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When does a vehicle become subject to building codes?

Y

Yikes

SAWHORSE
Joined
Nov 2, 2009
Messages
4,108
Location
Southern California
I have a homeless services (Homekey) hotel conversion project in California where they are trying to move residents in now, before the permanent resident laundry room if finished 3 months from now.
They are intending to rent an all-in-one laundry trailer. See example below. It would be placed in the parking lot, using several parking stalls.
It has a vehicle license plate and is roadworthy, kind of like those restroom trailers they use on movie sets or country weddings. The laundry trailer has its own propane supply and grey water tank, just like an RV - -all it needs is a power hookup and a hose connection.

  • The city building official is calling it "temporary construction" per CBC 3103, requiring either a full plan check; or else an HCD modular tag, foundation (auger) plans, and access ramp plans.
  • I contend that because it is licensed by the DMV as a "trailer coach" (like a travel trailer) it is not subject to the building code at all, and can be parked like any other RV - - no foundation needed, no plan check by the building department, and thus no property line setbacks (because vehicles are allowed to park next to the property line).
Who is correct?

1664231493195.png
 
Do you think that it could pass a plan check? The stairs alone would kill it. Has the Division of State Architect approved the trailer?

I have encountered trailer bathrooms at stores during remodel work that are similar to the picture in your post. They were not my responsibility to approve and I thought that they were an accident waiting to happen.

Negotiating the steel stairs while toting a laundry basket is a problem.

As an aside, a trailer is not a vehicle.
 
Last edited:
ICE said:
As an aside, a trailer is not a vehicle.
Click to expand...
If you Google "is a trailer a vehicle" it seems it is. One hit:
"California Vehicle Code 630 – A “trailer” is a vehicle designed for carrying persons or property on … A “trailer” is a vehicle designed for carrying persons or property on its own structure and for being drawn by a motor vehicle and so constructed that no part of its weight rests upon any other vehicle."
 
It must be true, it's on the internet. How many times have we herd this. Mobile homes are vehicles now.

I'm sure the CA code has something to say about how laundry rooms are to be built.
 
We would probably require at least a permit and drawings for an accessible ramp & landing with guards/handrails & some sort of anchorage. The trailer my be a vehicle but it is being used by the public and being used as a temporary bldg. and should be accessible. We also require landings, handrails & anchorage for MH placements. So basically treat just like we would a manufactured home.
 
If it has a license plate then it has a registration as a trailer and I have no jurisdiction over it

Electrical permit for the connection and I would need to know where the propane tanks are located
IFC
6109.10.1 Quantities on equipment and vehicles.
LP-gas containers carried as part of service equipment on highway mobile vehicles need not be considered in the total storage capacity in Section 6109.10, provided that such vehicles are stored in private garages and do not carry more than three LP-gas containers with a total aggregate LP-gas capacity not exceeding 100 pounds (45.4 kg) per vehicle. LP-gas container valves shall be closed.
 
I guess what I'm saying is: You don't plan check a motor home when it sits in a driveway, right?
It's regulated by the department of motor vehicles.

OK, now let's say that motor home hooks up to 110 volts on an exterior electrical outlet, and hooks up to a hose bibb.
At what point does the building official plancheck it? For example, after 30 days of it sitting in one spot, do you start treating it like a structure instead of a vehicle? If so, is the authority to treat it like a structure found in your adopted building code, or your municipal/zoning code?
 
Yikes said:
I guess what I'm saying is: You don't plan check a motor home when it sits in a driveway, right?
It's regulated by the department of motor vehicles.

OK, now let's say that motor home hooks up to 110 volts on an exterior electrical outlet, and hooks up to a hose bibb.
At what point does the building official plancheck it? For example, after 30 days of it sitting in one spot, do you start treating it like a structure instead of a vehicle? If so, is the authority to treat it like a structure found in your adopted building code, or your municipal/zoning code?
Click to expand...
We've had this discussion internally. At no point does it become a building subject to regulation by the building code.

As soon as it is no longer licensed we will designate it a derelict vehicle and deal with it under our Dangerous and Unsightly By-law.

Otherwise it can stay there forever. We found that any other approach has some issues with consistency.
 
Here people use to get license plates for their mobile homes to keep from paying real estate taxes. But then they changed the law about that.
A neighbor that built a little house on a trailer with a license plate and lives in it. It's really cool. No taxes or inspections.
 
we have had this discussion before

"Temporary" office trailer

I have a submittal for an office trailer to be set up while a new building is being built. It will be there for > 180 days so 3103 is out. I made some comments concerning accessibility, MOE, plumbing etc. The response is that the public will only be minimally on site, by appointment only and...
www.thebuildingcodeforum.com
 
Here the State requires (home made or not) that if it is intended to be habitable it must have a RVIA or module/manu. home tag/medallion. If no tag needs to me IRC/IBC. Our local zoning ordinances get us the for anything over 30 days is not temporary and we have placement permit for RV/security trailers also. They also still need to meet set backs. We also would require permits for electric & plumbing connections.
 
my250r11 said:
Here the State requires (home made or not) that if it is intended to be habitable it must have a RVIA or module/manu. home tag/medallion. If no tag needs to me IRC/IBC. Our local zoning ordinances get us the for anything over 30 days is not temporary and we have placement permit for RV/security trailers also. They also still need to meet set backs. We also would require permits for electric & plumbing connections.
Click to expand...
So, does that even extend to say a host in a state or national park campground? (Which are wonderful in New Mexico!)
 
In Florida the department of community affairs plan reviews and inspects modular/ portable buildings. I don't know where this is written but my understanding is my scope (designer) and the AHJ's scope stops at the modular. The modular comes with a tag indicating it's good until a certain date and we just handle the access and utility connections.

Although I did once have an AHJ require a portable be brought to code current at the time (it was certified under the 2014 code, being used in 2018) and it became a negotiation between the owner, the portable lessor and the AHJ. The owner ended up having to pay to bring it up to code and pay extra to have it recertified. Suprise.
 
mark handler said:
we have had this discussion before

"Temporary" office trailer

I have a submittal for an office trailer to be set up while a new building is being built. It will be there for > 180 days so 3103 is out. I made some comments concerning accessibility, MOE, plumbing etc. The response is that the public will only be minimally on site, by appointment only and...
www.thebuildingcodeforum.com
Click to expand...
Thanks Mark, but that thread appeared to be more about a modular like this, that is towed to a site and placed on jacks for longer term (>180 days) use:
1664497380390.png

My question is, would you require the same kind of permit and plan check for a short term trailer, like this movie location restroom vehicle?
1664497602465.png
 
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