Where is a LULA Elevator Allowed?

This questions comes up a great deal and the unfortunate answer is that it depends.  To understand why the question is a little bit complex it helps to understand the differences between a LULA (Limited Use/ Limited Application) Elevator and a Full Commercial Passenger Elevator.

  • LULA elevators are limited use limited application – this means they are limited in weight capacity (1400lb), floor space (18 square feet) and travel distance (7.6m/ 26ft)
  • They are primarily used to accommodate the requirements for an accessible/ barrier free route in commercial buildings
  • They typically do not have sufficient space for a stretcher as a stretcher is 79in by 24in (see guidance on stretcher ready lifts)

The key questions are really whether a building requires a full passenger elevator and whether that elevator needs to be equipped for Fire Emergency Operation (FEO) or be a Fire Service Access Elevator (FSAE). Whether a building requires a passenger elevator is a complex question and depends on 3 main factors:

  1. The Authority Having Jurisdiction (AHJ) and their specific local requirements
  2. Fire Protection/ firefighter access
  3. Barrier Free Accessibility

The International Building Code provides guidance on a variety of topics including accessible routes. For instance, in IBC section 1104.4 Multilevel buildings and facilities. “At least one accessible route shall connect each accessible level, including mezzanines, in multilevel buildings and facilities. Exceptions:

1. An accessible route is not required to stories and mezzanines that have an aggregate area of not more than 3,000 square feet (278.7 m2) and are located above and below accessible levels. This exception shall not apply to:

1.1. Multiple tenant facilities of Group M occupancies containing five or more tenant spaces;

1.2. Levels containing offices of health care providers (Group B or I); or

1.3. Passenger transportation facilities and airports (Group A-3 or B).

2. Levels that do not contain accessible elements or other spaces as determined by Section 1107 or 1108 are not required to be served by an accessible route from an accessible level.

3. In air traffic control towers, an accessible route is not required to serve the cab and the floor immediately below the cab.

4. Where a two-story building or facility has one story with an occupant load of five or fewer persons that does not contain public use space, that story shall not be required to be connected by an accessible route to the story above or below.

5. Vertical access to elevated employee work stations within a courtroom is not required at the time of initial construction, provided a ramp, lift or elevator can be installed without requiring reconfiguration or extension of the courtroom or extension of the electrical system.”


The international building code also states in  section 1007.2.1 Elevators required “In buildings where a required accessible floor is four or more stories above or below a level of exit discharge, at least one required accessible means of egress shall be an elevator complying with Section 1007.4. Exceptions:

1. In buildings equipped throughout with an automatic sprinkler system installed in accordance with Section 903.3.1.1 or 903.3.1.2, the elevator shall not be required on floors provided with a horizontal exit and located at or above the levels of exit discharge.

2. In buildings equipped throughout with an automatic sprinkler system installed in accordance with Section 903.3.1.1 or 903.3.1.2, the elevator shall not be required on floors provided with a ramp conforming to the provisions of Section 1010.”


It should be noted that 2 Fire Service Access Elevators are required for any building that has an occupied level more than 120ft above ground level. FSAE’s are an even more robust rating than a standard passenger elevators but this travel distance is well beyond the limit of LULA elevators.  – http://www.neii.org/iccfsae.cfm

RAM Provides LULA products in North America so looking at this from a Canadian and US code perspective there are a few more points to consider:


Canada Building Code – 2006

  • The Class of building being considered will dictate many things including whether an elevator is required but in general if a building is under 3 storeys then a passenger elevator is not required and a LULA elevator can be used in place of a full passenger elevator as part of barrier free accessibility design.
  • According to section if a LULA is used in a building in place of a full passenger elevator then the floor must be sprinklered through out and have a number of other fire separation requirements met. If those requirements ae not met then a full passenger elevator with all the fire operation requirements outlined in and of the Canadian building code will be required


United States of America Guidance

The ADA (Americans with Disabilities Act) outlines that generally elevators are required in commercial buildings but section 4.1.3 has the following exceptions:

  • Elevators are not required in facilities under three stories or with fewer than 3000 square feet per floor, unless the building is a shopping center or mall; professional office of a health care provider; public transit station; or airport passenger terminal
  • public facilities that are less than three stories and that are not open to the general public if the story above or below the accessible ground floor houses no more than five persons and is less than 500 square feet. Examples may include, but are not limited to, drawbridge towers and boat traffic towers, lock and dam control stations, and train dispatching towers.
  • Elevator pits, elevator penthouses, mechanical rooms, piping or equipment catwalks are exempted from this requirement
  • Platform lifts (wheelchair lifts) complying with 4.11 of the guideline and applicable State or local codes may be used in lieu of an elevator only under the following conditions: (a) To provide an accessible route to a performing area in an assembly occupancy. (b) To comply with the wheelchair viewing position line-of- sight and dispersion requirements of 4.33.3. (c) To provide access to incidental occupiable spaces and rooms which are not open to the general public and which house no more than five persons, including but not limited to equipment control rooms and projection booths. (d) To provide access where existing site constraints or other constraints make use of a ramp or an elevator infeasible. (e) To provide access to raised judges’ benches, clerks’ stations, speakers’ platform, jury boxes and witness stands or to depressed areas such as the well of a court. (f) To provide access to player seating areas serving an area of sport activity


Some local authorities have specific guidance relating to LULA elevators to try and clarify interpretations of the code. An example of this can be found for the Province of Alberta in the following two links:

In summary, RAM’s guidance for LULA elevator usage and applicability is as follows:

LULA’s are used for meeting accessible route requirements

  1. If a stretcher ready elevator is required, a full passenger elevator should be used unless a variance is issued by the local building authority
  2. A LULA is not meant for Fire Emergency Operation or as an Fire Service Access Elevator but the ASME A17.1/ CSAB44 – 2010 code requires LULA’s to have phase 1 operation
  3. For any building 3 storeys and under, where the travel required is less than 7.6m or 25ft, a LULA can be considered instead of a full passenger elevator
  4. Local building authorities may have additional requirements that negate the use of a LULA and they should be consulted during planning and permitting stages to ensure appropriate use.


Still Confused? Contact us and we’ll do our best to guide you.

Learn more about other Ram Manufacturing Products:

Commercial Elevators
Home Elevators
Commercial Lifts
Home Lifts
Wheelchair Lifts