Public Guidance: Ready-Removables and Non-Traditional Homes

The Tennessee State Fire Marshal’s Office (“SFMO”) issues this guidance to clarify the licensing and codes requirements for structures that are partially complete prior to transportation to a final site intended for residential use. The following describes the SFMO’s understanding regarding such structures.

Pursuant to Tennessee Code Annotated § 68-126-303(9), “‘Ready-removable’ means a structure without any foundation, footings, or other support mechanisms that allow a structure to be easily relocated but which may include electrical wiring.” Further, pursuant to Tennessee Code Annotated § 68-126-311, “No ready-removable shall be modified for use as residential, recreational, or emergency housing in this state.” Tennessee Code Annotated § 62-6-103 requires any contractor(s) who work on projects costing

$25,000 or more to obtain a contractor’s license with the Department of Commerce and Insurance.

A structure is not considered a ready-removable, and will be considered a one- or two-family dwelling by the SFMO, if all the following criteria is met:

  1. Only the structure’s exterior walls, floor, and roof systems are constructed off-site and are constructed in accordance with the 2018 International Residential Code (“IRC”); (These systems may include exterior components such as doors, windows, exterior wall coverings, and roofing materials necessary to weatherproof the structure. Bracing may be used for safe transport.)
  2. The structure has no electrical or plumbing systems installed at the time of transport;
  3. All structural components are visible at the time of transport; (Interior framing may be completed prior to transport, so long as all structural components remain visible.)
  4. The structure complies with all inspection, permit, and codes requirements applicable to one-and two- family dwellings; and
  5. The structure is placed on a foundation with a sill plate and follows the 2018 IRC R403.1.6 (refer to figure R403.1.3), or the structure is placed on concrete piers, with proper footings in place, and is anchored in accordance with a registered engineer’s design.

If a structure, as described above, is to be located in a jurisdiction that is monitored by either, or both, the SFMO’s electrical or residential codes programs, the structure will be subject to all permit and inspection requirements applicable to traditional one- and two-family dwellings if the structure is intended for residential use.

If a structure, as described above, is to be located in a jurisdiction that is monitored by a local building official for either, or both, electrical or residential codes, the structure will be subject to all permit and inspection requirements as designated by that jurisdiction.

If a structure, as described above, is to be located in a jurisdiction that has elected not to enforce a residential building code, the SFMO informs the retailer, manufacturer, and their consumers of the following information:

Tennessee Code Annotated § 68-120-101(b)(1)(B) allows a county or municipality to adopt a resolution to exempt the county or municipality from the application of statewide standards for one-family and two-family dwellings.

Further, Tennessee Code Annotated § 68-120-101(b)(1)(D) provides, “…[T]he owner of a building, structure, or premises located in a county or municipality that has taken action pursuant to subdivision (b)(1)(B) may request the state fire marshal inspect the building, structure, or premises to determine whether the building, structure or premises meets the statewide codes…”

Requesting a residential inspection from the SFMO will more easily facilitate the connection of electricity for the homeowner in many jurisdictions and is allowed under state law in opt out areas.

The homeowner can request a state inspection by purchasing a residential building permit. Information regarding purchasing a residential permit can be found at www.tn.gov/commerce/fire/residential-permits.