Seattle DCI Tip #305 Factory Constructed Structures For Residential And Commercial Use PJF2 UNV( S) Cam305

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Tip

sdci

Seattle Department of Construction
and Inspections

305

Seattle Permits
— part of a multi-departmental City of Seattle series on getting a permit

Factory-Constructed
Structures for Residential
and Commercial Use
Updated December 22, 2005

Factory-constructed structures include both residential and commercial structures that are built off-site in
a factory and are later transported to a building site
for installation. The State Department of Labor and
Industries (L&I) regulates and approves the construction of all factory-constructed structures that are sold,
leased or used in Washington state. Site installation
requirements and inspections vary with the type and
use of the factory-constructed structure and are generally the responsibility of the local jurisdiction where
the structure is to be located.
This Tip describes the types of factory-constructed
structures allowed in Seattle, along with their permitting and inspection requirements.

PERMITTED RESIDENTIAL STRUCTURES
Two types of residential structures built in factories are
permitted in the city of Seattle if they comply with local
code requirements, such as structure setbacks, side
and rear yards, environmentally critical areas (ECAs),
and other development standards, including:
1. Factory-built structures (typically described as
manufactured housing) that are approved by L&I
with issuance of a red seal insignia certifying that
they meet standards of the federal Department of
Housing and Urban Development (HUD)
2. A type typically described as modular construction
(used for residential and non-residential purposes)
is approved by L&I with issuance of a gold seal
insignia certifying that it meets the standards of the
Washington State Building Code.

City of Seattle
Department of Construction and Inspections

The City of Seattle’s Comprehensive Plan, adopted
in July 1994, and updated in 2004, states in Housing
Policy H19:
Allow the use of modular housing, conforming to
the standards of the State of Washington building and energy codes, and manufactured housing, built to standards established by the Federal
Department of Housing and Urban Development.
Modular and manufactured houses shall be permitted on individual lots in any land use zone where
residential uses are permitted.

Red Seal Housing Insignia
Factory-constructed housing with a red seal insignia
(typically referred to as manufactured housing or "red
seal housing") is regulated through the National Manufactured Home Construction and Safety Standards
Act of 1974 as administered by HUD. The act sets
minimum construction standards that preempt local
and state building codes for all manufactured housing built after June 15, 1976. The red seal is issued
through L&I, which inspects the factories assembling
manufactured housing to certify compliance with HUD
standards. This approval also applies to the plumbing, heating, electrical and other components within
the structure.
Red seal housing has two separate information plates.
The first, a red seal insignia, is discussed below. The
second is a data plate, located near the main electrical panel, which lists important information about the
home itself, including where and on what date the
home was built, a list of major equipment installed in
the home, and the structural earthquake zone and
wind loads for which the home was designed.
The red seal insignia must be attached to each transportable section of manufactured housing, located
at the tail light end of each section. It is a 2” x 4”
label on aluminum, stamped with a number composed of three letters followed by six digits (e.g., ABC
- 000001). The three letters identify the inspection
agency responsible for inspecting a manufactured
housing factory.

www.seattle.gov/sdci
700 5th Avenue, Suite 2000
P.O. Box 34019
Seattle, WA 98124-4019
(206) 684-8600

Printed on totally chlorine-free paper made with 100% post-consumer fiber

SDCI Tip #305—Factory-Constructed Structures for Residential and Commercial Use

All building plans, subsequent alterations to building
plans, and construction of red seal housing must be
approved by L&I. If alterations to the housing structure are made prior to or during installation or after
occupancy without L&I approval, the red seal insignia will be invalidated. Manufacturers who wish to
alter red seal housing must revise the building plans
and resubmit them to L&I for reapproval. If an owner
wishes to alter a red seal structure after occupancy,
and applies for a permit to make such alterations, the
Seattle Department of Construction and Inspections
(Seattle DCI) requires either proof that such alteration
has been L&I-approved prior to permit issuance or
that the plans have been approved and stamped by a
licensed engineer or architect.

Is a foundation required?
Although red seal housing may not be required to
be placed on a foundation, the HUD standards do
require the manufacturers to make provisions for both
an anchoring system and a foundation to be used for
installation by a HUD-certified installer. The manufacturer is not, however, required to provide the anchoring system or stabilizing devices. Owners should look
at the manufacturer’s instructions for more information.
HUD standards include specifications for foundations.
By design, red seal housing can be used with or
without a permanent foundation conforming to the
Seattle Building Code (SBC). Additional information
on permanent foundations for manufactured housing
can be ordered from HUD at 1-800-245-2691, or the
information can be accessed at www.hudclips.org.
At time of purchase, a lending institution may require
the use of a permanent foundation conforming to the
SBC. Seattle DCI recommends that owners install
factory-constructed structures on a permanent foundation. The Federal Housing Administration (FHA)
and the Veteran’s Administration (VA) are two lending
institutions that require a permanent foundation with
manufactured housing. (NOTE: Please check with
your lender before installation.)

What are mobile homes?
Mobile homes are factory-constructed housing built
before June 15, 1976, when the HUD Manufactured
Home Construction and Safety Standards went into
effect. There will be no red seal insignia on mobile
homes, and they do not meet local building code
requirements. In Seattle, mobile homes are typically
located in established mobile home parks.

page 2

Gold Seal Insignia
Factory-constructed structures with a gold seal
insignia (typically referred to as modular or “gold
seal buildings") are regulated by state standards for
housing body and frame construction as determined
by state law (Washington Administrative Code 296150B). Gold seal buildings may be used for commercial or residential uses. The structure must
comply with the Washington State Building, the Mechanical, the Plumbing, and Energy codes, and must
be placed on a permanent foundation conforming to
the SBC. The gold seal insignia must be placed on or
near the meter base or near the location where electrical service enters the structure.
If alterations to the gold seal structure are made before occupancy without the prior approval of L&I, the
gold seal insignia will be invalidated. Manufacturers
must resubmit a building plan and design for approval. Approved alterations will be added as a data plate
on the gold seal building. The additional data plate
will state what alterations have been made and the
date of approval. Alterations made after the gold seal
building is occupied are subject to the review and approval of the local jurisdiction.
In summary, gold seal buildings differ from red seal
housing in three important ways:
1. Gold seal buildings must be installed on a permanent foundation.
2. Gold seal buildings are built to the Washington State
Building, Mechanical, Plumbing and Energy codes.
3. Gold seal buildings are built according to the state
L&I construction standards, as opposed to HUD
construction standards.

PERMITTED
NONRESIDENTIAL STRUCTURES
A factory-constructed structure built for nonresidential
use (typically referred to as a commercial coach) is
approved by L&I with issuance of a black seal or gold
seal insignia certifying that the structure was manufactured in compliance with state standards.

Black Seal Insignia
Nonresidential factory constructed structures with a
black seal insignia are called commercial coaches.
The black seal insignia certifies that the structure is
manufactured in compliance with state standards.

LEGAL DISCLAIMER: This Tip should not be used as a substitute for codes and regulations. The applicant is responsible for compliance
with all code and rule requirements, whether or not described in this Tip.

SDCI Tip #305—Factory-Constructed Structures for Residential and Commercial Use

page 3

Table 1: Comparison of the Three Types of Factory-Constructed Structures

Insignia
Required
Red Seal
(Manufactured
Housing)2

Use
Residence

Gold Seal
Residence or
(Modular
Non-Residence4
Construction)2
Black Seal
(Commercial
Coaches)

Non-Residence
(Temporary Only)

Construction
Code
Requirements

Construction
Location1

Who
Inspects
Construction
in Factory?

Who
Inspects the
On-Site
Structure?

Federal Housing
and Urban Development (HUD)

Factory

State Labor and
Industries (L&I)
for HUD3

City of Seattle

Washington State
Building Code

Factory

L&I

City of Seattle

Washington
Administrative
Code Commercial

Factory

L&I

City of Seattle

Construction of that portion of the structure above the foundation.

Manufactured housing and modular construction for residential purposes are frequently used terms to describe certain
types of factory constructed housing, but these terms are often misused and not consistently defined. Due to this
problem, the L&I insignia system is used in this Tip to distinguish between types of factory-constructed housing.

L&I inspects the assembly of factory-constructed structures for manufacturers in Washington State. Factory-constructed
structures assembled in other states would be inspected by the state agency acting for HUD.

Gold Seal could be commercial if constructed to commercial requirements.

Commercial coaches must comply with the Washington State Building Code (for occupancy determination), the State Mechanical, Plumbing, the Energy
codes, as well as other standards outlined in Washington State Law (WAC 296-150B). Coaches must
be placed on a permanent foundation conforming
to the Seattle Building Code. This insignia can be
found adjacent to the entry door, at least 12 inches
above the floor line.

tant information about the non-residential structure,
such as where and on what date the structure was
manufactured and an assigned identification number
for the structure.

Gold Seal Insignia
See information about permitted nonresidential structures in previous Gold Seal section on page 2.

Commercial coaches can only be used as temporary
structures designed for human occupancy for industrial, educational, assembly, professional or other
commercial purposes. They can include temporary
office buildings and portable school classrooms.

LOCAL REGULATORY REQUIREMENTS:
PERMITS, FEES AND INSPECTIONS

Commercial coaches that are portable classrooms
have additional requirements for ventilation, heating,
cooling and temperature-control systems. These
systems must be designed by a professional engineer
registered in the state of Washington and experienced
in the design of heating, ventilating and air conditioning systems.

In order to install a factory-constructed structure on a
site, you must apply for a building permit from Seattle
DCI's Applicant Service's Center (ASC), located on
the 20th floor of Seattle Municipal Tower at 700 Fifth
Ave. in downtown Seattle, (206) 684-8850. There are
different requirements for each of the three factoryconstructed structures. (See Table 2 on page 6.)

In addition to the black seal insignia, commercial
coaches have an identification plate which lists impor-

Building Permit Requirements

Please note that with your building permit application,
you will be asked to supply two sets of the plans and

SDCI Tip #305—Factory-Constructed Structures for Residential and Commercial Use

specifications for the factory-constructed structure
providing verification of design and construction approval from L&I. The design drawing must include
foundation details.
A site plan of the site showing the location of the
factory-constructed structure with setbacks and yard
requirements noted is necessary to ensure compliance with the Seattle Land Use Code.
Installation does not cover any additions or accessory structures, unless specifically included in the L&I
approvals, such as a deck, porch, carport or garage,
since these elements are typically constructed on-site.
If you are planning to add accessory structures on
the site, you will need to include information relating
to these in your application to erect the base building
or subsequently obtain an additional building permit
from Seattle DCI. If accessory structures are partially
supported by factory-constructed structures, such additional loads must be included in the L&I approvals.

page 4

certification number of the certified installer. Seattle
DCI cannot issue the permit without this information.

Additional Requirements for
Black Seal Commercial Coaches
According to the SBC, commercial coaches may be
installed as temporary office or other uses approved
by the building official for 18 months. A permit for a
commercial coach used as temporary office space
may be renewed and an inspection made to ensure
continued compliance with the SBC and the Land
Use Code. Commercial coaches may be placed on
a temporary foundation, meeting the requirements in
SBC Section 106.13, and must be anchored to resist
wind and seismic forces.

Other Permits Required
Installation of factory-constructed structures may
require some or all of the following:

Additional Requirements for
Red Seal Housing

n Curb cut permit from Seattle DCI if there will be a

As of July 1, 1995, red seal housing may not be installed in Washington without a certified manufactured
housing installer providing on-site supervision whenever installation work is being performed.

n Gas piping permit from Seattle - King County Dept.

Exceptions are allowed for homeowners performing
installation work on their own homes. Installation is
defined as all on-site work necessary for the installation of red seal housing, including, but not limited to,
construction of the foundation (if any), support piers,
anchors, skirting and connections to the water and
sewer systems. It does not include site preparation
or accessory structures that are constructed, such as
garages, carports and decks, which are items subject
to Seattle DCI inspections. Seattle DCI will inspect
the foundation when it meets SBC standards.
When the foundation does not meet SBC standards,
Seattle DCI may require an independent inspection by
a person knowledgeable with the federal standards
(an architect, engineer or other licensed professional
certified by L&I). After the inspection, this independent inspector will be required to submit a letter to
Seattle DCI attesting that the installment meets federal
standards, as administered by L&I.
Red seal housing must be installed per the manufacturer’s instructions, which are approved by HUD. A
building permit application must include either the
name and registration number of the contractor or
licensed manufactured home dealer or the name and

new driveway cut.

of Public Health, if gas appliances will be installed.

n Plumbing permit from Seattle - KC Dept. of Public

Health if any plumbing is added to the structure.

n Service connection from Seattle City Light.
n If the permit includes any excavation, a Seattle DCI

Construction Stormwater Control Plan and/or Drainage Standard Plan will be required.

n A side-sewer permit from Seattle DCI is required

for new sewer hookups.

n If your factory-constructed structure will be located

in an ECA, plan review will be required and the
foundation plan might be required to be designed
by a licensed structural engineer and must be approved by a geotechnical engineer licensed by the
state of Washington. A soils report prepared by
the geotechnical engineer will be required. To find
out if your site is in an ECA, visit Seattle DCI's ASC.

Fees
For information about building permit fees for factoryconstructed structures, refer to the Fee Subtitle or
contact the Seattle DCI Public Resource Center at
(206) 684-8467. You may also find current fee ordinance information online at www.seattle.gov/dpd/
codesrules/codes/fees/.

SDCI Tip #305—Factory-Constructed Structures for Residential and Commercial Use

page 5

Inspection Requirements

Important Information to Remember

After the factory-constructed structure has been sited,
you will need to schedule an inspection. Seattle DCI
inspects the structure to ensure that it has been properly sited and meets all applicable code requirements.
Manufacturer’s instructions must be at the site for an
inspector to review during the inspection. Call Seattle
DCI at (206) 684-8900 to schedule an inspection.

n Make sure that you get a building permit to install

The following list includes inspection requirements for
factory-constructed structures, organized by the City
department responsible for the inspection. (These
requirements may vary depending on the type of
structure installed.)
Seattle Department of Planning and
Development: (206) 684-8850
n Inspection of yard and setback requirements
n Inspection of permanent foundation (when required)
n Inspection of electrical hookup
n Inspection of site grading
n Inspection of side sewer
n Inspection of stormwater control used during con-

struction/installation

n Inspection of any required infiltration pit or com-

mercial parking lot drainage

Seattle Transportation: (206) 684-5283
n Inspection of driveway cuts

Seattle Public Utilities: (206) 684-5800
n Inspection of water hookup

Seattle-King County Department of Public Health:
(206) 296-1175
n Inspection of plumbing and gas piping

all factory-constructed structures. In addition, if
you are adding porches, decks, or garages, you
must get a building permit for those additions. If
desired, multiple related permit requests could be
combined together under one permit for all activity on the site. For more information, visit the ASC
(see location at right).

n All factory-constructed structures must have an L&I

insignia plate.

n Alterations to any of these structures must have

prior approval from L&I. If prior approval is not
obtained, the insignia approval is no longer valid.

n If you are purchasing a red seal housing structure,

you will want to check with your lending institution
for additional installation requirements. The FHA
and VA have additional requirements for foundations for manufactured housing.

n Make sure the site you have chosen is suitable for

your factory-constructed structure. The site must
have adequate drainage and load-bearing capacity. In addition, be aware of any Land Use and
Zoning Code restrictions, such as ECAs and building setbacks.

n If you are planning to install a solid-fuel burning

appliance (such as a wood stove or pellet stove),
you must have a UL-listed appliance specifically
for use in manufactured housing. Please see Tip
416, Installation Requirements for Wood, Coal and
Other Solid Fuel Burning Appliances. For more
information call the Seattle DCI Electrical Permit
Counter at (206) 684-8464.

n Remember that black seal commercial coaches are

intended for temporary uses, not as a permanent
structure.

Access to Information
Links to electronic versions of Seattle DCI Tips,
Director's Rules, and Forms are available on the
"Tools & Resources" page of our website at www.
seattle.gov/sdci. Paper copies of these documents are available from our Public Resource Center, located on the 20th floor of Seattle Municipal
Tower at 700 Fifth Ave. in downtown Seattle, (206)
684-8467.

SDCI Tip #305—Factory-Constructed Structures for Residential and Commercial Use

page 6

Table 2: Installation Requirements for Factory-Constructed Structures
City Permits
and Information
Required

Types of Factory-Constructed Structures
Red Seal Insignia

Gold Seal Insignia

Black Seal Insignia

Expedited review (ER),
with installation
certification per L&I
requirements

ER, but more extensive
plan review may be
required for difficult
sites or complex
foundation plans

Site Plan
(see SDCI Tips #103
and #103A)

Yes

Site Drainage Plan

Yes

Site Grading Permit
(Excavation Plan)

If exceeding grading
threshold, or if located
in an ECA

If exceeding grading
threshold, or if located in
an ECA

Structure Foundation
Plan

Yes

Copy of L&I
Approved Factory
Constructed
Structure Plans

Yes

Electrical Permit
from SDCI

Yes

Certificate of
Water Availability
from Seattle
Public Utilities

Yes

Plumbing
Permit from KC
Public Health Dept.

Yes

Site Inspection by
SDCI Inspector

Yes

Yes, except special
inspections required
for HUD foundations

Yes

Type of Building
Permit Required
from SDCI

Foundation
Inspection by
SDCI Inspector

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