Code Change Appendix BB Tiny Houses Did Not Include Chassis

Applies To 400 Square Feet Or Less

Appendix BB Tiny Houses is the name of the voluntary appendix in the 2024 IRC edition. Appendix BB relaxes various requirements in the body of the code as they apply to houses that are 400 square feet in area or less. Attention is specifically paid to features such as compact stairs, including stair handrails and headroom, ladders, reduced ceiling heights in lofts and guard and emergency escape and rescue opening requirements at lofts.

Appendix Q Tiny Houses was the name of the code inclusive in the 2018 IRC.
Appendix AQ Tiny Houses was the name of the code inclusive in the 2021 IRC.

 

New Code Proposal For Appendix BB Tiny Houses Failed To Include The Chassis

A new code proposal for the 2027 IRC for Appendix BB Tiny Houses  has been submitted and fails to include the chassis, which is what is needed for the tiny house industry currently.  The code proposal references the new ICC/THIA OSMTH 1215 standard that is currently being drafted, and does include provisions for the chassis.

The code proposal will be heard at the first ICC CAH # 1 committee in Orlando, Florida on April 28, 2025. The hearings are open to the public and there will be a virtual streaming option.
Register For The Hearings

I contacted the proponents with questions about the proposal, but they have not answered.  It does state that they have no obligation to answer, but is seems odd, because it will be the same questions building officials will ask. You can view the code proposal through ICC CP Access.

How To Create An ICC Cp Access Account To View The Code Proposal

  • Create an account. Click to enter.
  • Click on current cycle from navigation pages on top left
  • Click on proposals from dropdown menu
  • Submit: RB42-25 in first box called Agenda Number
  • The second box is Groups and it should say 2025 Group B.
  • After you submit RB42-25, the next page will highlight the number in blue that is clickable and will take you to the code proposal.

RB42-25

IRC: SECTION R301, R301.1 (New), R301.1.1 (New), R301.1, ICC Chapter 44 (New), APPENDIX BB, SECTION BB101, BB101.1

Proponents:

Brad Wiseman, Garmin USA, representing Tiny Home Industry Association; Zachariah Giffin, Operation Tiny Home, representing consumers (za********@***il.com); Amelia Dicks, representing Wind River Built (am****@************lt.com); Nick Mosley, representing California Tiny House, Inc.

2024 International Residential Code

SECTION R301
DESIGN CRITERIA

Add new text as follows:

R301.1 Scope.

Design criteria of buildings, structures and parts thereof shall comply with this chapter.

R301.1.1 Small residential units.

A dwelling unit that is1,200 square feet (111.5 m2) or less constructed as a permanent residential structure, shall be constructed in accordance with ICC/THIA 1215 or this code, as applicable.

R301.2 Application.

Buildings and structures, and parts thereof, shall be constructed to safely support all loads, including dead loads, live loads, roof loads, flood loads, snow loads, wind loads and seismic loads as prescribed by this code. The construction of buildings and structures in accordance with the provisions of this code shall result in a system that provides a complete load path that meets the requirements for the transfer of loads from their point of origin through the load-resisting elements to the foundation. Buildings and structures constructed as prescribed by this code are deemed to comply with the requirements of this section.

Add new standard(s) as follows:

ICCInternational Code Council, Inc. 200 Massachusetts Avenue, NW, Suite 250 Washington DC 20001
1215-202xICC/THIA Design, Construction and Regulation of Tiny Houses for Permanent Occupancy

APPENDIX BB TINY HOUSES

SECTION BB101
GENERAL

Revise as follows:

BB101.1 Scope.

This appendix shall be applicable to tiny houses used as single dwelling units. Tiny houses shall comply with this code except as otherwise stated in this appendix.

Exception: A permanent residential structure constructed in accordance with ICC/THIA 1215.

Reason:

The proposed change seeks to include minimum requirements to safeguard public health, safety, general welfare and to address societal and industry challenges for the inspection and regulatory compliance of small residential units, a new defined term that seeks to address structures less than 1,200 square feet that may serve as both primary and accessory residential dwelling space.  This change will also serve to improve uniformity in the inspection and regulatory compliance of small residential units.   

The proposed change is necessary to update the IRC to explicitly include provisions related to common design elements, construction practices and regulatory compliance requirements commonly associated with small residential units, thereby improving the uniformity and consistency of those design elements, construction practices and regulatory compliance requirements.

The proposed change will also serve to ensure that the provisions of the IRC are properly harmonized with the provisions of the ICC/THIA 1215 standard.

Finally, the proposed change will improve building officials’ ability to develop and adopt regulations and practices that allow small residential units as a permissible form of residential building for permanent occupancy.

For additional information, see the ICC webpage for this standard for ICC/THIA 1215.

Cost Impact:

Increase

Estimated Immediate Cost Impact:

$0.00

Estimated Immediate Cost Impact Justification (methodology and variables):

The ICC/THIA 1215 standard simply provides better focus on small residential units and the specific needs of this type of construction, so this change will not affect the cost of construction.  Instead it provides a better regulatory tool which will facilitate the construction of small residential units.

Staff Analysis:

A review of the following standards proposed for inclusion in the code regarding some of the key ICC criteria for referenced standards (Section 4.6 of CP#28) will be posted on the ICC website on or before April 1, 2025.
ICC 1215-202x    ICC/THIA Design, Construction and Regulation of Tiny Houses for Permanent Occupancy

My Statement And Questions To The Proponents

A pins notification is a way to let interested parties  that would be materially effected by the standard become aware so they can participate as a voting member or interested party.

When ICC/THIA 1215 standard was submitted to ANSI Standard Actions, this was the pins notification.

New Standard

BSR/ICC/THIA 1215-202x, Design, Construction, Inspection and Regulation of Tiny Houses for Permanent Occupancy

(new standard)

Stakeholders: Tiny house builders, building code officials, building product manufacturers, architects, engineers,

third-party plan review and inspection agencies, consumer advocates, homeowners and renters.

Project Need: Tiny houses are growing in popularity as communities look to address affordable housing issues and

home buyers are looking for new housing options. This standard will codify existing requirements for the design,

construction, inspection and certification of tiny houses used as permanent dwellings into a single standard and

address identified gaps in available requirements for foundations and chassis. The 2021 International Residential

Code (including Appendix AQ), and ICC/MBI Standards 1200 and 1205 will serve as the initial base documents with

references to other existing standards.

Interest Categories: Manufacturer, Builder, Standards Promulgator/Testing Laboratory, User, Utility, Consumer,

Public Segment, Government Regulator, Insurance This standard will provide minimum requirements for the design, construction, inspection, certification, and

regulatory compliance of tiny houses used for permanent occupancy to assure public safety, sustainability, and

resilience. The standard will include: consensus definitions for tiny houses and related terminology; ; prescriptive and

performance based compliance methods for tiny house foundations and chassis; and plan review, inspection and

certification requirements for tiny houses constructed onsite and off-site. The standard will address tiny houses built

on a foundation and those with wheels and a permanent chassis intended for permanent occupancy. The 2021

International Residential Code (including Appendix AQ), and ICC/MBI Standards 1200 and 1205 will serve as the initial

base documents with references to other existing standards. The standard will be written in mandatory code-

intended language to support use by manufacturers and adoption by jurisdictions globally. This standard will not address tiny houses used for temporary

or seasonal occupancy, or tiny house community development or microgrids.

Link

The Draft Of The Standard Is Out Of Compliance With The Original Intent Of The Standard

The draft of the standard is out of compliance with the title, scope, and working group scopes, and has been hijacked by a new term-Small Residential Unit ( SRU)  as a  primary focus of the standard that they seek to position over a tiny house, placing a tiny house as a sub-category under the Small Residential Unit.

The term Tiny House is a codified term in the IRC, and the Small Residential Unit is a new term that is not currently inclusive in the IRC, IBC, or used by building officials, engineers,

And more. The committee failed to submit a new pins notification as required by ANSI because of substantive changes. It was requested and denied. 

The code proposal change does nor correlate with the definitions of the small residential unit or tiny house definition in the standard and conflicts with

Each other.

Definitions In 1215 

SMALL RESIDENTIAL UNIT (SRU). A dwelling unit that is 1,200 square feet or less constructed as a

permanent residential structure with or without a PERMANENT CHASSIS system.

TINY HOUSES.  A SMALL RESIDENTIAL UNIT 400 square feet or less with or without a PERMANENT

CHASSIS system

The Working Group Scopes Of 1215

Work Group One Scoping Statement: 

Under the direction of the IS-OSMTH Committee, Working Group 1 will create draft versions of

the “Application and Administration” and “Definitions” chapters of the ICC/THIA 1215 Standard

for Tiny Houses as residential dwellings with or without wheels and deliver those draft versions

to the IS-OSMTH. 

Work Group Two  Scoping Statement:

Under the direction of the IS-OSMTH Committee, Working Group 2 will address the design criteria for tiny houses, including provisions for Fire Safety, Mechanical, Electrical, Plumbing, Gas and Fuel, Energy and Structural Design.

Work Group Three  Scoping Statement:

Under the direction of the IS-OSMTH Committee, Working Group 3 will create draft versions of 

The “Transportation and Storage” and “Installation” chapters of the ICC/THIA 1215 Standard for 

Tiny Houses and deliver those draft versions to the IS-OSMTH committee for review.

Work Group Four  Scoping Statement:

Under the direction of the IS-OSMTH Committee, Working Group 4 will create draft versions of the Manufacturing and Fabrication chapters of the ICC/THIA 1215 Standard for Tiny Houses and deliver those draft versions to the IS-OSMTH committee for review.

The mandatory work group scoping statements for OSMTH 1215 do NOT include the term Small Residential Unit ( SRU) at all, so the current draft is NOT in compliance with the work group scopes. The small residential unit is beyond the approved scope of this standard. 

The term Small Residential Unit Is Also Not In The Title Or Scope Of The Standard.

The code change does nor correlate with the definitions of the small residential unit or tiny house definition in the standard

Definitions In 1215 

SMALL RESIDENTIAL UNIT (SRU). A dwelling unit that is 1,200 square feet or less constructed as a

permanent residential structure with or without a PERMANENT CHASSIS system.

TINY HOUSES.  A SMALL RESIDENTIAL UNIT 400 square feet or less with or without a PERMANENT

CHASSIS system

These Are Questions I Propose To The Proponents

I have been puzzled by the code proposal because the proposal omits the chassis on the definition of a small residential unit, and surprisingly does not add the chassis to the Appendix BB Tiny Houses, and the exception does not include the term small residential unit. 
 
Is it because the Code Correlation Committee determined that adding the chassis to either section would cause it to fail, because a tiny house on wheels is a vehicular unit, a structure on a trailer? A trailer is considered a motor vehicle, 
 
And motor vehicles are regulated by NHTSA and DOT, not considered real property, or considered a permanent residence? 
 
The original proposal for tiny houses that resulted in Appendix Q Tiny Houses had to be edited to remove movable provisions at the request of ICC which was considered a hijack of the proposal. 
 
Are we right back where we started from 7 years ago? 
 
I have tried to dissect the proposal from many different angles, and am I correct in my analysis? 
This is my analysis. 
 
  • You added the term small residential unit to the code under design criteria. You omitted the chassis in the definition based on the feedback of the Code Correlation Committee. 
  • You did not add the chassis to Appendix BB Tiny Houses based on the feedback of the Code Correlation Committee. 
  • The exception did not include the term small residential unit, and you chose to use the term ‘ permanent residential structure,’ that would include the SRU and tiny houses, possibly because of the debate that is going on regarding the SRU. 
  • This way, the term small residential is added to the code, and if the code proposal is not approved,  you have added the exception without using the term SRU, while adding 1215, in case the SRU is stricken, and jurisdictions that want to approve a tiny house on wheels, they adopt 1215, leaving out the chassis in the code. 
I would really appreciate your feedback on this, and I thank you in advance. 

We have had a lot of debate in the 1215 committee, and many are concerned that the Small Residential Unit will bring confusion in the marketplace and erase the great progress Appendix Q Tiny Houses, now known as Appendix BB Tiny Houses have brought to the tiny house industry in the first steps of uniformity across the nation through the adoption of the appendix.

The term Small Residential Unit has no place in this standard,  the size of house already exists, on a chassis, it would be a frame on modular, or a manufactured home if it is larger than 400 square feet. and it will cause unintended consequences to houses of that size.

Thank you,

Janet Thome President
Tiny House Alliance USA

SRU Big Industry Tiny House Takeover OSMTH 1215

What Is A Small Residential Unit ( SRU) ?

A Small Residential Unit ( SRU) is defined as -A dwelling unit that is 1,200 square feet or less constructed as a permanent residential structure with or without a permanent chassis  system in the new tiny house standard currently being drafted by the International Code Council. The committee is trying to position the Small Residential Unit ( SRU), A made up term that is not currently enforced by building officials, or recognized by anyone in a primary position over Tiny Houses, a codified IRC term, placing Tiny Houses as a subcategory under the SRU.

Learn More About The Standard

 

Tiny House Alliance USA Editor
April 16, 2025
The Future Of Tiny Is Now!
Janet Thome Founder And President
ja***@******************sa.org
509 345 2013

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