Discussion Forum

Moved or Relocated? That is the Question
Original Comment:
Unlike site-built buildings, which are typically intended to remain on their original site for the life of the building, relocatable modular buildings are designed and intended for relocation, reuse and/or repurposing. Many states have statutes that govern the building and relocating of relocatable modular buildings. For those that do not have state requirements, much confusion and inconsistency exists about the requirements for relocatable modular buildings in the building code.

The 2009 International Building Code simply defines a structure as “that which is built or constructed,” while defining an existing structure as “any buildings and structures for which the ‘start of construction’ commenced before the effective date of the community's first flood plain management code, ordinance or standard.” “Existing construction” is also referred to as “existing structures.”

Chapter 34 of the IBC requires that: “Structures moved into or within the jurisdiction shall comply with the provisions of this code for new structures.”

So it’s clear: if you move an existing structure into a new jurisdiction, that structure is required to comply with provisions of the IBC for a newly constructed building. But wait a minute …

The 2009 International Existing Building Code defines an existing building as a building erected prior to the date of adoption of the appropriate code, or one for which a legal building permit has been issued.

Chapter 13 of the IEBC deals specifically with “Relocated or Moved Buildings” requiring: The building shall be safe for human occupancy as determined by the International Fire Code and the International Property Maintenance Code. Any repair, alteration, or change of occupancy undertaken within the moved structure shall comply with the requirements of this code (IEBC) applicable to the work being performed. In short, the relocated building must meet the seismic, snow and wind loads at the new location.

So what if you have an existing relocatable building that you move into a new jurisdiction? Does it have to meet the requirements for new construction of the IBC or Chapter 13 of the IEBC? We have always felt that it was unfair to put the local building code official in a position to make an interpretation that could potentially cost the owner of the building several thousands of dollars.

During the most recent code development cycle for the 2015 IEBC, MBI worked with the ICC’s Code Technology Committee (CTC) on a proposal to help clarify some of the confusion. The CTC submitted a proposal that was accepted to ensure that “relocatable buildings” were in fact considered relocated or existing buildings when moved into a new jurisdiction. The CTC further defined a relocatable building as “a partially or completely assembled building constructed and designed to be reused multiple times and transported to different building sites.”

This change firmly places conformance requirements for existing relocatable buildings in Chapter 13 of the IEBC rather than Chapter 34 of the IBC. To further clear up the discrepancy, beginning with the 2015 version of the IBC, Chapter 34 was modified and will now refer code officials to the IEBC for conformance requirements for existing buildings.

So in summary, an existing relocatable building, now defined as “a partially or completely assembled building, constructed and designed prior to the date of adoption of the appropriate code or one for which a legal building permit has been issued, to be reused multiple times and transported to different building sites” will need to comply with the applicable requirements of the International Existing Building Code rather than the International Building Code.
Started on January 17, 2014 by Tom Hardiman
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