WA State Labor & Industries Info 

Think of L & I as Washington's "building department" for mobile structures.

Mobile structures are regulated by L&I for such things as electrical wiring, the water supply and waste water systems, and any mechanical systems such as gas piping or heating and cooling equipment.  It is not L&I's jurisdiction to regulate what elements you might need to satisfy health department requirements — the health department can require a hand-washing sink, for example — but it is L&I's responsibility to be sure it is plumbed correctly.  A Conversion vendor unit or "Conversion vending unit" does require the L & I insignia and means a motor vehicle or other structure that has been converted or built for the purpose of being used for commercial sales at temporary locations. The units must be 8 feet 6 inches or less in width (exterior floor measurement) in the set-up position, and the inside working area must be less than 40 feet in length (interior floor measurement). Conversion vendor units:

• Are transported in only one section;

• Are designed for highway use;

• Are temporarily occupied for distribution of items, e.g., food;

• Are built on a permanent chassis; and

• Include at least one of the following systems: Plumbing, mechanical or 120 and/or 240 volt electrical.

Our state building code for mobile food units can be located in the Vendor Packet found here. 

Mobile Food Units are governed by the Factory Assembled Structures Department of L & I: WAC 296-150V See WAC 296-150V-0800 for a list of code standards that are applicable to Vendor Units.

International Building Codes (WAC Chapter 51-50)

International Mechanical Code (WAC Chapter 51-52)

Find an Inside Look at the LNI Program here….https://www.youtube.com/watch?v=xqeZwQvJMYc

Here's the process for getting your Vendor Unit plan approved and the work inspected and approved by L&I: Please be advised the planning process should always proceed the build / construction process. Constructing a unit before the plans have been approved reverse engineers the process often resulting in additional costs, additional plan review and inspection time to the applicant.

1.  First, you need to create a plan and submit it to L & I (or one of the few 3rd party licensed pros, see the new emergency rule below) for review.

2.  Next, L&I must review and approve your plans before you start the construction work.

3. Then, L&I must inspect and approve the work you've done. (The review & approval process can take 8-weeks or more depending on their current backlog and your need for resubmittals.) If you had one of the few 3rd party licensed pros approve your submiited plans, it will be a local/regional L & I employee that will do the on site physical inspection and issue you the insignia that is needed for your annual county health permit. For most plans the one year design plan application fee is selected. If multiple units are constructed from a single plan the master design plan option is selected. An insignia fee must also be submitted for each insignia application.

   Please know, it is required by our state food code to submit to county health for plan review approval: 09110 Plan review. The owner of a MOBILE FOOD UNIT shall submit a properly prepared plan of operation with specifications of the MOBILE FOOD UNIT, COMMISSARY, and SERVICING AREA to the REGULATORY AUTHORITY for (plan review ) approval before: Beginning a construction or remodeling project.

Find the vendor inspection checklist here.   

L & I has two application types: 

1. Limited System “Plan Exempt” Vending Unit and Inspection (this application type does require the L & I insignia, is not exempt from code compliance although no plans are required) for vending units that qualify based on the following criteria found on the L & I page here: https://lni.wa.gov/licensing-permits/manufactured-modular-mobile-structures/food-trucks-trailers/#need-to-submit-plans

Inspections are required.  A single form application is to be submitted with a fee for the screening and insignia.  Inspections are priced by the hour, plus travel (the total fee is assessed at the time of inspection, these fees are invoiced after the inspection due to the unknown time involved).  

Don't need to submit plans? You still need an inspection. Food trucks need to be inspected to receive an L&I insignia. You need an inspection before starting your food truck business.  You cannot receive your county health department operating permit without the L&I insignia. Please contact 800-705-1411 (Option 3) for the plan review staff or call: 360-902-5218.

2. Standard Plan Review for Approval and Inspection:  Design plans for conversion vendor units and medical units are required for units that are sold, leased, or used in Washington state and must be approved when vendor units contain one or more of the following components:

(a) Concentrated loads exceeding five hundred pounds (see WAC 296-150V-0930);

(b) Fuel gas piping systems and equipment;

(c) Solid fuel burning equipment;

(d) Fire suppression systems;

(e) Commercial hoods;

(f) Electrical systems and equipment in excess of 30 amps/120 volts;

(g) Electrical systems with more than five circuits;

(h) Electrical systems incorporating photovoltaic energy, fuel cell energy, or other alternative energy systems;

(i) Plumbing drainage systems conveying solid or bodily waste.

(2) Medical units.

(3) Modification of an approved design plan through addendums;

(4) Addition of options to an approved design plan through addendums.Includes all systems and requires complete plans of the systems to meet the regulations. 

The fee for plan review and insignia is to be submitted with the plans.  Once the plans are approved the applicant can schedule the regional inspection.  The insignia is issued to the local inspector for inspection verification.  Inspections are by the hour plus the same for travel (the total fee is assessed at the time of inspection and if other required inspections are needed, these fees are invoiced after the inspection due to the unknown). 

Not sure if you need to submit plans for approval? Check here: https://lni.wa.gov/licensing-permits/manufactured-modular-mobile-structures/food-trucks-trailers/#need-to-submit-plans

Everything you need to know about how to build your truck or trailer can be found in the vendor plan review packet here. Read this doc all the way through.

** Be sure to follow the application instructions and the example pages they provide. Do not leave any blanks.

The Fee chart for Vendor units can be located here: https://apps.leg.wa.gov/WAC/default.aspx?cite=296-150V-3000

Alterations

If you have just purchased or already own a mobile food unit (truck or trailer) that has its original L & I insignia but you are changing out commercial equipment, rewiring, or making other significant plumbing or mechanical changes, you do need to submit an “alteration plan” that needs to be approved, learn more here: https://lni.wa.gov/licensing-permits/manufactured-modular-mobile-structures/food-trucks-trailers/food-truck-alterations#what-changes-require-a-permit

Send the “Insignia Application” form in along with a photo of your current insignia via email to: FAS1@lni.wa.gov and tell them what you are altering on your already L & I approved mobile and need a regional inspection. Send in this form here: https://lni.wa.gov/forms-publications/F623-040-000.pdf (Check the new label request box.) There is a fee for this of $131.60. Find the code for alterations here: https://app.leg.wa.gov/WAC/default.aspx?cite=296-150V-0020 

New Code 2024 -

(will take effect March 2024) requires mobile food units to have a visual and audible alarm installed on the exterior of the vehicle when the ansul (fire suppression) system is triggered (Per IFC 904 and NFPA Chapter 11 (11.5.2). It will only apply to new or altered units with L & I plan approvals on or after that date.

All L&I approved plans for vendors units (food trucks, trailers, and similar) approved under the WAC 296-150V and in accordance with the 2018 code cycle are valid one year from date of approval. You can tell if your plan was approved under this code cycle if the plan approval number begins with the number 18 (such as 18VEN…). If you have an approved 2018 code cycle “master plan” it expires with this code cycle (valid through March 14, 2024). Units already in production must be completed – including final inspections – by June 15, 2024.

L & I will be reviewing to the new code cycle for all “one year” plans submitted after March 14th, 2024. Any new “master” plans submitted after this notice will need to be compliant with the new code cycle provisions, if/as applicable, including the sections of WAC 51-54A-0904 that take effect on July 1, 2024.

DOWNLOAD the LNI NEW VENDOR Code Cycle Information for 2024 here.

3rd Party Review Approvals-

(issued January 2022) to address backlog of plan reviews. This new rule allows other 3rd party licensed professionals to do the plan review approval with an L & I plan review fee. This plan review fee charged by L & I is in addition to the fees you will pay the 3rd party professional. Please email us for the list of licensed pros approved by L & I. As of 12/2022, the emergency rule has been extended to April 14, 2023. As of 10/22, L & I has indicated they are no longer backed up by plan reviews and there is a normal 4-8 week wait time. Learn more about this here: https://lni.wa.gov/licensing-permits/manufactured-modular-mobile-structures/modular-other-mobile-structures/

If you plan to use a 3rd party approved licensed professional, you must use this document for guidance. You can find a list of those approved here: https://lni.wa.gov/licensing-permits/_docs/LicensedProfessionalList.pdf

If you have submitted plans for review approval directly to L & I but then you or your builder decided to submit your plan review to a 3rd party professional, you do still need to notify L & I and request a partial refund. L & I will not be aware of your 3rd party plan review submittal until that 3rd party receives an approval and you move forward for inspection and therefore you remain in their backlog que of vendor aps.

If you want to cancel your L & I plan review and have the review done by a 3rd party licensed professional, you need to submit this request in writing via email to FAS1 (FAS1@lni.wa.gov). The email needs to request that they refund any unused fees and be clear about which plan or plans they are referring to, by providing the FAS plan number, mfg. job number, the mfg. serial numbers or project name. All or part of the FAS fees will be refunded depending on whether your plan review was started. The program will destroy any unneeded physical copies of the plans unless the manufacturer instructs in the email to mail the plan sets back to them. The plan review has not been started or the manufacturer has a new plan needing review. • The plan will be “voided” and fees refunded to the mfg. This would include a refund of the insignia fees. When the LP approved plan is submitted, it will be assigned a new FAS approved plan number and processed per the standard LP plan submittal and intake procedures.

Plan reviews from approved Licensed Professionals (LP) can serve as the required plans that you & your builder must have to obtain an FAS regional inspection. This document provides general guidance for the licensed professionals and builders about the typical drawings and other information that must be submitted in the professionally approved plans for Vendor Units.

LP Tank Mounting Requirements: For LP cylinders and tanks on food trucks/trailers, L & I will use the same requirements as for RV’s found in NFPA 1192 section 5.  You can email L & I for the code mounting requirements. Liquid propane (LP) tanks must be located in one of three places. On trailers, they can be mounted on the front towing hitch, like an RV trailer. The tank must not extend past the side of the hitch where it might be damaged by the towing vehicle during a turn. On trucks or trailers they can also be mounted either under the floor like a motor home or they can be mounted inside a sealed compartment that is within the body of the truck or trailer and accessed from the outside.

Per L & I as of 4/17/24 - Here are the requirements for rear mounted propane tanks, after review of NFPA 58 and discussions with the state fire marshals association they are allowed under the following conditions:

NFPA 11.8.1 Location of LP Containers - 11.8.1.1 Containers shall be located as to minimize the possibility of damage to the container and its fittings. 11.8.1.2 Where containers are located in the rear of the vehicle they shall be protected. Rear mounted LP tank cages must be designed by a Washington State engineer to equivalent protection of other approved locations. Engineered plans must be submitted and are part of LNI plan review. 11.8.3 Containers shall not be mounted directly on roofs or ahead of the front axle or beyond the rear bumper of the vehicle. Indicate LP cylinder locations to be a minimum of 5 feet from any source of ignition (i.e. shore power connections, generators, electrical panels, outlets, appliances that are direct vent (sealed combustion) intake/vent (i.e. gas water heater), etc. from the discharge of the pressure relief device per NFPA 58 ‐ 6.8.1.6 & Table 6.3.4.3. Ensure the LP cylinder locations are a min. of 3 feet horizontally from any opening that is below the level of the discharge of the pressure relief device per NFPA 58 ‐ 6.8.1.5 & Table 6.3.4.3. Find the exact code language here: https://app.leg.wa.gov/WAC/default.aspx?cite=296-150V-1350

Generator Placement/Mounting: you will indicate on your L & I plans where the generator is located, that it is sealed in a vapor resistant enclosure from the interior, that it is not directly connected to the system unless listed for the connection (RV listed) or installed through a listed system. Indicate if the generator is connected by use of the shore power cord when the electrical system is not connected to shore power service. Provide the make and model of the generator. Indicate that the generator is secure against displacement per the manufacturer’s recommendations. Indicate if it is permanently installed and that it is installed in a 26 MSG minimum galvanized steel or better compartment that it is vented properly per the manufacturer. NFPA 1192 ‐ 6.4.5 & NEC 551.30. Check with your local fire authority for the allowance of permanently mounting a generator to your trailer tow frame.

Built-In Generators: must be listed for RV use, hard wired, with a listed transfer switch into the electrical system. Regardless of what health departments have approved in the past, they are becoming increasingly more concerned about how food trucks are able to maintain hot/cold temps while in transit, and they will be asking questions about how units are powered while in transit. They will very likely deny trucks that plan to use gas powered generators while in transit. You are best off to hardwire onboard appliances, just like an RV, using the power provided by the engine while in transit. Additionally, the fire department has a problem with running generators on a moving vehicle.

Re Smokers - Per L&I: Smokers and bbq units must be listed appliances (NSF, UL, ETL etc.) for interior use (just as all other appliances for cooking), vented or other (under hood possibly) per the manufacturer recommendations and provided with the required clearances in place per the manufacture. This is even if on the back (porch or patio unit) as this is considered the envelope interior area under the roof / shell of the trailer. Many smokers / bbq units are not listed and do not comply and are technically not legal to function on the trailer. Often we find people hauling them on the back then removing and operating the units on the ground and this is ok from our L&I regulations as its not on the trailer. These have high probability of fire and are unsafe when not listed. Make sure you have your county health plans approved for a smoker first before doing construction as not all counties allow them, and check with the local fire authority for permitting.

Re Wood Fire Pizza Ovens: At this time, it is a good idea to get your local fire marshal to inspect your mobile plans and get in writing if the local fire marshal may still require a hood and/or fire supression system, while looking at the differences between the 2015 and 2018 codes. L & I's request for documenting this code path is optional however it provides the basis for discussions with authorities if local fire inspectors question the pizza oven installation in the approved unit. In the absence of local codes, installation must conform to the National Fuel Gas Code, ANSI Z223.1/NFPA 54, Natural Gas and Propane Installation Code, CSA B149.1, or Propane Storage and Handling Code, B149.2, as applicable.

Gas System Testing: Per WAC 296‐150V‐1450 & WAC 296‐150V‐1460 the gas piping shall be tested and documentation of these tests shall be provided to the inspector upon inspection. See the code sections indicated for specific testing standards. Acceptable documentation: A completed ‘Affidavit of Testing’ supplied by Washington State Labor & Industries FAS Plan Review OR a test report with the testing agent’s official letterhead and contact information. The test is to be performed by a third party agent and the testing information is to be supplied to the inspector upon inspection. Any registered contractor can provide the test if they have the equipment and the skill. They also sign the affidavit if witnessed by the unit owner.

Re Power Supply Cords: Unless only a generator or the truck engine supplies power, a correctly sized RV power supply cord must be used.

• Food trucks/trailers with one 15 amp circuit may have a 15 amp / 120 volt (2 wire with ground) RV supply cord and a 15 amp circuit breaker in the panel.

• Food trucks/trailers with one 20 amp circuit may have a 20 amp / 120 volt (2 wire with ground) RV supply cord and a 20 amp circuit breaker in the panel.

• Food trucks/trailers with up to five 15 and 20 amp circuits may have a 30 amp / 120 volt (2 wire with ground) RV supply cord and a 30 amp main breaker in the panel.

• Food trucks/trailers with more than five 15 and 20 amp circuit must have a 50 amp / 240 volt (3 wire with ground) RV supply cord and a 50 amp main breaker in the panel.

Regarding the Structural Load- (code: 296-150V-0930)

When are structural load tests or structural calculations required?

(1) A structural analysis is required when a unit has a concentrated floor load of 500 pounds or more in a 16 square feet or less area.

(2) The structural load test can be used as an alternative.

(a) A structural assembly tested for qualification must sustain the design dead load plus the superimposed design live loads for vendor units and medical units assembly.

(b) An assembly failure is defined as a rupture, fracture, or residual deflection which is greater than the limits.  

An engineer needs to check the floor to be sure it can support the weight. If you need to hire an engineer, our members have been referred to: By Design Engineering, located here in Wa.

Size limitations: Mobile units must be 8 feet 6 inches or less in width (exterior floor measurement) in the set-up position, and the inside working area must be less than 40 feet in length (interior floor measurement).

Direct versus Indirect Drain/Sink Requirements: Any sink that is indicated on the plans as a food preparation sink would be required to have an indirect drain connected and L & I will inspect them that way. Here is what the plumbing code says: (from the 2018 UPC Illustrated Training Manual, Chapter 8, INDIRECT WASTES) 801.3.3 Food-Handling Fixtures. Food-preparation sinks, steam kettles, potato peelers, ice cream dipper wells, and similar equipment shall be indirectly connected to the drainage system by means of an air gap. Bins, sinks, and other equipment having drainage connections and used for the storage of unpackaged ice used for human ingestion, or used in direct contact with ready-to-eat food, shall be indirectly connected to the drainage system by means of an air gap. Each indirect waste pipe from food-handling fixtures or equipment shall be separately piped to the indirect waste receptor and shall not combine with other indirect waste pipes. The piping from the equipment to the receptor shall be not less than the drain on the unit and in no case less than 1/2 of an inch (15 mm). Any fixture, appliance or piece of equipment, such as an ice cream dipper well (see Figure 801.3.3), that can contain or may come in contact with food is required to be indirectly wasted through an air gap only. This is to keep any possible contaminates from coming into contact with food, items that may contain food, or any utensils used to eat food. Not doing so could cause a severe health hazard, so the installer should be well aware of the regulations governing such installations. Ice-maker storage bins or storage containers for ice are also considered food storage equipment. The drain must discharge its waste through an air gap. The size of the indirect waste pipe shall be no smaller than the drain of the container but in no case smaller than one-half of an inch. The indirect waste pipes from this equipment may not combine with other indirect wastes; they must be individually piped to the receptor.

Hood Types - Type 1 hoods are designed to be used with appliances that produce greasy by- products and smoke created while cooking. Type 1 hoods primarily deal with the removal of grease particles from the air they are often referred to as Grease Hoods. Type 1 hoods are often located above deep fryers, cook tops, open-flame stoves, conveyor-pizza ovens, char broilers, and more – basically kitchen equipment that are used to cook greasy foods. Because of the grease and grease by-products that are captured by the Type 1 hoods it is suggested to perform more regular cleanings on the types of hoods to help prevent damage and fire risks that can occur due to grease build up. Find the fire inspection information for this type of hood here.

Type 2 Hoods focus on other types of kitchen appliances and equipment that don’t have to pertain directly to cooking. This type of equipment includes dishwashers, ovens, pasta cookers, and other equipment that doesn’t produce any smoke or grease that would need to be extracted. Since Type 2 hoods particularly deal with the removal of heat and steam from the air they are often referred to as Condensate Hoods and Heat Hoods. The Type 2 Condensate Hood is designed with a full perimeter gutter and drain to capture the condensation from steam that is exhausted. These types of hoods are used to clear the air from excess heat and moisture and help to create a more comfortable work environment. If the mobile food unit does not have a gas system, generator, a fire suppression system, gas or solid fuel burning appliances and the electrical system is 30 amps or under then applicants qualify as plan review exempt. Because a type 2 hood is for removal of steam vapors only and does not require a fire suppression system the unit would still qualify as plan exempt.

Fire Certifications - if you buy your mobile from out of state and need to have the fire supression system certified by a NAFED professional, see the Washington State fire listings here: https://web.nafed.org/directory/results/results.aspx?State=WA

Alternative Automatic Fire-Extinguishing Systems - if you buy your mobile from out of state or buy a mobile that still needs a fire suppression schematic/drawing, you can contact: Fire Performance Systems Integration

Per WAC 51-54A-0904:

904.1.1 Certification of service personnel for fire-extinguishing equipment. Service personnel performing system design, installation or conducting system maintenance or testing on automatic fire-extinguishing systems, other than automatic sprinkler systems, shall possess the appropriate ICC/NAFED certification.

904.1.1.1 Pre-engineered kitchen fire-extinguishing systems. A current ICC/NAFED certification for pre-engineered kitchen fire-extinguishing systems is required when performing design, installation, inspection/testing or maintenance on kitchen suppression systems.

904.1.1.2 Engineered fire suppression systems. A current ICC/NAFED certification for engineered fire suppression systems is required when performing design, installation, inspection/testing or maintenance on kitchen suppression systems.

Makeup Air - Eff. 2024, There is no code path for L & I to incorporate NFPA Chapter 4 “General Requirements for Cooking Operations in Buildings and Mobile and Temporary Cooking Operations” , the chapter that would include the requirements for makeup air. This would fall under the Fire Marshals authority and could vary from one jurisdiction to the next. L & I is meeting with the Fire Marshals Association and are working for consistency on the requirements throughout the state.

Plan Rejection

8-10 plans are initially rejected. Per L & I, here are the top reasons plans submitted fail. These are items that are either missing or incomplete that cause plan rejection. Design professionals and experienced builders usually will have these issues resolved. It’s the novice builder or designer or applicants that do not use design professionals that have the most problems.

WAC150V (Electrical) Provide specs for generator.

WAC150V (Electrical) Provide specs for transfer switch & schematic for the generator shore power system interconnection.

IMC 507.2 (Mechanical) Need manufacturers spec sheets on all appliances, including water heater.

UPC 601 (Plumbing) Need spec sheets for water pump.

NEC 220 (Electrical) Provide load calculation for electrical system & include panel directory, wiring schematic and raceway type used.

IMC 507.2 (Mechanical) Type I hoods shall bear a label indicating the minimum exhaust flow rate in cfm per linear foot (1.55 L/s per linear meter) of hood that provides for capture and containment of the exhaust effluent for the cooking appliances served by the hood, based on the cooking appliance duty classifications defined in this code. Need to provide all specs on hood including label.

IMC 101.2 (Mechanical) Provide gas piping schematic & include gas piping sizing & materials used.

IMC 506 (Mechanical) Provide specs on fire supression system.

IMC 507.2 (Mechanical) Provide specs on hood fan.

L&I Risk Classification Codes

If your food truck is not moving to different locations during the day, all operations are reported under code 3905, with a base rate of .44.  Code 1101 - (base rate = 2.38),  is for route food services that travel to various locations throughout the day.  Anyone with any exposure to the nature of the business is reportable in the basic classification, so any cashier or clean-up person would be reportable in 3905 in a food truck operation that doesn’t travel from place to place throughout the day. Even if the food truck is going to one location for the day then packs up and goes home, they would be reportable in 3905.

If you have questions related to workers compensation issues: their web site is http://www.lni.wa.gov/ClaimsIns/

Outdoor Heat Exposure Rules

On March 21, 2023, the Department of Labor & Industries’ (L&I) filed proposed rules to update the Outdoor Heat Exposures rules under WAC 296-62-094 and 296-307-097. These proposed changes address minimum requirements to prevent heat-related illness and reduce traumatic injuries for outdoor workers associated with heat exposure. More on what you need to know to keep you and your employees safe below:

https://lni.wa.gov/safety-health/safety-training-materials/workshops-events/beheatsmart

https://www.littler.com/publication-press/publication/washington-becomes-second-state-issue-emergency-heat-standard

https://mynorthwest.com/3577233/wa-workers-receive-extra-breaks-to-keep-cool-in-the-extreme-heat/

Does your mobile unit need a USDOT number?

In general, a USDOT Number is required if you are operating in interstate commerce and meet the following criteria:

You have vehicles that are over 10,000 lbs. (GVWR, GCWR, GVW or GCW), you transport between 9 and 15 passengers (including the driver) for compensation, whether direct or indirect, you transport 16 or more passengers, you haul hazardous materials.

See the DOT page for more information.

(PLEASE report any broken links, or edits that need to be made, here).