Accessible transient lodging guest sleeping rooms must comply with the Americans with Disabilities Act (ADA). The 1991 standards apply to all hotels that began construction before March 15, 2012, provided that no alterations to guest rooms have taken place since that date. For all hotels built or which have undergone alterations to accessible guest rooms on or after March 15, 2012, the 2010 standards apply.

This article will discuss the scoping and technical requirements in the 2010 ADA Standards for ADA accessible transient lodging sleeping rooms 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 schematic below is representative of an ADA compliant transient lodging guest sleeping room.

Scoping Requirements

2010 ADA Standard 224.1.1, [Transient Lodging] Alterations, states, “Where guest rooms are altered or added, the requirements of [Standard] 224 shall apply only to the guest rooms being altered or added until the number of guest rooms complies with the minimum number required for new construction.” The minimum number required for new construction is found in Table 224.2 below.

In alterations and additions, the minimum required number of accessible guest rooms is based on the total number of guest rooms altered or added instead of the total number of guest rooms provided in a facility. Typically, each alteration of a facility is limited to a particular portion of the facility. When accessible guest rooms are added as a result of subsequent alterations, compliance with 224.5 (Dispersion) is more likely to be achieved if all of the accessible guest rooms are not provided in the same area of the facility.

2010 ADA Standard 224.2, [Transient Lodging] Guest Rooms with Mobility Features, states, “In transient lodging facilities, guest rooms with mobility features complying with [Standard] 806.2 shall be provided in accordance with Table 224.2.” Standard 806.2 covers guest rooms with mobility features. Table 224.2 is shown below.

Using the table above, if a hotel has 100 rooms, five must be accessible and have mobility features for disabled individuals, and, of those five, at least one has to have a roll-in shower, and the other four accessible guest rooms should have an accessible bathing room without a roll-in shower, such as a transfer shower or bathtub.

2010 ADA Standard 224.1.2, [Transient Lodging] Guest Room Doors and Doorways, states, “Entrances, doors, and doorways providing user passage into and within guest rooms that are not required to provide mobility features complying with [Standard] 806.2 shall comply with [Standard] 404.2.3.” Standard 404.2.3 requires door openings to provide a clear width of 32 inches minimum, measured between the face of the door and the stop, with the door open 90 degrees. The graphic on the right is representative.

Because of the social interaction that often occurs in lodging facilities, an accessible clear opening width is required for doors and doorways to and within all guest rooms, including those not required to be accessible. This applies to all doors, including bathroom doors, that allow full user passage. Other requirements for doors and doorways in Section 404 do not apply to guest rooms that are not required to provide mobility features. In other words, all guest room doors in a transient lodging facility have to be 32 inches wide minimum, when opened. This applies to rooms for the disabled and rooms not for the disabled.

An exception for this Standard is that shower and sauna doors in guest rooms that are not required to provide mobility features complying with Standard 806.2 shall not be required to comply with Standard 404.2.3.

2010 ADA Standard 224.4, [Transient Lodging] Guest Rooms with Communication Features, states, “In transient lodging facilities, guest rooms with communication features complying with 806.3 shall be provided in accordance with Table 224.4.” See the table below.

2010 ADA Standard 224.5, [Transient Lodging] Dispersion, states, “Guest rooms required to provide mobility features complying with [Standard] 806.2 and guest rooms required to provide communication features complying with [Standard] 806.3 shall be dispersed among the various classes of guest rooms, and shall provide choices of types of guest rooms, number of beds, and other amenities comparable to the choices provided to other guests. Where the minimum number of guest rooms required to comply with [Standard] 806 is not sufficient to allow for complete dispersion, guest rooms shall be dispersed in the following priority: guest room type, number of beds, and amenities. At least one guest room required to provide mobility features complying with [Standard] 806.2 shall also provide communication features complying with [Standard] 806.3. Not more than 10 percent of guest rooms required to provide mobility features complying with [Standard] 806.2 shall be used to satisfy the minimum number of guest rooms required to provide communication features complying with [Standard] 806.3.”

In other words, transient lodging facilities are required to have at least one room with both mobility features and communication features. It is common for transient lodging facilities to design more than one of the mobility accessible rooms with communication features, and they are allowed to dual purpose up to 10% of the mobility accessible rooms towards satisfying the communication requirements.

Factors to be considered in providing an equivalent range of options to comply with dispersion should prioritize guest room type, number of beds, and amenities. Within these priorities factors may include, but are not limited to, room size, bed size, cost, view, bathroom fixtures such as hot tubs and spas, smoking and nonsmoking, and proximity to facility amenities provided such as a pool, laundry room, restaurant, and business center.

2010 ADA Standard 215.4, [Fire Alarm Systems] Transient Lodging, states, “Guest rooms required to comply with [Standard] 224.4 shall provide alarms complying with [Standard] 702.” More on this below.

Technical Requirements

2010 ADA Standard 608.4, [Shower Compartments] Seats, states, “A folding or non-folding seat shall be provided in transfer type shower compartments. A folding seat shall be provided in roll-in type showers required in transient lodging guest rooms with mobility features complying with [Standard] 806.2. Seats shall comply with [Standard] 610.” The graphic below is representative of a roll-in shower with a fold-up seat.

Standard 806 covers the technical requirements for transient lodging, but only in a broad sense. The requirements in Standard 806 do not include specific requirements that are common to all accessible spaces. For example, showers in guest rooms must comply with the applicable provisions for showers specified in scoping.

The following two ADA Standards are very broad based in their language about requirements for ADA compliance. 2010 ADA Standard 806.2.1, Living and Dining Areas, states, “Living and dining areas shall be accessible.” 2010 ADA Standard 806.2.2, Exterior Spaces, states, “Exterior spaces, including patios, terraces and balconies, that serve the guest room shall be accessible.”

That’s it. So what does this mean? This is where the statement above comes in that the requirements in Standard 806 do not include requirements that are common to all accessible spaces. So owners and operators have to know what these requirements common to all accessible spaces are. These requirements include floor surfaces, protruding objects, doors, clear spaces, door maneuvering spaces, etc., that are found throughout the ADA Standards.

2010 ADA Standard 806.2.3, [Transient Lodging] Sleeping Areas, states, “At least one sleeping area shall provide a clear floor space complying with [Standard] 305 on both sides of a bed. The clear floor space shall be positioned for parallel approach to the side of the bed. EXCEPTION: Where a single clear floor space complying with [Standard] 305 positioned for parallel approach is provided between two beds, a clear floor or ground space shall not be required on both sides of a bed.” So if there is one bed in the room, there must be two clear spaces for the bed. If there are two beds in the room, there only has to be one clear spaced, between the beds and shared by the beds. But there can be more than one clear space. The graphic above is representative of a clear space.

2010 ADA Standard 806.2.4, [Transient Lodging] Toilet and Bathing Facilities, states, “At least one bathroom that is provided as part of a guest room shall comply with [Standard] 603. No fewer than one water closet [toilet], one lavatory [sink], and one bathtub or shower shall comply with applicable requirements of [Standards] 603 through 610. In addition, required roll-in shower compartments shall comply with [Standards] 608.2.2 or 608.2.3. Toilet and bathing fixtures required to comply with [Standards] 603 through 610 shall be permitted to be located in more than one toilet or bathing area, provided that travel between fixtures does not require travel between other parts of the guest room.” In other words, if an ADA accessible guest room includes a bathing room, that bathing room must also meet ADA accessibility requirements. And there are a lot.

2010 ADA Standard 806.2.4.1, [Transient Lodging] Vanity Counter Top Space, states, “If vanity counter top space is provided in non-accessible guest toilet or bathing rooms, comparable vanity counter top space, in terms of size and proximity to the lavatory, shall also be provided in accessible guest toilet or bathing rooms.” Vanity space is broken out separately here to make sure that a disabled room has equal or better vanity space than that of a room not ADA compliant.

2010 ADA Standard 806.2.5, [Transient Lodging] Kitchens and Kitchenettes, states, “Kitchens and kitchenettes shall comply with [Standard] 804.” Standard 804 covers kitchens and kitchenettes in detail. Transient lodging suites often have kitchens or kitchenettes. If the ADA suite is accessible, the kitchen or kitchenette must be ADA accessible also.

2010 ADA Standard 806.2.6, [Transient Lodging] Turning Space, states, “Turning space complying with [Standard] 304 shall be provided within the guest room.” Standard 304 covers turning spaces as represented in the graphic below. Accessible sleeping rooms and bathing rooms both must have a compliant turning space.

2010 ADA Standard 806.3, [Transient Lodging] Guest Rooms with Communication Features, states, “Guest rooms required to provide communication features shall comply with [Standard] 806.3.”

In guest rooms required to have accessible communication features, consider ensuring compatibility with adaptive equipment used by people with hearing impairments. To ensure communication within the facility, as well as on commercial lines, provide telephone interface jacks that are compatible with both digital and analog signal use. If an audio headphone jack is provided on a speaker phone, a cutoff switch can be included in the jack so that insertion of the jack cuts off the speaker. If a telephone-like handset is used, the external speakers can be turned off when the handset is removed from the cradle. For headset or external amplification system compatibility, a standard subminiature jack installed in the telephone will provide the most flexibility.

2010 ADA Standard 806.3.1, [Guest Rooms with Communication Features] Alarms, states, “Where emergency warning systems are provided, alarms complying with [Standard] 702 shall be provided.”

2010 ADA Standard 702.1, [Fire Alarm System] General, states, “Fire alarm systems shall have permanently installed audible and visible alarms complying with NFPA 72 (1999 or 2002 edition) (incorporated by reference, see “Referenced Standards” in Chapter 1), except that the maximum allowable sound level of audible notification appliances complying with section 4-3.2.1 of NFPA 72 (1999 edition) shall have a sound level no more than 110 dB at the minimum hearing distance from the audible appliance. In addition, alarms in guest rooms required to provide communication features shall comply with sections 4-3 and 4-4 of NFPA 72 (1999 edition) or sections 7.4 and 7.5 of NFPA 72 (2002 edition).” These NFPA requirements mostly cover decibel levels, light frequency and brightness, and locations of the alarms. Basically, an audible and visual smoke alarm is required in each sleeping room and should be mounted on the ceiling or on a wall at least 80 inches above the finished floor.

2010 ADA Standard 806.3.2, [Guest Rooms with Communication Features] Notification Devices, states, “Visible notification devices shall be provided to alert room occupants of incoming telephone calls and a door knock or bell. Notification devices shall not be connected to visible alarm signal appliances. Telephones shall have volume controls compatible with the telephone system and shall comply with [Standard] 704.3. Telephones shall be served by an electrical outlet complying with [Standard] 309 located within 48 inches (1220 mm) of the telephone to facilitate the use of a TTY.” In other words, there needs to be an audible and visual signal to indicate an incoming telephone call and someone at the entry door.

2010 ADA Standard 704.3, [Telephones] Volume Control Telephones, states, “Public telephones required to have volume controls shall be equipped with a receive volume control that provides a gain adjustable up to 20 dB minimum. For incremental volume control, provide at least one intermediate step of 12 dB of gain minimum. An automatic reset shall be provided.”

SUMMARY

Accessible transient lodging guest sleeping rooms must comply with the Americans with Disabilities Act (ADA). Hotels, motels, and inns must have a minimum number of accessible sleeping rooms based on the overall number of sleeping rooms. These accessible sleeping rooms must have accessible features and, if installed, accessible bathing rooms and kitchens or kitchenettes.

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If you observe a hotel, motel or inn that is not ADA compliant and you would like to know how to proceed, please see the link at What To Do When A Building Is Not ADA Compliant or Accessible.

ADA Inspections Nationwide, LLC, offers ADA/ABA/FHA accessibility compliance inspections for buildings and facilities, as applicable to the different laws, and expert witness services with respect to ADA/ABA/FHA laws for building owners, tenants and managers. Also, ADAIN offers consulting for home modifications as a CAPS consultant for people wishing to age in place in their homes. For a complete list of services please see ADAIN Services.

Thank you.