval by the commissioner or the commissioner's designated representative of
an organization or person referred to as a third-party agent, or independent
inspection agency.
c. All "modular
factory-built structures" manufactured for installation in Iowa after February
1, 1973.
d. Every modular
factory-built structure, building, building system, component, assembly or
system manufactured for installation in Iowa on or after February 1,1973, shall
bear a seal issued by the commissioner which certifies that the unit complies
with the code and that the certificates and approvals required by these rules
have been submitted or obtained.
e.
Every modular factory-built structure, building, building system, component,
assembly, or system which was manufactured before February 1, 1973, and which
is being installed in Iowa for the first time shall have a seal attached
attesting that it complies with the code and that the certificates and
approvals have been submitted to the commissioner.
f.Modular factory-built structures moved or
relocated after the first installation in Iowa shall comply with the applicable
codes and zoning restrictions of the jurisdiction into which it is being moved
or relocated.
(3)
Definitions. Definitions in Division I of this code also apply
to Division VI. These definitions also apply to all parts of Division 6. This
subrule covers terms and definitions that are defined for purposes of
clarification when used in Division VI.
"Building. " A combination of materials,
whether portable or fixed, to form a structure affording facilities or shelter
for persons, animals or property. The word "building" includes any part of a
building unless the context clearly requires a different meaning.
"Building component. " Any part, subsystem,
subassembly, or other system designed for use in, or as part of, a structure,
including but not limited to: structural, electrical, mechanical, fire
protection, or plumbing systems, and including such variations thereof as are
specifically permitted by regulation, and which variations are submitted as
part of the building system or amendment thereof.
"Certificate of compliance. " A certification
which is filed with the commissioner which indicates that the third-party
agency has approved specific models or model groups of factory-built structures
as meeting the state building code. (See 16.610(14)"d" and
16.610(17).)
"Closed construction. " Is any structure,
building, component, assembly or system manufactured in such a manner that all
portions cannot be readily inspected at the installation site without
disassembly, damage to, or destruction thereof.
"Code compliance certificate." Is the
certificate prepared by an approved manufacturer and submitted by the
manufacturer for each unit which is to be installed in Iowa and includes an
Installation Certificate. (See subrules 16.610(19) and 16.610(20).)
"Component. " Any part, material or appliance
which is built in as an integral part of the factory-built structure during the
manufacturing process, or any factory-built system, subsystem or assembly not
approved as part of a unit, section, or module.
"Evaluation or inspection agency." Is an
approved person or organization, private or public, determined by the
commissioner to be qualified by reason of facilities, personnel, experience and
demonstrated reliability and independence of judgment, to investigate, evaluate
and approve factory-built structures or buildings, building components,
building systems, and compliance assurance programs.
"Factory-built structure. " Is any structure,
building, component, assembly or system which is of closed construction and
which is made or assembled in manufacturing facilities, on or off the building
site, for installation or assembly and installation, on the building site.
Factory-built structures may also mean, at the option of the manufacturer, any
structure or building of open construction, made or assembled in manufacturing
facilities away from the building site, for installation, or assembly and
installation, on the building site. Factory-built structure also means
"factory-built unit."
"Independence of judgment." Means not being
affiliated with or influenced by or controlled by building manufacturers or
producers, suppliers, or vendors of products or equipment used in factory-built
structures or buildings and building components in any manner which is likely
to affect their capacity to tender reports and findings objectively and without
bias.
"Manufacturer's bill of sale" means any
document, certificate, sales receipt, etc., signed by the manufacturer or
importer that the modular factory-built structure described has been
transferred to the person or dealer named. The document shall have attached a
copy of the 3A section of the Code Compliance Certificate or shall contain at
least the make, model year, manufacturer's serial number, Iowa model approval
number and the code compliance seal number of the unit.
"Model or model groups. " One or more
manufacturer-designed modular homes which can constitute one model
group.
"Modular." A general term to describe all
factory-built structures which are not manufactured homes, manufactured home
add-on units, or temporary field construction offices, as defined in Part 2, at
661-16.620 (103A). Modular
includes, but is not limited to, panelized units, components, sections and
modules.
"Module. " A unit or a section which is
assembled in its final form and transported in such a manner.
"Open construction. " Is any structure,
building, component, assembly or system manufactured in such a manner that all
portions can be readily inspected at the installation site without disassembly,
damage to, or destruction thereof.
"Seal" or"insignia. " A
device or insignia issued to the manufacturer by the commissioner for affixing
to a factory-built structure or system evidencing compliance with the
code.
"Section. " A division of a factory-built
structure that must be combined with other sections to form a complete
structure.
"Structure. " That which is built or
constructed, an edifice or building of any kind, or any piece of work
artificially built up or composed of parts joined together in some definite
manner except transmission or distribution equipment of public utilities. The
word "structure" includes any part of a structure unless the context clearly
requires a different meaning.
"Testing agency. " An organization approved by
the commissioner which:
1. Is qualified
and equipped for the testing, observation, evaluation, or approval of building
components, construction, materials, equipment, or systems as regulated by
approved standards;
2. Is not under
the jurisdiction, affiliation, influence, or control of any manufacturer or
supplier of any industry;
3. Makes
available a published report in which specific information is included
certifying that the equipment and installations listed or labeled have been
tested and found acceptable according to approved standards.
"Third-party agency. " Is an approved person
or organization, private or public, determined by the state building code
commissioner to be qualified to act as an evaluation, inspection, testing, or
listing agency, as defined in this section.
"Unit. " A single factory-built structure
approved by the state building code commissioner. Units may be combined to form
a larger complex structure or may be a combination of
sections.
(4)
Administration. This section covers the basic requirements for
constructing modular structures and all of the administrative procedures under
which the modular program functions including methods of certification approval
and manufacturing requirements, inspection and installation.
(5)
Modular construction
requirements. All factory-built structures not designated as a
manufactured home, manufactured home add-on or a temporary field construction
office shall be constructed to the requirements in Division I, Part 4, Division
II, Division III, Division IV, or the alternate method of construction as
provided for in Division V, Division VII whenever applicable and Division VIII
of the state building code.
(6)
Modular installation requirements. All factory-built
structures designated as modular units shall be installed according to the
manufacturer's approved installation drawings and any additional state-approved
requirements. All approvals shall be part of the third-party certification
agency approval for their respective manufacturer. In addition, all
installations shall comply with local building codes for items not included as
part of the state approval and local zoning requirements whenever applicable.
Modular installers shall obtain approval as required by rule
661-16.622 (103A).
Modular installation seals shall be obtained and attached upon
completion and the installation certificate shall be completed and filed as per
subrule 16.610(20).
(7)
Procedures for approval. The method of third-party
certification and approval shall be used. The manufacturer shall contract with
third-party agencies for third-party approvals and notify the building code
commissioner of the intent to manufacture units to be installed in Iowa and the
name of the third party or parties to be used.
The third-party agency (or agencies) shall also notify the
commissioner that they have entered into a contract to perform services with
the manufacturer.
Third-party approvals are required for plan and design
approval, plant facilities approval and a continuing inspection of units during
manufacture.
The manufacturers shall submit plans to the third-party agency
or agencies for review and approval. After the plans, the plant facilities, and
an inspection procedure have been approved by the third-party agency or
agencies the manufacturer shall submit a compliance certificate on the form
supplied by the commissioner for each model or model group. The commissioner
will assign an Iowa approval number for those models included in the
approval.
At the time of production of units for installation in Iowa the
manufacturer shall obtain from the commissioner Iowa insignia seals for
manufacture and installation, to be attached to the units at the time of
manufacture and installation, as well as code compliance and installation
certificates.
(8)
Requirements and procedures for obtaining third-party agency
approval.
a. The commissioner or the
commissioner's designated representative shall be responsible for approving any
person, state or organization who submits an application to the commissioner
for approval and whose application is accompanied by written material
evidencing that said agency is:
1. Capable of
discharging without bias the responsibilities assigned by these
regulations.
2. Not under the
jurisdiction or control of any manufacturer or supplier of any
industry.
3. Professionally
competent with independence of judgment to perform the function for which
commissioned.
4. Qualified to
submit all findings regarding code compliance in a detailed report to the
commissioner.
5. Willing to be
inspected and reviewed by the commissioner for all phases of work.
b. The commissioner, in
considering the information supplied with the application for approval, may
limit the agencies' approval to particular types of factory-built structures,
buildings, building systems, components, assemblies or systems.
c. Other states wishing to exercise
application with this state in order to act in the capacity of an approved
third-party agency, may do so provided that:
1. The state laws for issuing seals or
insignia for code compliance are equally effective as those specified in this
code.
2. The conditions in "1" are
enforced in their state.
3. Other
states agree to monitoring of this reciprocal agreement by representatives of
this state assigned by the commissioner.
4. Violations of any condition as part of the
reciprocal agreement may be deemed just cause for revocation or suspension of
this agreement by the commissioner.
(9)
Third-party agency
responsibilities.
a. Evidence of
approval by the state must be on file at each manufacturing facility.
b. Notify the commissioner when they have
contracted with a manufacturer to serve as their third-party agency.
c. Manufacturer plans and specifications must
be approved by the third-party agency.
d. File of all plans and documents must be
maintained at each manufacturing facility and in the third-party agency
office.
e. Send a report to the
commissioner stating that the plans and specifications are in compliance with
the Iowa state building code.
1. Plans and
specifications are not necessary for submittal with this report.
2. A list of approved models for each
manufacturing facility.
3. Verify
that all engineering documents have been signed by a registered engineer or
architect.
4. Update the report as
necessary.
5. Indicate approval of
installation procedures for all of these structures as well as the personnel
who will be doing the installation. However, installation of factory-built
structures shall be, in addition to provisions of this code, in accordance with
any local ordinances which apply. (That is, those construction processes which
are not included as part of the state approval.)
f. Notify the manufacturer of plans and
specifications approval including model numbers for use in preparing
certificates of compliance.
g.
Inspect manufacturing facilities and review or establish a quality control
program and test procedure.
h.
Notify the manufacturer of facilities approval for use in preparing
certificates of compliance.
i.
Prepare an inspection manual to be used by the third-party inspectors and the
commissioner. This manual shall be on file at each manufacturing
facility.
j. Report to the state
outlining in-plant procedures and include a typical inspection checkoff
sheet.
k. Notify the manufacturer
when in-plant inspection program is in force for use in preparing certificates
of compliance.
l.Report each
quarter to the state for each manufacturer and submit information as follows:
1. Account for all Iowa seals used by each
manufacturer during the quarter.
2.
Manufacturer's serial number and model number.
3. Third-party seal number.
4. Iowa seal number.
5. The portion of the unit which was actually
inspected during an in-plant inspection.
(10)
Third-party agency documentation
and plan verification. The third-party agency will be responsible for
the investigation, evaluation, review of test results, of plans and documents,
and each revision thereto submitted to the agency by the manufacturer with
which it has a contract for compliance with applicable requirements set forth
in this code. Such a review shall include but not be limited to:
a. All documentations and plans shall
indicate the manufacturer's name, office address, and manufacturing facility
address.
b. Manufacturer's plans
shall show all elements relating to specific systems on drawings properly
identifiable.
c. Each plan which
contains material requiring engineering evaluation shall bear the signature and
seal of a registered architect or engineer.
d. The plans shall also indicate the method
of evaluation and inspection for all required on-site testing of each
system.
e. Plans shall designate
all work to be performed on site, including all system connections, equipment
and appliances and all work performed within the plant.
f. Space shall be provided on all sheets of
plans near the title box for the approved stamp.
g. Individual system design or any structural
design or method of construction and data shall be in accordance with the Iowa
state building code. Plumbing, electrical, heating and mechanical systems
constitute individual system designs.
h. Grade, quality, and identification of all
materials shall be specified.
i.
Design calculations and test reports shall be submitted when specified or
required.
j. Plans shall be drawn
to scale.
k. Plans shall indicate
the location of the approved seal and data plate locations.
l. Copies of approved plans showing
third-party agency approval shall be on file at each manufacturing facility or
made readily available.
m. Review
and approval of all installation procedures must conform to the following:
1. Crews performing installation which are
under the jurisdiction of the unit manufacturer or the manufacturer's designee,
are approved as competent by the authorized third-party agency.
2. Copies of the installation manual must be
available during installation for use by the commissioner or the commissioner's
representative or by the local building official.
(11)
Third-party agency
plant investigation for quality control. All manufacturing facilities
shall be inspected to the performance objectives as stated in the Iowa state
building code. These include as follows:
a.
Review of the manufacturer's quality control manuals or establishing a quality
control procedure to ensure code compliance.
b. Implementation of inspection and test
procedures which will control the quality of fabrication and
workmanship.
c. Making a complete
report to the commissioner that includes certification of all manufacturing
procedures.
(12)
Third-party agency in-plant inspections. To ensure compliance
with the approved specifications and plans and the Iowa state building code and
in conjunction with monitoring each manufacturer's quality control program,
every approved third-party agency shall:
a.
Maintain a record of inspections and such records shall be reported to the
commissioner every quarter and include the seal report.
b. Witness and verify all required testing in
accordance with the quality control manual.
c. Certify that all seals are being attached
as required and only after each unit meets the code requirements.
d. Prepare a detailed inspection manual that
specifies the third-party agency procedures in making the required inspections
and have this manual available for use by the commissioner or the
commissioner's representative when periodic monitoring is performed.
e. One hundred percent inspection is not
required, however some part of every unit is required to be inspected. A
complete inspection of a typical structural, plumbing, heating and electrical
system shall be made each visit to the manufacturing facility.
(13)
Reapproval of
third-party agencies. Any agency approved by the commissioner or the
commissioner's designated representative must file for reapproval annually.
Such application for reapproval may be filed at any time from the forty-fifth
day prior to the scheduled annual expiration date of the current approval. The
applying third-party agency seeking reapproval shall completely and accurately
furnish all pertinent information as is necessary to make current the
information previously submitted to the commissioner or the commissioner's
representative as part of its original application for approval and all
subsequent applications for reapproval. The application for reapproval shall
then become a permanent record of the department administering the provisions
of the code. Should there be no change in the status of the applying agency
from its original application for approval, an affidavit to that effect shall
suffice for consideration of approval.
(14)
Requirements and procedures for
modular manufacturers.
a. Every
manufacturer shall be responsible for all corrective actions required and the
contractual agreement that each has with the approved third-party agency shall
not diminish this responsibility.
b. Every manufacturer shall notify the
building code commissioner that the manufacturer's facility desires to
construct units which are to be installed in the state of Iowa.
c. Every manufacturer shall contract with an
approved third-party agency to perform all duties listed in 5.610(9),
5.610(10), 5.610(11), and 5.610(12). The commissioner will furnish a list of
approved third-party agencies upon request.
d. Every manufacturer shall file certificates
of compliance with the commissioner for each model or model group, after all
third-party reviews are completed. Whenever additional models or changes are
proposed, the manufacturer shall file additional certificates of compliance or
request that additions be made to existing model lists.
e. Every manufacturer shall notify the
commissioner in writing within 60 days after the effective date of this code,
the current Iowa approval(s) number that the manufacturer has been assigned and
the models which will be manufactured to these standards. Approvals which have
not been reaffirmed within this 60-day period shall be considered to be
canceled.
f. Every manufacturer
shall purchase Iowa seals from the office of the commissioner in accordance
with requirements of 5.610(22).
g.
All units or sections shall have seals if manufactured after February 1, 1973,
and if they are to be installed in Iowa. Regardless of manufactured date, all
units being installed in Iowa for the first time shall have a seal
attached.
h. Every manufacturer
shall complete and furnish compliance certificates and installation
certificates in accordance with the requirements of 16.610(19) and
16.610(20).
(15)
Manufacturer's data plate for modular units. The following
information shall be placed directly or by reference on one or more permanent
manufacturer's data plates in the vicinity of the electrical distribution panel
box or in some other designated location that is readily accessible for
inspection.
a. Manufacturer's name and
address.
b. Serial number of the
structure or unit.
c. Model
designation and name of each of the manufacturers of major factory-installed
appliances.
d. Wherever applicable,
identification of permissible type of gas for appliance and direction for water
and drain connections.
e. Name and
date of the standards complied with in construction of this structure or
unit.
f. The seal serial
number.
g. Design loads and special
conditions or limitations.
h. Date
of manufacture.
i. Electrical
ratings. Instructions and warnings on voltage, phase size and connections of
units and grounding requirements.
(16)
Changes and alterations to
factory-built structures.
a. Changes
to approved plans, drawings or installation instructions proposed by the
manufacturer or third-party agency are to be requested in writing and submitted
to the building code commissioner. All work being performed in the
manufacturing plant that is affected by these changes will not proceed until
written approval is received from the commissioner. Where these changes do not
affect code compliance, then approval is permitted when changes are authorized
through the third-party agency and said changes are then incorporated into the
design documents.
b. The
commissioner shall notify the manufacturer and the third-party agency of all
amendments, deletions or additions to the code provisions and the commissioner
shall allow the manufacturer a reasonable time frame in which to submit a
request for a change in plan approval, if required, in order to conform to the
code change.
c. Basic changes in
manufacturing facility locations, company name or address changes, and changes
resulting in companies changing ownership or dissolving their business are all
to be reported promptly to the commissioner, in writing, generally within a
two-week period after said change was made. The manufacturer shall also notify
the third-party agency of said changes.
d. Alterations to factory-built structures
pursuant to the construction, plumbing, heat producing, electrical equipment or
installation or fire safety in a unit after an Iowa seal has been affixed are
all considered to be subject to the same requirements that exist for any
structure within the local jurisdiction.
e. The following shall not constitute an
alteration to a factory-built structure.
(1)
Any repairs to approved component parts.
(2) Conversion of listed fuel-burning
appliances in accordance with the terms of their listing.
(3) Adjustment and maintenance of equipment
installed in the factory-built structure.
(4) Replacement of equipment in
kind.
(17)
Certificate of compliance. The manufacturer shall provide the
building code commissioner with a certificate of compliance for each model or
model group of the approved modular design. This certification shall include
the following:
a. Model or model group number
which will appear on the data plate and compliance certificate.
b. The signature of an authorized
representative of the manufacturer.
c. The name of the third-party agency
certifying compliance with the code, for each of the three
certifications.
d. Evidence of code
compliance certified by the third-party agencies, for the specific model or
model group being submitted.
(18)
Limitations. For all
types of structures other than one- and two-family dwellings, there shall be,
with the certificate of compliance, an attached statement which sets out the
limitations of the structure based on site conditions, type of construction,
area, and height limitations. A statement to the effect that the structure
should not be used except where it meets these conditions will not be
acceptable.
(19)
Code
compliance and installation certificates. Code compliance and
installation certificates approved for use are available at the Web site of the
building code bureau when seals are purchased pursuant to subrule 16.610(22).
The manufacturer shall complete the certificate and distribute it as follows:
a. A copy shall be returned to:
State Building Code Bureau
Department of Public Safety
215 East Seventh St.
Des Moines, Iowa 50319
b. A copy shall be retained for plant records
and shall be used to make additional copies if necessary. An additional copy
shall accompany other shipping documents carried by the transporter and be
available for inspection by any authorized official or department.
c. A copy of the compliance certificate shall
be forwarded to the dealer, distributor, or any other person who is required to
obtain a local building permit or to oversee installation.
(20)
Installation
certificates. The installation certificate portion of the supplied
combination certificate (see subrule 16.610(19)) shall be partially completed
by the manufacturer at the same time the code compliance certificate is
prepared and made part of the documents shipped with the unit and shall be
completed by the local building official or the installer.
a. When a building permit is required, a copy
of the code compliance certificate shall be presented to the local building
official at the time application for a permit is made. The building official
shall sign the certificate and send a copy to the commissioner at the address
designated in this rule.
b. When a
building permit is not required, the code compliance certificate shall be
signed by the installer and forwarded to the commissioner at the address
designated in this rule.
(21)
Certification seals.
There shall be two seals attached to every factory-built structure which is
installed in Iowa.
a. Every module, unit,
section, or component shall have a state seal securely affixed at the
manufacturing facility to show that the manufactured unit is in compliance with
the code. When components and systems are included within a module, section or
unit and have been approved by the third-party agency to be part of that
module, section or unit, only one seal is required for the module, section, or
unit. A series of panels which make up the final unit when assembled at the
site, and where approved in that manner, require only one seal.
b. Every completed unit when installed at the
final site shall have an installation seal attached to show that the
installation is in compliance with the requirements of this code.
(22)
Seals.
a.
Seal issuance. The state
seal shall be issued by the state building code commissioner upon application
and after approval of the plans and manufacturing procedures has been certified
by the third-party agency evidencing compliance with this code. Applications
for seals shall be made to the commissioner on the supplied form and shall
include the following:
(1) Number of seals
requested.
(2) Iowa model or system
approval numbers.
(3) Reference to
approval of manufacturing procedures and third-party agency or agencies
involved.
(4) A statement by the
applicant that consent is given for inspection and investigation at all
reasonable hours.
(5) Appicable
seal fees.
b.
Seal reporting. Manufacturers shall notify the commissioner monthly of
the use of seals by the manufacturers' facilities. This information shall be on
a form approved by the commissioner and shall contain adequate information to
determine the following:
(1) Seal
number.
(2) Serial number of the
unit on which the seal was placed.
(3) Make and model of the unit on which the
seal was placed.
(4) Number of
sections that comprise the finished unit.
(5) Location to which the unit was
shipped.
(23)
Number of seals required. Each modular building shall have a
seal attached to every section or unit of the building.
(24)
Seal placement on modular
units. Every seal shall be assigned and securely affixed to a specific
section or unit. Assigned seals are not transferable and are void when not
affixed as assigned. All seals not properly affixed shall be returned to or may
be confiscated by the commissioner. The seal shall remain the property of the
commissioner in the event of violation of the conditions of approval. Every
seal shall be placed on and affixed to each section or unit in a readily
visible location within the unit.
(25)
Denial and repossession of
seals. Should investigation or inspection reveal that a manufacturer
is not constructing modular units in accordance with the plans approved by the
third-party agency, and such manufacturer, after having been served with a
notice setting forth in what respect the provisions of these rules and the code
have been violated, continues to manufacture units in violation of these rules
and the code, applications for new seals shall be denied and the seals
previously issued shall be confiscated. Upon satisfactory proof of compliance
such manufacturer may resubmit an application for seals.
(26)
Seal removal. In the
event that any unit bearing the seal is found to be in violation of the code,
the commissioner may remove the seal (after furnishing the owner or the owner's
agent with a written statement of such violations). No new seals shall be
issued until proof of corrections has been submitted to the
commissioner.
(27)
Lost or
damaged seals. When or if a seal has been lost or damaged, the
commissioner shall be notified immediately in writing by the manufacturer. The
manufacturer shall identify the unit serial number, and when possible, the seal
number.
a. All seals that are damaged shall be
promptly returned to the commissioner.
b. Lost and damaged seals shall be replaced
by the commissioner with a new seal upon payment of the seal fee as provided in
this section.
(28)
Return of seals. When a manufacturer discontinues production
of a unit carrying plan approval, the manufacturer shall within ten days advise
the commissioner of the date of such discontinuance and either return all seals
allocated for such discontinued unit or assign said seals to other approved
units.
(29)
Fees.
a.
Form of remittance. All
remittances shall be:
(1) In the form of
checks or money orders;
(2) Made
payable to Iowa Department of Public Safety; and
(3) Addressed to:
State Building Code Bureau
Department of Public Safety
215 East Seventh St.
Des Moines, Iowa 50319
b.
Seal fees.
Modular code compliance seals $30 per seal
Modular installation seals $15 per seal
c.
Other fees. A fee equal
to the direct expense shall be charged for all other services furnished by the
commissioner which are not direct administrative duties of the commissioner's
office, including but not limited to obtaining consultants for review and
evaluation of applications or obtaining reviews from the national code writing
organizations.
(30)
Local issuance of building permits.
a. The issuance of building permits and
occupancy permits shall be in accordance with local ordinances and Iowa Code
sections 103A.19 and
103A.20.
b. Local building codes and regulations shall
apply to all parts of any project which are not included in the state approval
of either the manufactured structure or the installation procedure.
c. Nothing in these rules or the state
building code exempts any factory-built structure from the requirements of
local zoning or site condition requirements.
(31)
Noncompliance to code
provisions. Any noncompliance or unauthorized deviation with the
provisions of this code from the approved plans or production procedures shall
be just cause for the revocation of the plan approval and the return of the
seals.
