Key Takeaways
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UK-designed accessibility lifts can be installed in the USA, but only following approval from the local Authority Having Jurisdiction (AHJ).
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ASME A18.1 governs platform lifts in the United States, and different cities adopt different publication years.
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Some Sesame lift designs fully align with ASME A18.1, while others rely on equivalency arguments or formal variances.
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Early AHJ engagement before procurement is critical to programme certainty.
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Understanding which ASME clauses affect guarding, gates, and obstructions helps determine project suitability early.
Introduction
Sesame Access designs and manufactures bespoke accessibility lifts in London and installs them globally. These systems are engineered to British Standard BS 6440:2011 and European Standard EN 81-41, which take a performance-based approach to safety.
When installing in the United States, additional regulatory steps apply. Platform lifts are assessed against ASME A18.1, with final approval granted by the local Authority Having Jurisdiction. This means that suitability is not determined by a single national approval, but by how a specific design is reviewed and accepted locally.
As is often explained during early-stage enquiries, “the short answer is that approval must be achieved with the Authority Having Jurisdiction before a full order is placed.”
For a high-level overview of Sesame’s approach to US compliance pathways, see Using Sesame Lifts in the USA – Technical Overview.
Why US authorities and inspection bodies contact Sesame Access for technical guidance
US authorities and inspection bodies regularly engage with Sesame Access when assessing non-standard accessibility solutions that fall outside typical prescriptive designs.
In several approval scenarios, authorities have required detailed engineering explanations showing how performance-based safety measures achieve equivalent or higher risk control than traditional physical guarding. For example, when a landmark building required a lift solution that removed conventional upper guarding to preserve architectural character, comparative safety documentation and sensor-based risk mitigation evidence were used to support an equivalency determination.
In other cases, early-stage design consultation with the AHJ has allowed bespoke lift systems to be reviewed and refined before fabrication, avoiding late-stage redesigns or rejected inspections.
This advisory role reflects that Sesame Access is not only supplying lifts, but also supporting how ASME A18.1 is interpreted for bespoke, constrained environments.
Why do UK-designed lifts need AHJ approval in the USA?
British and European standards permit safety to be achieved through controlled movement, sensing systems, and integrated protection. ASME A18.1 is more prescriptive in certain areas, particularly around upper landing guarding, gate construction, and proximity to obstructions.
As a result, not every UK-designed lift can be accepted automatically. Instead, the AHJ assesses whether a design conforms fully, can be accepted through equivalency, or requires a formal variance.
As one common clarification states, “the USA client takes responsibility for ensuring the lift is approved by the AHJ, with technical support provided throughout the process.”
Which Sesame lift designs are typically assessed for US projects?
Several Sesame lift systems are regularly reviewed for US installations, depending on building constraints and regulatory tolerance.
Examples include the Kensington Stairlift for limited-rise seated access, but this is a EU product, the Seattle ADA Lift developed specifically with ASME alignment in mind, the Westminster Equality Act Lift for retracting stair applications, and the fully enclosed Windsor Lift.
A detailed comparison of retracting stair solutions in a US regulatory context is available in Seattle vs Westminster Retracting Stair Lifts in NYC.
Common misconceptions about using non-US lifts in the USA
Many specifiers assume UK-designed lifts cannot be used in the United States. In practice, ASME A18.1 allows alternative designs where equivalent safety can be demonstrated and accepted by the AHJ.
Another common belief is that variance applications are always prohibitively slow. In reality, where AHJs are engaged early and provided with structured comparative safety documentation, responses are often achieved within predictable timeframes.
It is also frequently assumed that sensor-based safety systems are automatically rejected. In practice, AHJs may accept these systems where risk is demonstrably mitigated and supported by recognised testing and documentation.
What ASME A18.1 clauses most commonly affect design decisions?
Why do upper landing guarding rules matter?
ASME A18.1 requires the upper landing to be protected by a solid door or gate with defined clearances. This directly affects the use of open or hidden barriers, particularly for horizontal retracting stair designs.
Where concealed barriers are integral to the stair retraction mechanism, a visible upper gate may be required instead, such as those used with the Regent Wheelchair Platform Stairlift.
How do grab rail and wall height requirements differ?
ASME A18.1 specifies both minimum wall heights and separate grab rail positions. British Standards allow rising guard walls to act as grab rails at a higher level.
As has been noted during live US enquiries, “British Standards allow the guard wall to act as the grab rail, whereas ASME specifies a separate grab bar at a lower height.”
How do nearby obstructions affect approval?
Where fixed handrails or architectural elements sit close to the platform enclosure, ASME A18.1 may require continuous guarding to mitigate pinching or shearing hazards. UK standards often permit sensor-based mitigation instead, which may be accepted by AHJs when supported by technical evidence.
Approval documentation we provide to support AHJ review
To support AHJ assessment and equivalency determinations, Sesame Access typically provides comparative safety analysis mapping BS 6440 against ASME A18.1, third-party certification data for sensors and control systems, structured risk assessments using recognised methodologies, and installation and maintenance protocols adapted for US inspection practices.
This documentation often forms the technical basis for AHJ approvals or variance submissions and has been refined through multiple successful US projects.
Related Regulatory Pathways Across Jurisdictions
Where prescriptive compliance under ASME A18.1 creates architectural or operational conflict, a formal variance pathway may be required. A detailed case study of a permanent variance submission under the adopted ASME A18.1-2003 framework is documented in ASME A18.1 Permanent Variance: Docket 24-V-358 Analysis. For comparison with Canadian guarding interpretation under CSA B355 and TSSA oversight, see Roll-Off Guard Canada – CSA B355 & TSSA Approval Guide. European liftway scope boundaries under EN 81-41 are explained in Liftway Definitions and EN 81-41 Scope.
Is your project suitable for a UK-designed lift?
Before progressing, consider the following decision framework.
If the building is landmarked or architecturally sensitive, the project may be suitable. If the programme allows 12–16 weeks for AHJ consultation, the project may be suitable. If the project team is willing to engage the AHJ before procurement and accepts that variance outcomes are not guaranteed, proceeding may be appropriate.
If these criteria cannot be met, a standard ASME-compliant vertical platform lift or LULA elevator may be more appropriate, and alternative options can be discussed.
Product Integration Summary
| Lift Solution | Typical ASME Alignment | Common Approval Route |
|---|---|---|
| Kensington Stairlift | Minimum | AHJ equivalency |
| Seattle ADA Lift | High | AHJ design consultation |
| Westminster Equality Act Lift | High | AHJ review with adjustments |
| Windsor Lift | Full | Direct ASME conformity |
| Cavendish Platform Lift | Partial | Formal ASME variance |
Why early AHJ engagement reduces risk
Engaging the AHJ during concept design allows regulatory constraints to be addressed before fabrication. This reduces redesign risk, supports clearer cost planning, and aligns expectations across all stakeholders.
As is often emphasised, “the AHJ who will ultimately sign off the lift should be part of the design process before final approval.”
Frequently Asked Questions
Can UK platform lifts be legally installed in the USA?
Yes, provided they are approved by the local AHJ under the adopted edition of ASME A18.1.
Does every US city apply the same ASME rules?
No. Different jurisdictions adopt different publication years and may interpret clauses differently.
Are variances guaranteed to be approved?
No. Variances carry risk and should be approached with realistic time allowances and early consultation.
Which Sesame lift is most straightforward for US approval?
Fully enclosed designs such as the Windsor Lift are typically the most straightforward.
Can retracting stair lifts be approved in the USA?
In some jurisdictions, yes, depending on guarding, gate strategy, and AHJ interpretation.
Next Steps
If you are assessing a UK-designed accessibility lift for a project in the United States, early technical discussion is essential.
You can book a Teams meeting with one of our Project Managers to review AHJ approval routes and suitability for your project here:
https://www.sesameaccess.com/book-a-meeting