Key Takeaways
- BS 6440:2011 permits a 100 mm roll-off guard only for travel up to 1,000 mm in domestic or trained-user contexts, and it is a wheel-retention feature rather than fall protection.
- CSA B355 does not include a like-for-like, BS 6440-style prescriptive permission for a 100 mm roll-off guard, so Canadian projects typically proceed via prescriptive guarding or a documented equivalency case accepted by the AHJ.
- Ontario approvals are governed by O. Reg. 209/01 and administered by TSSA, with CSA B355:19 enforced through the provincial code adoption document route.
- A roll-off guard proposal in Ontario is realistically a variance or equivalency submission with a P.Eng.-prepared safety case and iterative review risk.
- From March 16, 2026, TSSA confirmed more services move online through the Client Portal, including engineering submissions, improving tracking and coordination for design registrations.
- Sesame Access can engineer both routes: an evidence-led equivalency submission where appropriate, and fully code-aligned lift concepts such as the Westminster Equality Act Lift and the Seattle ADA Lift.
Introduction
When a specifier in Canada asks for a 100 mm roll-off guard, they are usually referencing a UK concept that originates in BS 6440:2011. The risk is assuming that a UK permission automatically translates into Canadian compliance.
A better way to think about it is the way we frame most Canadian platform lift conversations: start with the approval route, not the product. If you want a broader planning framework for early-stage decisions, read the Canadian platform lift planning guide alongside this page.
This article focuses on the roll-off guard question and the practical approval pathway, with a clear decision framework for when a roll-off guard approach is not worth the programme risk.
Why trust this article?
Sesame Access designs bespoke lifts for complex public buildings and heritage constraints internationally, and we routinely work with Authority Having Jurisdiction-style review models where local interpretation determines what can be approved.
This page reflects how Sesame Access approaches real submissions: defining the safety objective, documenting hazards and mitigations, and selecting the approval route that best protects the project programme.
What is a roll-off guard in BS 6440:2011?
BS 6440:2011 is a UK standard that covers stairlifts for domestic use and use by trained operators. Within that specific context, it allows a minimum 100 mm roll-off guard where travel is up to 1,000 mm, and then requires a gate beyond that threshold.
The roll-off guard concept is often misdescribed as a general barrier. It is not. A roll-off guard is intended to prevent wheelchairs rolling off the platform edges during travel. It does not provide fall protection for standing users.
Does CSA B355 permit a 100 mm roll-off guard?
CSA B355 is Canada’s National Standard for platform lifts and stair lifts for barrier-free access. The edition in force depends on the province, and provinces may apply amendments through their own adoption documents.
CSA B355 does not present a direct, BS 6440-style prescriptive clause that simply permits a 100 mm roll-off guard as the guarding approach.
Where projects do explore non-standard guarding, the viable pathway is typically an equivalency case with technical documentation demonstrating equivalent or superior safety, accepted by the AHJ. This is the engineering basis for any roll-off guard argument under Canadian standards.
Why Canadian projects often feel more “strict to code”
In public-facing Canadian work, the dominant expectation is usually prescriptive compliance and clear code alignment, especially where civic, institutional, or high-traffic buildings are involved. This affects what is worth pursuing, because a variance route can create programme risk even when a concept is technically defensible.
Which CSA B355 edition matters, and why province changes everything
Provincial adoption varies, and provinces may adopt with amendments.
As of February 2026:
- Ontario is operating under CSA B355:19 through the TSSA code adoption approach, with amendments and enforcement shaped by the relevant code adoption document.
- Alberta confirmed CSA B355:24 is in force as of December 1, 2025.
- For other provinces, adoption status should be confirmed with the local AHJ at concept stage.
What is the Ontario compliance hierarchy under TSSA?
Ontario elevating devices are governed by the Technical Standards and Safety Act, 2000 and O. Reg. 209/01, with TSSA administering design registration, inspection, licensing and enforcement.
TSSA code adoption documents define how CSA B355 requirements are applied in Ontario.
If you are proposing a non-standard guarding approach, you should assume you are moving from prescriptive compliance into a formal justification route.
A useful Ontario exemption to check early
Ontario regulation includes exemptions in section 2(3), including a pathway that may be relevant for some low-rise, non-public applications. Where a platform lift is low rise and not accessible to the general public, this can change the regulatory conversation dramatically.
This is always something to confirm early with the relevant parties, because it can be the difference between a straightforward solution and a full design registration path.
How does a TSSA variance or equivalency submission usually work?
Ontario submissions are built as reviewable safety cases.
A variance or equivalency submission for a roll-off guard approach typically includes:
- a P.Eng.-prepared risk assessment and documented hazard controls
- evidence showing how the roll-off guard achieves the safety objective for the defined user population and environment
- clear drawings and safety circuit logic, including failure mode response
- defined assumptions about user type, supervision, and public accessibility
Variance routes are reviewed and may require iteration, and approval is not guaranteed. The practical takeaway is that a roll-off guard route should be treated as a programme-risk choice, not a default.
What changes on March 16, 2026 with the TSSA Client Portal?
TSSA confirmed that more services move online through the Client Portal as of March 16, 2026, including engineering submissions.
For international manufacturers and project teams, the practical benefit is clearer submission tracking and improved coordination across stakeholders, which matters most where iterative review is expected.
When a roll-off guard approach is not appropriate
Use this as a hard-stop list during concept selection:
- the lift is accessible to the general public
- unaccompanied users are foreseeable
- standing users are foreseeable during travel or boarding
- the project is civic or institutional and programme delay risk is unacceptable
- a prescriptive compliant barrier solution is physically feasible and does not compromise critical heritage constraints
- the project cannot tolerate the possibility of variance rejection and redesign
If two or more of these apply, a prescriptive barrier concept is usually the more strategic route.
When a roll-off guard approach may be viable
A roll-off guard approach is most defensible when the safety objective is wheel retention for a defined user group and the environment is controlled.
Typical conditions include:
- controlled access or supervised use
- trained user assumptions that are realistic and enforceable
- heritage constraints where full barriers cannot be accommodated without unacceptable building impact
- project teams who understand an equivalency route can extend review time and require iteration
Three misconceptions about roll-off guards in Canada
Misconception 1: BS 6440 permission transfers into Canadian compliance
It does not. BS 6440 is a UK context permission. Canadian compliance is governed by CSA B355 as adopted by the province.
Misconception 2: CSA B355 contains a direct 100 mm roll-off guard clause
It does not present a like-for-like prescriptive permission. Where pursued, the pathway is technical equivalency evidence accepted by the AHJ.
Misconception 3: a roll-off guard provides fall protection
It does not. A roll-off guard is wheel retention, not fall protection for standing users.
Strategic selection matrix: choose the route before choosing the lift
Project reality |
Lowest risk route |
Why |
Public building, foreseeable standing users |
Prescriptive full barriers |
Approval certainty is higher and safety intent aligns to public access expectations |
Ontario project with TSSA involvement |
Prescriptive barriers unless a strong equivalency case exists |
Variance routes add review and iteration risk |
Heritage constraint makes barriers physically impossible |
Equivalency / variance route |
The constraint can justify a documented alternative safety strategy |
Low rise with controlled access |
Case-by-case |
The safety objective may be wheel retention rather than fall protection |
If you want the wider context on how this decision framework fits into Canadian project planning, the Canadian platform lift planning guide is the companion page.
How Sesame Access approaches compliant design options
Sesame Access can engineer both strategies:
- a variance-ready, evidence-led approach where an equivalency argument is justified
- a code-aligned barrier approach designed to minimise approval uncertainty
Where the AHJ expectation aligns to ASME A18.1-style full barrier concepts, the practical route is a barrier system such as the Seattle ADA Lift, which is designed around full-height user barriers and grab rail expectations.
For retracting stair architecture where a code-aligned barrier strategy is required, the Westminster Equality Act Lift is the route for higher-rise or public-facing contexts.
For deeper design intent comparisons between retracting stair lift concepts and how compliance expectations change by jurisdiction, see Seattle vs Westminster retracting stair lifts.
Product integration summary: roll-off guard route vs full barrier route
Decision factor |
Equivalency roll-off guard route |
Prescriptive full barrier route |
Regulatory predictability |
Lower |
Higher |
Documentation burden |
Higher |
High but more standardised |
Review and iteration risk |
Higher |
Lower |
Best fit |
Controlled access, defined users, hard constraints |
Public buildings, high confidence approvals |
Engineering case notes: what a Canadian-ready submission pack looks like
A Canadian-ready pack is built as an AHJ-readable engineering story:
- site-specific drawings showing guarding extents and boarding points
- control descriptions and safety interlocks
- failure-mode behaviour, including safety contact responses
- defined assumptions on use and supervision
- a clear statement of what is prescriptive and what is alternative, with evidence to support equivalency
This approach aligns with the way Canadian regulators and AHJs tend to review novel concepts: evidence first, then design.
Frequently Asked Questions (FAQ)
Can a 100 mm roll-off guard be approved in Ontario?
It can be proposed, but it is realistically an equivalency or variance route that requires a P.Eng.-prepared safety case and may involve iterative review.
What is Ontario enforcing right now for platform lifts?
Ontario references CSA B355:19 through the TSSA code adoption route.
What changes with the TSSA Client Portal on March 16, 2026?
TSSA confirmed more services become available via the Client Portal as of March 16, 2026, including engineering submissions.
Does Alberta use a different CSA B355 edition than Ontario?
Alberta confirmed CSA B355:24 is in force as of December 1, 2025, while Ontario remains on B355:19 through TSSA adoption documents.
Is a roll-off guard the same as fall protection?
No. A roll-off guard is wheel retention. Fall protection for standing users is a different safety objective.
Long-tail query: what should I ask before I specify a platform lift in Canada?
Confirm the enforced standard edition in the province, whether the lift is accessible to the general public, and what the AHJ expects for guarding strategy.
Long-tail query: what is the difference between Seattle and Westminster retracting stair lift concepts?
The comparison page Seattle vs Westminster retracting stair lifts explains how barrier strategy, grab rail expectations, and jurisdictional approvals shape the concept choice.
Long-tail query: what is the safest way to avoid redesign during TSSA review?
Choose a prescriptive barrier concept where feasible, and engage early with a complete submission package that anticipates reviewer questions and clarifies assumptions.
Call to action
If you are planning a Canadian platform lift project and want to reduce redesign risk, book a Teams meeting with one of our Project Managers so we can confirm the enforced edition, guarding strategy, and likely approval route before tender: