Fall Protection vs. Egress Requirements for Bedroom Windows (PDF)

The 2020 National Building Code of Canada created a conflict affecting openable windows in many homes. On one hand, a new fall protection provision now requires operable windows to be limited and only releasable with tools or special knowledge.  On the other hand, egress provisions require a bedroom window to open fully and be easily releasable without tools, keys, or special knowledge. 

For some bedroom windows, it is therefore impossible to meet both requirements at the same time, which leaves builders and inspectors unsure how to resolve this conflict, with different interpretations emerging across provinces and even between inspectors.

Fall Protection Requirements

Any openable window located higher than 1.8 meters above the surface on the other side must include fall protection by a guard or a device limiting the window to an opening of 100mm. The device or mechanism must only be releasable using tools or special knowledge, so it cannot be easily defeated by children.

This does not apply where the windowsill is higher than 900 mm above the interior floor.

Bedroom egress requirements

For bedrooms in homes, at least one window must serve as an emergency exit and must be openable from the inside without the use of keys, tools, or special knowledge. 

The egress window must provide a minimum, unobstructed or clear opening size of 0.35 m² with no dimension smaller than 380 mm, so a person can escape. 

Are there solutions?

One potential solution is the use of Window Opening Control Devices (WOCD). 

These devices limit the initial opening of a window to reduce the risk of falls, but they can be released by the occupant in an emergency to allow the window to open fully. When the window is closed, the device automatically re-engages. While a WOCD is designed to address both fall protection and emergency egress, its acceptance varies by jurisdiction. Some provinces, such as Quebec and Alberta[JM1.1], allow their use through provincial acceptance or variances, while other provinces do not. In the United States, similar devices are permitted – and in some cases – required.     

What Builders and Renovators Should Do

To navigate this, builders and renovators should explore whether changing the windowsill height from the interior floor (to more than 900mm) or to the exterior ground (less than 1800mm) is possible to avoid the fall protection requirements being triggered. Egress windows are recommended not to be higher than 1500mm above the interior floor. 

If staying outside the min/max height limits cannot be achieved through re-design, consider whether an approved guard can be installed in front of the window. 

Where the code conflict is unavoidable, work with the municipality for your project during the planning stage to help avoid unexpected and costly surprises. Consider proposing the use of Window Opening Control Devices (WOCDs) that comply with ASTM F2090 to the authority having jurisdiction. These devices limit window openings to 100 mm but can be released for emergency escape.

Note: manual night locks are not to be confused with WOCDs. Check with your window supplier on available options to ensure the device is an approved WOCD in compliance with ASTM F2090.

Monitor code updates, as Fenestration Canada and CHBA are advocating for changes in future codes to solve this conflict.