Can You Use RVs and Mobile Homes for H-2A Worker Housing?
A fencing contractor in Wyoming lands contracts across Montana, Idaho, and Utah. Hotels every night drain the budget and exhaust the crew. Fifth-wheel trailers seem like the obvious solution—workers have their own space, costs drop dramatically, and the mobile housing follows the work. But will the Department of Labor allow it for H-2A workers?
A rancher expanding into H-2A for the first time faces a similar question from a different angle. Building a traditional bunkhouse means foundation work, septic systems, water lines, electrical service, and potentially a year of permitting and construction. A few quality mobile homes could be on-site and ready for inspection in weeks. Is that legal?
The answer to both questions is yes—mobile housing units including RVs, campers, fifth-wheels, and mobile homes are permitted for H-2A workers. But they must meet every applicable standard without exception, pass mandatory State Workforce Agency inspection, and comply with all the same requirements as fixed-site housing.
What Federal Regulations Say About Mobile Housing
The H-2A housing regulations at 20 CFR § 655.122(d) require employers to provide housing at no cost to workers who cannot reasonably return to their residence within the same day. Employer-provided housing must meet one of two full sets of standards, “whichever are applicable under § 654.401”:
OSHA standards: the full set of temporary labor camp standards at 29 CFR § 1910.142 (Temporary Labor Camps)
DOL’s older ETA standards: the full set at 20 CFR §§ 654.404-654.417, which 20 CFR § 654.401 makes available only for housing completed or under construction before April 3, 1980, or under a signed construction contract before March 4, 1980.
For a mobile unit built after those dates, the OSHA standard governs. Neither standard creates a separate category for mobile housing or grants mobile units any special exemption. Outside the special-procedures occupations discussed next, the same standards apply to employer-provided housing whether the structure is fixed or mobile. (Rental and public accommodations, such as motels, follow a separate path under 20 CFR § 655.122(d)(1)(ii).)
The Special-Procedures Regime: 20 CFR 655.300–655.304
The general mobile housing analysis above applies to fixed-site employers who want to use mobile units at their own operations. A parallel regulatory regime, codified at 20 CFR 655.300 through 655.304, governs three occupations where the work itself is itinerant: custom combining, animal shearing, and commercial beekeeping. Under 20 CFR 655.304, employers engaged in animal shearing or custom combining (but not commercial beekeeping) may use a mobile unit, camper, or other similar mobile housing unit as worker housing, subject to detailed standards on drinking water, waste disposal, structural soundness, heating, electricity, and fire safety. The special-procedures regime also permits a single labor certification and job order to cover multiple areas of intended employment in one or more contiguous States (20 CFR 655.303(c)), rather than separate filings for each area.
Paragraph 655.304(a)(2) contains one of the more distinctive provisions in US labor regulation: “A Canadian employer performing custom combining operations in the United States whose mobile housing unit is located in Canada when not in use must have the housing unit inspected and approved by an authorized representative of the Federal or provincial government of Canada, in accordance with inspection procedures and applicable standards for such housing under Canadian law or regulation.” In effect, the regulation accepts a Canadian Federal or provincial inspection as a substitute for the US inspection that would otherwise apply.
If your operation is a multi-state custom combining crew rather than a fixed-site farm using a trailer for a few seasonal workers, the special-procedures framework is likely the one you should be planning against. For a full treatment, see our article on Canadian Custom Combine Crews and the H-2A Program.
The Controlling OSHA Interpretation
In June 1991, OSHA addressed mobile housing directly in an interpretation letter that OSHA still publishes as its interpretation of the standard. A portable-housing company had asked whether the 100-square-foot-per-person minimum for rooms where workers cook, live, and sleep applies to mobile housing units. OSHA’s answer:
“[A]ll mobile housing units, without exception, must comply with the general provisions of .142, including the 100 square feet provisions of standard. The mobility of the units does not relieve the employer from complying with the relevant provisions of the standard. The number of employees housed in the mobile units, as with fixed or permanent units, must be based on the 100 square feet per person formula. For the purposes of enforcing the standard, OSHA considers each entire mobile housing unit to be one room.”
This interpretation establishes a critical principle: mobility is not a basis for reduced requirements or special treatment. A fifth-wheel trailer used for H-2A housing must meet exactly the same standards as a stick-built bunkhouse. It also sets the occupancy math: because the whole unit counts as one room, a mobile unit can house one worker for every 100 square feet of floor space, not one for every 50 square feet of sleeping area.
OSHA Standards That Apply to Mobile Units
The OSHA Temporary Labor Camp standard at 29 CFR § 1910.142 applies comprehensively to mobile housing. Key requirements include:
Site and Drainage: Housing sites must be adequately drained and not subject to periodic flooding. Sites cannot be located within 200 feet of swamps, pools, or other standing water unless those water surfaces can be subjected to mosquito control measures. The site must be located so drainage from and through the camp will not endanger any domestic or public water supply. The area where food is prepared and served and where workers sleep must be at least 500 feet from any area where livestock is kept.
Space Requirements: Each room used for sleeping must provide at least 50 square feet of floor space per occupant and at least a 7-foot ceiling; in a room where workers cook, live, and sleep, the minimum is 100 square feet per person. For mobile units, OSHA treats the whole unit as one room, so the 100-square-foot figure is the one that counts. Beds must be spaced at least 36 inches apart side to side and end to end and raised at least 12 inches off the floor. Double-deck bunks must be spaced at least 48 inches apart, with at least 27 inches of clear space between the lower and upper bunk; triple-deck bunks are prohibited. Each sleeping room also needs storage, such as wall lockers.
Windows and Screens: Living quarters need windows totaling at least one-tenth of the floor area, with at least half of each window able to open, and all exterior openings must be screened with 16-mesh material, with self-closing screen doors.
Heating: All heating, cooking, and water-heating equipment must be installed in accordance with state and local codes, and if the housing is used during cold weather, adequate heating equipment must be provided. The OSHA standard does not itself list approved or banned heater types; state and local codes and your SWA’s inspection checklist fill that in. Confirm what your inspector will accept for an RV furnace or any portable heater before the inspection.
Water Supply: An adequate and convenient water supply, approved by the appropriate health authority, must be provided for drinking, cooking, bathing, and laundry. OSHA deems a supply adequate if it can deliver 35 gallons per person per day at a peak rate of 2½ times the average hourly demand. If water is not piped to each unit, no shelter may be more than 100 feet from a yard hydrant.
Toilet Facilities: Where toilet facilities are shared, the number of water closets or privy seats for each sex must be based on the maximum number of persons of that sex the camp will house at any one time, in a ratio of one unit per 15 persons, with a minimum of two units for any shared facility. A toilet room must be within 200 feet of the door of each sleeping room, and toilets must be cleaned at least daily.
Bathing, Handwashing, and Laundry: One handwash basin per family shelter or per six persons in shared facilities, one shower head for every 10 persons, and one laundry tray or tub for every 30 persons, with an adequate supply of hot and cold running water and facilities for drying clothes.
Lighting and Electrical: Where electric service is available, every habitable room must have at least one ceiling-type light fixture and at least one separate floor- or wall-type outlet. Kitchens and living quarters must be lit to at least 30 foot-candles measured 30 inches above the floor (20 foot-candles in toilet and storage rooms).
Garbage Disposal: Garbage containers must be fly-tight, rodent-tight, impervious, and cleanable (or single-service) and approved by the health authority, with at least one per family shelter, located within 100 feet of each shelter on a wooden, metal, or concrete stand. Containers must be kept clean and emptied when full, but not less than twice a week.
Fire Safety and First Aid: The OSHA standard requires adequate first-aid facilities approved by a health authority, in the charge of a person trained in first aid. It does not itself list smoke detectors, carbon monoxide detectors, or fire extinguishers, but state and local fire codes and your SWA’s inspection checklist may, so get the checklist before you prepare the units.
Insect and Rodent Control: Effective measures must be taken to prevent infestation by and harborage of insects, rodents, and other pests.
These requirements apply identically whether the housing is a mobile home, an RV, a converted barn, or a purpose-built bunkhouse.
State Workforce Agency Inspection Requirements
Federal regulations at 20 CFR § 655.122(d)(6)(i)–(ii) require the State Workforce Agency to inspect and certify all employer-provided housing, including mobile units. The SWA must verify that:
- The housing is sufficient to accommodate the number of workers requested
- All housing meets the applicable standards under § 655.122(d)(1)(i)
- The inspection occurs no later than 30 calendar days before the first date of need stated in the application
This 30-day deadline is absolute. If you plan to file for an April 15 start date, the housing inspection must be completed by March 16. The inspection requirement applies to each housing unit. If you’re using five mobile homes, the SWA inspects all five. If you’re using three RVs and two apartments, all five get inspected.
For farm labor contractors specifically, housing requirements carry extra weight. Under 20 CFR § 655.132(e)(1), when a fixed-site agricultural business provides housing for workers employed through a farm labor contractor, the housing must still comply with § 655.122(d) and receive SWA certification. The involvement of an FLC does not change housing standards or bypass inspection requirements.
State-Specific Restrictions on Mobile Housing
Federal regulations permit mobile housing, but the federal standard is not the only one that applies.
Mobile housing comes up most often for contractors moving crews between several growers’ places. If that describes your operation, read our guide on what DOL requires from a labor contractor before you plan the housing, because the worksite list drives everything else.
Before committing to mobile housing, ask your State Workforce Agency how it inspects campers, trailers, and mobile homes, and get a copy of its inspection checklist. A call to your SWA before purchasing or leasing RVs can prevent expensive mistakes.
Even in states that accept mobile housing, local regulations may apply. County health departments sometimes impose requirements beyond federal standards for temporary agricultural housing. City or county zoning ordinances may restrict where mobile housing can be sited. These local requirements layer on top of federal standards—they don’t replace them.
When Mobile Housing Makes Economic Sense
For many agricultural employers and farm labor contractors, mobile housing solves real problems. Understanding when it makes sense requires comparing it to the alternatives. One cost does not change with the housing model: the 2025 wage rule lowered the H-2A rate to offset free housing, a piece a federal court has since held unlawful, as our page on the H-2A housing adjustment and wage rates explains.
The Hotel Model
A fencing contractor working across Wyoming, Montana, and Idaho might pay $120 per night per worker for basic hotel rooms. With a six-person crew working 180 days, that’s $129,600 in lodging costs for the season. Workers spend evenings in rotating hotel rooms, never establishing a stable base. Meal costs rise because workers eat out rather than cooking. Worker fatigue increases from constant relocation.
The Fixed Bunkhouse Model
A rancher adding H-2A workers for the first time might consider building permanent housing. A basic four-bedroom bunkhouse with shared kitchen and bathrooms might cost $150,000-$250,000 to construct in Montana or Wyoming, depending on site conditions and utility access. If you need septic, well, and electrical service run to a remote site, add another $50,000-$100,000. Construction timelines run 8-12 months from permitting through completion. For an employer with seasonal needs who might use different H-2A workers each year, that’s significant capital tied up in an asset used 6-8 months annually.
The Mobile Housing Model
Used mobile homes are advertised for roughly $15,000-$40,000 each depending on size and condition, but units at the low end of that range usually need substantial work before they will pass inspection. New units cost far more: in 2026 I have seen a nearly new mobile home, bought as H-2A worker housing and used only a couple of months, offered for about $120,000, which is toward the top of the market. A fifth-wheel RV suitable for two workers costs $20,000-$45,000 new or $8,000-$18,000 used. Setup costs include utility hookups (water, septic, electric), but these are far less extensive than permanent construction—typically $5,000-$15,000 per site depending on existing infrastructure.
For the fencing contractor scenario, purchasing three fifth-wheel trailers at $30,000 each ($90,000 total) plus $30,000 in hookups at a home base creates a $120,000 one-time investment that eliminates $129,600 in annual hotel costs. The trailers can travel to job sites where hookups are available, or workers can stay at the home base with daily transportation to distant work sites.
For the rancher scenario, purchasing two mobile homes at $30,000 each plus $25,000 in site preparation totals $85,000—roughly half the cost of permanent construction, with the work completed in weeks rather than months.
These figures are illustrative planning numbers, not quotes. Prices vary widely by location, condition, and year, so get local bids before you decide.
The mobile housing approach works particularly well when:
- Work locations change seasonally or annually
- The employer is testing the H-2A program before committing to permanent infrastructure
- Workers will be divided among multiple work sites across a region
- The employer wants flexibility to adjust housing capacity year to year
- Existing infrastructure (power, water, septic) makes setup relatively simple
Mobile housing makes less sense when:
- The employer has a stable, long-term location with ample space for permanent construction
- Local regulations prohibit or severely restrict mobile housing placement
- Site conditions make utility hookups extremely expensive
- The employer plans to use the same housing for 10+ years (permanent construction may be more economical long-term)
Common Inspection Failures with Mobile Units
State Workforce Agency inspections of mobile housing commonly identify the same issues. Understanding these patterns helps employers prepare housing that passes on the first attempt.
Inadequate Square Footage
Many RVs and mobile homes marketed as sleeping six or eight people cannot house that many H-2A workers. Under OSHA’s 1991 interpretation, the entire mobile unit counts as one room and occupancy is based on 100 square feet per person. A “sleeps 8” trailer with about 320 square feet of floor space can house three workers under that formula, not eight. Measure the actual floor space, ask your SWA how it measures, and don’t rely on the manufacturer’s occupancy rating.
Insufficient Bathroom Facilities
The toilet ratio is one unit per 15 persons of each sex where facilities are shared, with a minimum of two units for any shared facility, and the shower ratio is one shower head per 10 persons. An RV’s single built-in bathroom shared by a crew can fall short of those numbers. Count fixtures against the maximum number of workers you will house, and plan additional facilities if the units alone don’t meet the ratios.
Improper Heating Systems
OSHA requires heating equipment installed to state and local codes and adequate heat when the housing is used in cold weather. An RV furnace or portable heater that your state or local code, or your SWA, does not accept will fail. If the unit’s heating doesn’t qualify, replace it with an approved system before the inspection.
Missing Safety Equipment
Smoke detectors, fire extinguishers, carbon monoxide detectors (if using gas appliances), and emergency exits are frequently missing or inadequate in mobile housing. Whether each is required comes from your state and local fire codes and the SWA’s checklist rather than the OSHA standard itself; where they are required, they must be present and working at the time of inspection.
Inadequate Drainage and Site Preparation
A mobile home parked on ungraded ground may be compliant internally but fail site requirements. The area around the unit must drain properly, the site cannot be within 200 feet of standing water without mosquito control, and the site must not pose a flood risk. Proper grading and drainage work before the inspection often determines pass or fail.
Water Supply Issues
In remote or rural locations, water supply often causes problems. If the mobile housing connects to a well, the well must be tested and approved by the state or local health authority. If workers will haul water, you must provide adequate storage and maintain sanitary conditions. “Adequate supply” means enough water for drinking, cooking, bathing, and laundry for all occupants.
Housing That Becomes Unavailable
Even after housing passes inspection, problems can arise. The regulations at 20 CFR § 655.122(d)(6)(iv) address what happens when certified housing becomes unavailable for reasons outside the employer’s control.
If housing becomes unavailable for reasons outside your control after you have asked the SWA to certify it, the regulation lets you substitute rental or public accommodation housing that meets the applicable local, State, or Federal standards. You must promptly notify the SWA in writing of the change and the reason for it, and give the SWA evidence that the substitute housing complies.
For mobile housing, the limits matter. If a fifth-wheel trailer is totaled in a highway accident on the way to the job, you can move the workers into compliant rental housing, such as apartments or a motel. The substitution provision speaks only of rental or public accommodations; a replacement trailer of your own is employer-provided housing, which the SWA must inspect and certify under 20 CFR § 655.122(d)(6)(ii). And the reason must genuinely be outside your control: “We decided to use a different RV” doesn’t qualify. “The original RV was totaled in a highway accident” does.
If, on inspection, the SWA finds the substitute housing doesn’t meet the standards, it must notify you in writing to cure the deficiencies, with a copy to the Certifying Officer. Failure to provide compliant housing will result in either denial of a pending application or revocation of an approved certification.
Farm Labor Contractor Considerations
Farm labor contractors face the same housing requirements as direct agricultural employers, but with additional complexity. If you’re operating as an FLC and providing housing, remember several points:
You Bear the Compliance Burden
Even if a fixed-site agricultural business agrees to provide housing for workers you supply, 20 CFR § 655.132(e)(1) requires proof that all housing complies with § 655.122(d) and has been certified by the SWA. The FLC application cannot proceed without this certification. If the fixed-site business’s housing fails inspection, your application stalls until housing is brought into compliance or alternative housing is secured.
Mobile Housing Offers Flexibility
For FLCs who supply labor to multiple farms or ranches, mobile housing provides operational flexibility that fixed housing cannot match. A fencing contractor operating as an FLC can move housing units with the crew as work locations change, rather than relying on each farm to provide compliant housing. This gives the FLC control over a critical program requirement.
Vehicle and Housing Standards Both Apply
Housing and transportation are separate obligations. Any vehicle you use to carry workers must comply with applicable federal, state, and local law and, at a minimum, meet the vehicle safety, driver licensing, and insurance requirements of 29 U.S.C. 1841 and 29 CFR 500.104 or 500.105 and 500.120 through 500.128, which 20 CFR § 655.122(h)(4) applies to H-2A employers. The truck that tows a fifth-wheel and carries the crew is transportation; the trailer, once parked and occupied, is housing that must meet 29 CFR § 1910.142 and pass SWA inspection. The two are checked separately.
Bond Calculations Don’t Change
The surety bond required for FLCs under 20 CFR § 655.132(c) is calculated based on the number of workers requested, not the type of housing provided. Using mobile housing instead of fixed housing doesn’t reduce the bond amount or change the calculation methodology.
Strategic Guidance on Mobile Housing
Based on the firm’s H-2A practice across Montana, North Dakota, Wyoming, Utah, Idaho, and Colorado, several strategic considerations emerge for employers considering mobile housing:
Start the Process Early
Housing inspection is often the bottleneck in H-2A applications. SWAs in rural states may have limited inspection staff covering enormous geographic areas. Requesting an inspection in February for an April start date gives you time to address any deficiencies and request a re-inspection if needed. Waiting until March to request inspection for an April start creates unnecessary risk.
Measure Before You Buy
Many employers purchase mobile units based on advertised sleeping capacity only to discover during inspection that the units don’t meet square footage requirements (OSHA counts 100 square feet per worker across the whole unit). Before purchasing or leasing, physically measure the floor space in sleeping areas. If purchasing used units, have them inspected by a local building inspector or RV technician to identify any issues before the SWA inspection.
Document Your Setup
Take photographs of the housing setup showing site drainage, utility connections, spacing between units, fire safety equipment, and interior layout. If questions arise during or after inspection, documentation helps demonstrate compliance. For FLCs working across multiple states, documentation also helps when working with different SWAs who may have different inspection protocols.
Maintain a Relationship with Your SWA
SWA inspectors in Montana, Wyoming, and North Dakota often work with the same agricultural employers year after year. If you used mobile housing last season and it passed inspection, maintain that relationship. Inform the SWA early if you’re using the same units in the same configuration. Some SWAs may streamline re-inspection if the housing and setup haven’t changed materially.
Consider the Full Lifecycle Cost
Mobile housing has lower upfront costs than permanent construction but higher ongoing maintenance requirements. RVs and mobile homes deteriorate faster than stick-built structures when used seasonally. Budget for annual maintenance, repairs, and eventual replacement. A $25,000 mobile home might need $2,000-$3,000 in annual upkeep and require replacement after 8-10 years of seasonal use.
Plan for Expansion or Contraction
One advantage of mobile housing is scalability. If your H-2A needs increase, you can add units without major construction. If needs decrease, you can sell units or redeploy them. This flexibility is particularly valuable for employers still establishing their optimal crew size or FLCs whose contracts vary year to year.
Bottom Line for Agricultural Employers
Mobile housing—RVs, fifth-wheels, campers, and mobile homes—is legally permissible and often economically advantageous for H-2A employers and farm labor contractors. The mobility of the housing creates no legal barrier and outside the special procedures for animal shearing and custom combining, triggers no special regulatory category. These units must simply meet the same comprehensive OSHA and DOL standards that apply to all employer-provided housing.
The fencing contractor question posed at the beginning of this article has a clear answer: Yes, you can use fifth-wheel trailers for your H-2A crew as they work across Wyoming, Montana, and Idaho. You’ll save substantially compared to hotels, give your workers stable housing, and maintain flexibility as work locations change. But those trailers must meet every OSHA requirement, pass SWA inspection at least 30 days before your first date of need, and comply with any state-specific restrictions in the states where you operate.
The rancher question has an equally clear answer: Yes, you can use mobile homes instead of building a permanent bunkhouse, get housing ready faster, and reduce your capital investment significantly. But those mobile homes must still meet all applicable housing standards, and the timeline advantage only materializes if you start the inspection process early enough to address any deficiencies identified during inspection.
The regulations don’t prohibit mobile housing. They require compliant housing, and compliance is achievable with proper planning, accurate measurement, and attention to OSHA’s detailed requirements. For many employers across the Rocky Mountain West, mobile housing represents the most practical solution to the H-2A housing requirement.
If you’re considering mobile housing for your H-2A program or expanding your farm labor contracting business to include crew housing, we can help you evaluate whether your proposed setup meets regulatory requirements and guide you through the inspection process. Contact us for a strategy consultation—we help agricultural employers across Montana, North Dakota, Wyoming, Utah, Idaho, and Colorado develop compliant H-2A housing strategies.
