Summary of the TDLR IHB May 14 Code Council Meeting – Increased Enforcement and Compliance Efforts

The Texas Department of Licensing and Regulation Industrialized Building Code Council, the Texas governmental body overseeing commercial and residential modular construction, met on May 14. Several general staff reports were presented for those interested in program data trends. 

However, what TMHA specifically wanted to bring to the attention of all residential modular builders was the meeting’s significant focus on intensified compliance and enforcement efforts within the Industrialized Housing and Buildings (IHB) program. Staff reported that roughly one-third of active manufacturers are either not submitting required monthly decal and certification reports or are submitting them late. 

Here is the link to monthly reporting form. 

Additionally, staff explained that following the industrialized housing code cycle changes that took effect in July 2024, manufacturers were required to submit updated compliance control manuals reflecting the new code requirements. The council had previously granted manufacturers an extended deadline until February 1, 2026, to submit those revised manuals; however, staff reported that 14 manufacturers still had not submitted them as of the end of March 2026.

Chrissy Cooper stated that TDLR/IHB intends to begin filing complaints against manufacturers that fail to comply with these requirements. Cooper also noted that council members and staff discussed stronger enforcement measures, including formal complaints against noncompliant manufacturers and the potential withholding of decals or labels from companies that continue to fail to comply.

A TDLR workgroup has also been actively developing recommendations to improve monitoring, auditing, escalation procedures, and enforcement coordination.

The clear takeaway for our industry from this meeting is that enforcement efforts are increasing and will likely continue to intensify. TMHA strongly encourages all modular home builders to ensure their monthly reports are being timely submitted to TDLR and to verify that all required 2021 compliance manuals have been submitted and are current.