Accessible Transient Lodging and the Americans with Disabilities Act
Photo of Hotel from Holiday Inn
Accessible transient lodging must comply with the Americans with Disabilities Act (ADA). This article will discuss the general requirements for ADA accessible transient lodging in public accommodations and at State or local government facilities. 2010 ADA Standard 224 covers scoping requirements for transient lodging and Standard 806 covers technical requirements for transient lodging. The photo on the right is representative of a place of public accommodations for transient lodging.
The word “transient” is defined with respect to time as “lasting only for a short period of time.” Transient lodging is defined in the 2010 ADA Standards as a building or facility containing one or more guest room(s) for sleeping that provides accommodations that are primarily short-term in nature. This definition can include hotels, motels, inns, and other facilities that offer sleeping rooms for short-term stays (generally 30 days or less) and meet certain other conditions.
In the 2010 ADA Standards, the term “sleeping room” is intended to be used interchangeably with the term “guest room” as it is used with respect to transient lodging.
Transient lodging does not include residential dwelling units. A residential dwelling unit is defined in the 2010 ADA Standards as a unit intended to be used as a residence, that is primarily long-term in nature. Examples of residential dwelling units includes dormitories and apartment buildings.
Apartments or townhouse facilities that are provided by or on behalf of a place of education, which are leased on a year-round basis exclusively to graduate students or faculty, and do not contain any public use or common use areas available for educational programming, are not subject to the transient lodging ADA standards.
Transient lodging also does not include inpatient medical care facilities, licensed long-term care facilities, detention or correctional facilities, or private buildings or facilities that contain not more than five rooms for rent or hire and that are actually occupied by the proprietor as the residence of such proprietor.
Owners or operators of transient lodging must maintain their facilities in compliance with the ADA. The general elements in these facilities that need to be ADA compliant include:
Parking areas - If self parking is provided, there must be at least the minimum number of accessible parking spaces provided, as required by the ADA parking spaces table.
Loading zones - If any loading zones for public use are present, a portion of the loading zone must be ADA accessible.
Exterior routes - Exterior routes must allow disabled individuals to approach, enter and use each facility on a given site. Exterior routes start at the site arrival points.
Building Entrances - At least 60% of all exterior public pedestrian entry/exit entrances should be ADA accessible. Entrances that are not accessible should have signage to direct disabled individuals to accessible entrances.
Interior Lobby - All aspects of the lobby should be compliant with the ADA including the floor surfaces, counters, dispensers, protruding objects, doors, and clear spaces in the waiting areas. If a portion of the lobby is used for breakfast service, the lobby should be approachable and usable as a food service area by persons with disabilities.
Interior Routes - Interior routes to the sleeping rooms, public toilet rooms, amenities, restaurants and bars, etc., should be compliant for floor surfaces, route width and slope, doors, elevators, stairs, areas of rescue, protruding objects, drinking fountains, public telephones, public computer spaces, etc.
Public Use Restrooms - Interior restrooms for use by the public must be ADA compliant for doors, sinks, toilets, toilet stalls, urinals, changing tables, dispensers and turning spaces.
Food Service Areas - At least 5% of all fixed tables or portions of eating counters should be ADA accessible. Food service counters should have a portion of the counter that is accessible. If a portion of the lobby is used for breakfast service, the lobby should be approachable and usable as a food service area by persons with disabilities.
Accessible Guest Sleeping Rooms - These rooms should have compliant entry/exit doors and bathroom doors, and accessible toilet/bathing rooms including access to the shower, toilet, sinks, and tubs, if applicable. Accessible guest sleeping rooms should be arranged so that persons who use wheelchairs, crutches and other mobility aids can approach and use beds; bathrooms; closets; heating, air conditioning and drapery controls; lamps and light switches; telephones; computer outlets; mirrors; televisions; balconies; and other room features without moving furniture. Turning spaces should be included in the sleeping rooms and bathing room. Close captioning should be available on televisions in accessible sleeping rooms designed for people with impaired hearing. A folding seat shall be provided in roll-in type showers. A hand-held spray unit should be installed in showers.
Kitchens and Kitchenettes - These spaces should have compliant routes with clear spaces to all elements including a sink, cabinets, refrigerator, range, microwave, etc. A portion of the counter(s) should be accessible. Appliances must be ADA accessible for reach ranges and operable parts.
Teletypewriter (TTY) Installations - There should be a TTY available at the front desk so that lodging facility personnel can communicate with persons who are deaf or have speech impairments. The facility should have a reasonable number of TTYs available for use by persons with impaired hearing.
Interior Signs - Signs should be properly designed and mounted for all permanent spaces such as guestrooms, public and employee restrooms, restaurant, meeting rooms, banquet rooms, retails sales spaces, guest amenities spaces such as exercise rooms and laundry rooms, mechanical and electrical rooms, stairways, emergency exits, areas of rescue.
Fire Alarm System - Transient lodging guest rooms required to comply with Standard 224.4 shall provide alarms complying with Standard 702. If the facility has an audible fire alarm system, there should also be visual alarm strobe light components mounted 80 inches above the finished floor in required spaces such as the lobby, public corridors, restaurants, other food vending areas, ballrooms, meeting rooms, public and employee restrooms, all retail spaces, guest laundry, exercise room, business center, guest sleeping rooms designated for people who have impaired hearing, etc. Corridors should have smoke alarms mounted within 15 feet of the end of the corridor(s) and at least every 100 feet of long corridors.
Facility Maintenance - Accessible features inside and outside the lodging facility should be maintained in good working order. Periodic inspections of these features should be completed and documented to verify compliance for operational capabilities.
Staff Training - Facility staff should be trained, willing, able and available to move furniture, and provide and adjust accessible features in guestrooms when features require installation or adjustment to ensure accessibility. The facility staff should be trained to offer assistance, upon request, to persons with disabilities who cannot transport their luggage to/from their guestrooms/suites and who may need assistance in locating guestrooms and hotel amenities. Facility staff should be trained in operation of TTY equipment.
Room Reservations - Transient lodging facilities should have methods for persons with disabilities to reserve accessible guestrooms/suites in the same ways and on the same terms that other persons that are not disabled can reserve guestrooms/suites. Accessible guestrooms/suites for possible use by persons with disabilities should be held until all other rooms in the same price category have been rented.
Reservations Information - All staff should have ready access to information about the lodging facility's accessible guestrooms/suites for use in making reservations and answering questions. This information should include specific information on types and sizes of accessible beds, showers, bathtubs and other features such as tub seats. Printed materials provided for use by guests who are not disabled should also be available in alternate formats so that blind persons and persons with low vision can read them.
Transportation - If the facility offers transportation services for guests who are not disabled, accessible transportation should be readily available for guests who are disabled without additional charge. Staff should specifically inform guests who are blind or who have low vision of the presence of the transportation services. Staff shuttle bus drivers should be trained to offer assistance to people who are blind or who have low vision. Drivers should announce all stops to riders who are blind or who have low vision. Service animals such as guide dogs should be permitted to accompany their handlers and/or owners.