There Are More And More Wrecks With Modular Homes
The ICC 1215 standard has a transportation section that is promoting a type of trailer that they have named ”independent carrier system ” and they have given it an exemption from DOT requirements. There are more and more documented wrecks of this type of trailer. The image above shows that the modular fell of the trailer. They are not even using the term trailer, though that is exactly what it is. I have nicknamed the trailer the ‘Ghost Trailer’, because it is never in the NHTSA/DOT system. I have been compiling a incident report.
See incident report below. There are related blog posts on this topic if you need more of the back story and more details that I have linked below.
Crash Involving Modular Home: April 20, 2026
A three-car crash involving a truck carrying a modular home in Amesbury, Massachusetts, caused hourslong delays during the Monday afternoon commute. The collision occurred around 3:20 p.m. on the northbound side of Interstate 495 just south of Route 150. According to a Massachusetts State Police spokesperson, the crash involved a tanker truck, a trailer carrying a modular home, and another vehicle. There were no reports of any injuries, but the modular home rolled off the trailer and into the roadway. Sky5 was over the scene where the home could be seen sitting on its roof in the median of I-495.
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My Complaint To ICC
ICC's Reply
My Rebuttal To ICC
27 Email Exchange
NHTSA Interpretation Letter Modular Transport
Summary
ICC 1215 purposely put an exception provision ( To Support Their Silence So It Would Not Trigger Preemption) in the transportation section in ICC 1215 for the temporary carrier system the chassis so this type of chassis does not have to meet DOT or any other requirements of the ICC 1215 standard which shines a very bright light and blows holes in their argument about incidental use.
The temporary carrier system ( chassis) is fabricated strictly for the use of transporting modular structures and is the sole purpose of its use. The exception was added after I pointed out to them that it is an illegal ‘ghost trailer’ never in the NHTSA/DOT system and their silence will help continue this practice and is an intentional coverup.
A code or standard cannot lawfully avoid federal preemption through silence or omission. Where federal law occupies the field or establishes mandatory requirements, any subordinate standard that creates an alternate compliance pathway—without acknowledging or reconciling those requirements—is preempted, arbitrary, and procedurally defective as a matter of law.
ICC 1215 is addressing transportation in the standard with known federal and state laws in place, this is a due-process violation, not a neutral drafting choice to choose silence by omission.
ICC 1215: Chassis Silence or Regulatory Coverup?
On Dec. 9, 2025, I received a reply from the International Code Council regarding a complaint that I sent to them regarding that ICC 1215 was trying to override federal laws for the chassis in the standard and was in conflict with federal laws and ICC policy #49. A copy of my initial complaint and their reply to me is included after my letter.
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Silence Does Not Nullify Federal Law
Omitting NHTSA, SAE, FMVSS, and FMCSA does not avoid their application. Federal motor vehicle law is not optional, and it cannot be displaced by selective terminology or purposeful omission.
‘’DOT is the umbrella. Once it is invoked, the full federal transportation framework follows.’’
Conclusion From NHTSA Interpretation
Your second question is as follows: ‘ . . . we do manufacture some of these low-bed trailers, they are strictly for our own use in transporting our modular homes, and in this case are we required to submit this report and also label any trailers we would build in the future?’
Trailers are motor vehicles under the National Traffic and Motor Vehicle Safety Act and are required to comply with applicable standards. They are also required to be certified by the manufacturer in accordance with the Certification regulations (Part 567), and as a manufacturer of trailers you are required to submit the information specified in Part 566.; A copy of the National Traffic and Motor Vehicle Safety Act, and Part 566, 567, and 568 are enclosed, as is a notice describing how to obtain a copy of the motor vehicle safety standards.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
Relalted Blog Posts
ICC 1215 Is Promoting A ‘Ghost Trailer’ For Tiny Houses
I am getting ready to submit my comments to the first draft of the ICC standard called ICC/THIA Design, Construction And Regulation Of Small Residential Units And Tiny Houses For Permanent Occupancy and I have a lot to say about the Transportation section that is promoting a trailer and asking for an exception to any compliance requirements that is never in the NHTSA/DOT system, does not have a VIN number, it is not labeled, or certified by the manufacturer, is not titled, and is essentially a ‘Ghost Trailer’.
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ICC 1215: Satire On The Ghost Trailer That Leaves No Ruts
Much Needed Comic Relief : A Pause From The Battle For Tiny Houses
This blog post is centered around the International Code Council ICC/THIA 1215 tiny house standard written with much needed humor to lighten the heaviness and stress of the issues I will present. The blog post includes a short satire video explainer and the tale of The Little House In The Desert -A Wagon That Leaves No Tracks – A Western Satire Tale Of Tiny House Swindlin’, Rustled By Free-Wheelin’, Backdoor Dealin’ Small Residential Unit Rich Barons written in a spaghetti western theme depicting the Wild Wild West, sprinkled with lots of satire.
I will add relevant blog posts at the end if you need to get caught up on the main issues including how the standard was hijacked by the small residential unit and how ICC is disregarding and ignoring motor vehicle and HUD preemption and the very path that could lead tiny houses on wheels to compliance for mortgages and legal placement. ICC is purposely rerouting tiny houses through the small residential unit detour that will stifle the industry.
The result is a “ghost trailer”—a structure that moves through jurisdictions without being regulated as a motor vehicle or as a manufactured home, without a VIN, without registration at the DMV, and without a title.
The small residential unit, is arbitrary and unconstitutional, a whim of ICC, and has nothing to do with structural integrity, life and fire safety or for consumer protection for tiny houses.
This strategic move will cause a regulatory reset, squeeze out small artisan builders in favor of BIG Players in the industry.
The reset will cause a slow adoption of a 50 state patchwork of different regulations, exactly what preemption is in place to prevent for their market control and domination with the strategy of rebranding tiny houses.
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May 14, 2026
