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Cargo containers used as accessory storage structures.
Building Code Guides (BCGs) provide a comprehensive alternative to a complicated set of code requirements.
Building Code Guides (BCGs) provide a comprehensive alternative to a complicated set of code requirements.
QUESTION: Can cargo containers be used as storage structures?
RESPONSE: Cargo containers are allowed to be installed on private property as structures for any type of use allowed under the building and zoning codes as long as they meet all development requirements. Under the following conditions, cargo containers may be used as storage structures without meeting the full requirements of the building code.
A. Scope.
In order to use the options in this code guide, the building and scope of work must meet all of the following criteria:
- Containers are used as storage only. For containers accessory to one- and two-family dwellings, storage is limited to materials belonging to the owner or tenant of the residence on the subject site.
- Containers are not used as shops, studios, hobby rooms, offices, lunchrooms, sales areas, playhouses, or other similar uses.
- Containers are not used for storage of motorized passenger vehicles.
- Containers are not classified as a High-Hazard Group H occupancy.
- Structural modifications are prohibited, except that door and window openings are permitted. The aggregate width of all openings on a single side, other than the original opening on the short end of the container, must not exceed 20% of the wall's linear length.
- Containers are not stacked on top of each other or used as supporting elements for other structures.
- Containers are not equipped with plumbing.
- Containers are not equipped with electrical power other than lighting.
- Semi-truck trailers are not considered cargo containers under the provisions of this Code Guide.
Cargo containers not meeting the criteria above must meet all applicable requirements of the Building Code for a site-built structure. See additional prescriptive structural options in the Oregon Structural Specialty Code (OSSC) Section 3114 Intermodal Shipping Containers for cargo containers outside the scope of this Code Guide.
Trade permits are always required for mechanical, electrical, and plumbing work. This applies regardless of whether a building permit is needed or if the structure complies with this code guide.
B. Building Permits.
- Building Permits Required. Following is a list of situations that require building permits. Requirements of this Code Guide and the Zoning Code must be met even if a building permit is not required:
- Containers accessory to one or two family dwellings. Containers greater than 200 square feet in floor area or greater than 15 feet in height, measured from grade plane to the average height of the roof surface, require a building permit. Smaller containers do not require a building permit.
Containers used for commercial storage. Except as allowed in i or ii below, a building permit is required to install containers used for commercial storage.
- Containers exempt from permit per OSSC 105.2.
Containers that are used by a contractor for storage of construction materials on a site that has a valid building permit and that remain on the site only for the duration of the construction activity are not required to have a building permit.
Such containers must be located on the site for which a building permit has been issued or on a site immediately adjacent to the site of the construction activity that has been approved for use by the contractor as a staging area.
The containers must be removed from the site not later than thirty (30) days after the building permit for the construction has received final inspection.
Note: Containers are not allowed to be used as temporary jobsite trailers under this code guide. Containers that have been approved as a prefabricated structure for the intended occupancy may be used on a construction site under the guidance of BCG 16-10: Temporary Prefabricated Structures.
- Multiple Containers. More than one container may be installed under a single permit. Contact the Permitting Services at PP&D for permit process information.
- Permit Documentation. Permit documentation must include a site plan, a floor plan for each container to be installed, and any details required to demonstrate compliance with the installation requirements outlined in this Code Guide.
- Permit Fees. Fees for permits must be calculated based on a valuation that includes the cost of the container(s) and the cost to install the container(s), including any site work necessary to prepare the site for the container(s).
C. Specific Design Requirements
Building code review for cargo containers within the scope of this Code Guide is limited to the following requirements:
- Exterior wall and opening protection: Fire protection for exterior walls, openings, and projections is based on fire separation distance (FSD).
- FSD 5 feet or more: Exterior walls are allowed to be unrated with unprotected openings.
- FSD less than 5 feet: Exterior walls are required to be one-hour fire-resistance rated and no unprotected openings are allowed. Two layers of 5/8" Type X fire rated gypsum board may be added to the interior side of the exterior wall instead of upgrading to a one-hour fire-resistance rated wall tested from both sides.
- Separation from other buildings on the same lot.
- One cargo container may be placed adjacent to an existing building without addressing exterior wall and opening protection for the fire separation distance from the existing building. Fire separation requirements from real property lines are still applicable.
- Where more than one cargo container is located less than ten feet from a building or less than ten feet from another cargo container that is less than ten feet from the building, the exterior wall and opening protection for all structures must be addressed.
- Where structures are analyzed as "portions of one building" in accordance with the building code, no exterior wall and opening protection is required between the structures. Fire separation requirements from real property lines are still applicable.
Egress Door. Containers must be provided with an egress door not less than 3 feet wide by 6 foot, 8 inches high.
The standard container doors can serve as the required egress door. To qualify, they must meet the minimum size requirement and be equipped with a mechanical latch or other similar mechanism to hold the door in the open position when the structure is occupied.
Threshold height and landings at doors for containers need not comply with Building Code requirements.
- Foundations and Tie Downs. Containers must be placed on firm, level, undisturbed natural grade or on an existing paved parking area or storage yard. Permanent foundations are not required. For containers more than 200 square feet in area, the storage container must be anchored to resist sliding and overturning due to seismic and wind loads in accordance with the building code.
- Zoning Code. Containers must meet all applicable use and development regulations of the Zoning Code. For example, use regulations may prohibit storage containers from being leased or used as self-service storage. Development regulations such as building setbacks, building coverage limits, or special overlay zones, may affect if or where a container can be placed on a site. For more information, contact Planning & Zoning.
- Stormwater Management.
- Drainage. Containers up to a maximum of 320 square feet of roof area are not required to be provided with gutters or downspouts or other storm water collection system provided the sheet flow of storm water from the container is contained on site and not allowed to encroach on adjacent property or public right of way.
- Containers that are used to store certain materials, such as solid waste or liquids, may trigger source controls. Please contact Environmental Development Review for more information.
HISTORY: UBC/5/#1 & CABO/1/#2 replaced Policy & Procedure # D-61 July 1, 1996. Revised March 1, 1999, April 3, 2006, August 22, 2007, January 29, 2013, and August 18, 2026.
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