Date of Publication: May 19, 2026 [2026.06.V-01.C]
Subject: Folding Access Ladders in Part 9 Buildings.
Ontario Building Code Reference(s):
Article 3.3.1.14. of Div B
Article 9.4.2.4. of Div. B
Article 9.8.4.1. of Div. B
Article 9.8.4.9. of Div. B
Article 9.19.2.1 of Div. B
Subsection 9.23.10. of Div. B
Subsection 9.23.12. of Div. B
Incoming Request:
Is a pull-down, folding access ladder permitted to provide access to an attic or roof space containing a furnace in a Part 9 building?
Executive Summary:
Pull-down folding attic access ladders are not recognized or regulated by the OBC. They are not permitted to provide code-mandated access to or egress from normally occupied spaces or floor areas. Authorities having jurisdiction should exercise caution when considering their use in other circumstances.
Discussion & Considerations:
Code Considerations:
The Code generally recognizes that service rooms, service spaces and areas accessed only for occasional servicing or maintenance do not require the same access and egress provisions as normally occupied spaces or floor areas. Part 3 includes specific exemptions. Sentence 3.3.1.14.(2) exempts stairs serving service rooms or service spaces used for occasional servicing of equipment and machinery from many stair requirements, including width, headroom, riser number, vertical rise, landings, handrails and guards, tread and riser dimensions, and curved flights. In practice, this could allow access by very steep stairs, such as a ship ladder.
Part 9 has similar, but less comprehensive exemptions for stairs serving similar areas. Footnotes (3) and (4) to Table 9.8.4.1. exempt certain stairs from riser height, and Sentence 9.8.4.9.(1) allows certain stairs to have open risers. However, the Part 9 exemptions do not extend to other stair requirements such as, guards, handrails, landings and height over stairs.
It is also implied in the Code that egress (and access) need not be provided to every space in a building, particularly areas not designed to be normally occupied, i.e. an attic or roof space with limited storage, service spaces, or other unoccupied/infrequently accessed areas. It would be up to the occupants to decide how and when to access these areas.
Is a pull-down, folding access ladder a stair?
No. These devices are not contemplated by the Code provisions for stairs, and generally would not meet the dimensional, guard, or handrail requirements applicable to stairs in Part 9. They are sometimes referred to as disappearing attic stairways. Although ANSI-ASC A14.9-2019: Safety Requirements For Disappearing Attic Stairways is a recognized standard, it is not referenced by the OBC. These devices are also not governed by Supplementary Standard SB-8, which is not referenced in Part 9. In summary, these devices are neither stairs nor fixed ladders conforming to SB-8, and are therefore not regulated or recognized by the OBC.
Where are they prohibited?
Because these devices are not regulated by the OBC, they are not permitted to provide either Code-mandated egress or supplementary access or egress to normally occupied spaces or floor areas.
Risk/Benefit Analysis:
These devices are not permitted to replace required stairs or fixed ladders. However, if they are shown on proposed plans or encountered during inspections, an authority having jurisdiction may wish to consider one of the following three courses of action, listed from lowest to highest assumed risk.
- Prohibit their installation. These devices serve a similar function to stairs, and members of the public may assume that they meet the requirements applicable to code-compliant stairs, which they generally do not.
- Permit them under limited circumstances. If the device provides access to a space that does not require a means of egress or a code-compliant stair, an authority having jurisdiction may choose to permit or approve its use through an internal policy or an alternative solution, while considering the associated risk and liability. In such cases, the authority having jurisdiction may consider referencing an industry standard for pull-down folding access ladders, such as ANSI/ASC A14.9, to support this approach.
- Provide no comment. Because these devices are not regulated by the OBC, an authority having jurisdiction may be reluctant to comment on their installation. However, it may be better practice to provide direction consistent with either option 1 or option 2 above.
Regardless of the course of action, the provisions of Article 9.19.2.1. and the related appendix note respecting access dimensions should be maintained, together with the required insulation value and air barrier or vapour barrier continuity where the device penetrates the insulated assembly. There may also be structural implications, as the attic may be considered accessible by a stairway under Articles 9.23.10.1. and 9.23.10.3., or might be considered to provide limited attic storage under Articles 9.23.12.3. and 9.4.2.4. If the ceiling has a fire-resistance rating, an approved rated device must be used. Where the space being accessed contains mechanical equipment, the manufacturer may also specify minimum requirements for the access opening, clear space, and headroom in front of the control panel. The designer should also consider how the equipment could be removed if replacement is required in the future.
Authorities having jurisdiction should also consider the intended use and context of these devices. Notwithstanding Article 9.8.4.1., particularly table notes 3 and 4, if an attic or roof space does not contain equipment requiring periodic servicing and is not designed to be accessible by a stairway or to provide limited attic storage, approval of an access ladder may not be appropriate. In any case, notes should be added to the approved plans and any subsequent inspection reports to clarify whether the device forms part of the authority having jurisdiction’s approval or is considered outside the scope of that approval. These notes may also identify any limitations on the use of the device or the space in question. In addition, authorities having jurisdiction may wish to establish a policy to support consistent interpretation and enforcement.
Final Recommendation:
Folding access ladders are not recognized or regulated by the OBC. Accordingly, they are not prescriptively permitted to provide access to, or egress from, normally occupied spaces or floor areas.
Recommendation to Ministry of Municipal Affairs and Housing:
The access requirements for service rooms and service spaces appear to be more permissive in Part 3 than in Part 9. Greater alignment between these requirements may help reduce inconsistency and improve interpretation.
Referenced Documents:
2024 Ontario Building Code O.Reg 163/24 Amended to 05/25
Disclaimer:
This guidance document is intended to assist building officials by gathering relevant information to interpret the OBC Act and the prescriptive requirements of the Ontario Building Code, and is intended to be a best practice aid for building officials.
The views expressed within this guidance document should not be considered as the official interpretation of legislated requirements based on the Ontario Building Code, as the final responsibility for interpretation rests with the local Authority Having Jurisdiction.
The views of this advisory committee should not be construed as legal advice.