Cal. Civ. Code § 188
Bulkheads and scuttles
Operative Text
§ 188. Bulkheads and scuttles. Except as provided in paragraph g of subdivision three of section one hundred seventy-one, bulkheads and scuttles shall conform to the following provisions: 1. Every required bulkhead to and through the roof shall be fireproof or constructed of wood covered with metal on the outside and fire-retarded on the inside, and shall have a fire-retarded door and assembly with the door self-closing. Every stair extending through a bulkhead shall have a hand rail. 2. Every scuttle shall be at least twenty-one inches in width and twenty-eight inches in length, covered on the outside with metal and provided with a stair or a stationary iron ladder leading thereto and easily accessible to all occupants of the dwelling. Every scuttle shall be located in the ceiling of the stair hall on the top story and access to the roof through the scuttle shall be direct and uninterrupted. It shall be unlawful to enclose in any manner the ladder or stair leading to a scuttle. 3. Every bulkhead door or scuttle shall not be self-locking and shall be fastened on the inside with movable bolts, hooks, or a lock which does not require a key to open from the inside of the dwelling. 4. Where a dwelling has a peak roof with a pitch of more than fifteen degrees, no bulkhead or scuttle, or stair or ladder leading thereto, shall be required.
New York Multiple Dwelling Law § 188 sets out construction and access standards for two types of roof-access points in multiple dwellings: bulkheads (enclosed stairway structures) and scuttles (hatch-style openings). Bulkheads must meet fire-resistance requirements, including self-closing fire-retarded doors and handrails on any stairs passing through them. Scuttles must meet minimum size dimensions, be metal-covered on the outside, and be reached by an unobstructed stair or iron ladder that cannot be enclosed; critically, neither bulkheads nor scuttles may use locks that require a key to open from inside the building. Buildings with steeply pitched roofs exceeding fifteen degrees are exempt from these requirements under § 188(4).
Plain English — not legal advice.
Property owners and managers subject to N.Y. Mult. Dwell. Law § 188 generally ensure that bulkhead doors are self-closing, fire-retarded, and equipped with hardware that allows exit from inside without a key. Compliant operators also verify that any scuttle meets the minimum 21-by-28-inch dimension, is metal-clad on the exterior, and is served by a fully unobstructed ladder or stair — no enclosures of any kind around that access path. Routine inspections of bulkhead and scuttle hardware, including bolt and latch mechanisms, help confirm that the no-key-required exit standard under § 188(3) is continuously maintained.
General guidance for property managers — not legal advice for your specific situation. Consult an attorney for advice on your case.
Under N.Y. Mult. Dwell. Law § 188, tenants in covered multiple dwellings have a right to roof-access points that are safely constructed and freely exitable from inside without a key. If a scuttle ladder is blocked or enclosed, a bulkhead door is self-locking, or hardware otherwise prevents keyless interior exit, these conditions may constitute violations of § 188 that can be reported to the New York City Department of Buildings or the relevant local housing enforcement agency. Tenants who observe such conditions may also consult a tenant-rights organization to understand what complaint or defense options are available to them.
General guidance for tenants — not legal advice for your specific situation. Consult a tenant-rights organization or attorney for advice on your case.
Generated September 13, 2026 — auto-generated, not yet human-reviewed. See /transparency for methodology.
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