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U.S. Department of Justice

Civil Rights Division

Disability Rights Section

Reproduction of this document

is encouraged. 11/99

Common ADA Problems

at Newly Constructed Lodging Facilities

Hotels, motels, inns, and other

places of lodging designed and

constructed after January 26,

1993 must comply with the

Americans with Disabilities Act

(ADA). To comply with the

ADA and to make it possible for

persons with disabilities to use

lodging facilities like everyone

else, lodging facilities must meet

specific requirements set out in

Justice Department regulations,

28 C.F.R. pt. 36. These

regulations include detailed

architectural requirements

known as the ADA Standards

for Accessible Design (ADA

Standards), 28 C.F.R. pt. 36,

Appendix A. The ADA

Standards are designed to make

lodging facilities usable by

persons with a wide variety of

disabilities, including persons

who are blind or who have low

vision, persons who are deaf or

hard of hearing, persons with

mobility impairments who use

wheelchairs, canes, crutches, or

walkers, and persons with other

disabilities or with combinations

of disabilities.

Introduction

The Justice Department is the

government agency responsible

for enforcing the ADA at

lodging facilities. As part of

ADA enforcement efforts, the

Department has conducted

numerous on-site investigations

of hotels, motels, inns, and

other places of lodging. During

these investigations, the

Department has observed certain

common ADA problems at

newly constructed lodging

facilities. This publication

describes those problems so that

owners, franchisors, architects,

and building contractors can

avoid these common ADA

mistakes and comply with the

law when designing and

constructing new facilities. This

document is not intended to be

comprehensive or exhaustive.

Any failure to comply with the

ADA Standards violates the

ADA.

For additional information about

the design and construction

requirements of the ADA,

contact the Department of

Justice ADA Information Line.

This free service provides

answers to general and technical

questions about ADA

requirements and is a source for

free ADA materials including

the ADA Standards for

Accessible Design, "Five Steps

to Make New Lodging Facilities

Comply with the ADA," and

"ADA Checklist for Newly

Constructed Lodging Facilities,"

and "Common ADA Errors and

Omissions in New Construction

and Alterations." You may

reach the ADA Information Line

at: 800-514-0301 (voice) or

800-514-0383 (TTY). ADA

information is also available on

the Department’s ADA Home

Page on the World Wide Web at

(http://www.usdoj.gov/crt/ada/

adahom1.htm).
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Measuring Clear Width

Guestroom Doors

Common Problem:

Doors and doorways into and within all guestrooms and suites,

including bathroom doors and doorways, do not allow 32 inches of

clear opening width.

Result:

Doors and doorways into and

within guestrooms and suites and,

in particular, bathroom doors and

doorways within these spaces are

too narrow to allow persons who

use wheelchairs, crutches, walkers,

and other mobility aids to pass

through them. As a result, persons

with disabilities are excluded from

accommodations when accessible

guestrooms are sold out and also

are unable to visit other guests in

their rooms.

Requirements:

All doors and doorways (except

shallow closets) into and within all

guestrooms and suites (including

guestroom bathrooms, kitchens, and

connecting room doors) shall

provide 32 inches of clear opening

width measured when a hinged door

is open 90 degrees or a sliding door

is fully opened.

ADA Standards 9.4; 4.13.5.
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Guestroom Types and Features

Common Problem:

Accessible guestrooms are not dispersed among the various classes

of rooms available at a lodging facility and do not provide people

with disabilities the same range of amenities available to others.

Result:

Persons with disabilities who desire

or may need different classes of

accessible guestrooms are denied

the range of lodging options that

other guests without disabilities

can take for granted (e.g., rooms

with one or two beds, suites).

Requirements:

In order to provide persons with

disabilities the same range of

options that are available to other

persons at the facility, lodging

facilities must disperse accessible

guestrooms/suites among the

various classes of guestrooms/

suites available at the facility.

Factors to be considered in

dispersing accessible guestrooms

among different classes of rooms

include room size, cost, amenities

provided (e.g., smoking and

nonsmoking rooms, suites,

kitchenettes, rooms with preferred

views, connecting rooms), and the

number of beds provided.

ADA Standards 9.1.4.

Accessible Guestroom Choices

Rooms with One Bed

Rooms with Two Beds

Suites

Smoking and Nonsmoking Rooms

✍

✓

✓

✓

✓
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Fig. 57

Roll-in Shower

with Folding Seat

Guestrooms with Roll-in Showers

Common Problem:

In hotels, motels, or other lodging facilities of 50 or more sleeping

rooms, no rooms with roll-in showers are provided, or the roll-in

showers that are provided lack a permanently attached fold-down

seat.

Result:

Some people with mobility

impairments, such as persons who

use wheelchairs, walkers, crutches,

and other mobility aids, must use a

roll-in shower or a shower with a

fold-down seat in order to shower.

When a roll-in shower is not

provided or when the roll-in

shower lacks a folding seat,

these guests may not be able

to shower or may resort to

using guestroom furniture in

the shower.

Requirements:

Lodging facilities must provide a

specific number of accessible

guest rooms based on the table

provided below. Bathing facilities

in these rooms must comply with

the Standards. In addition, in

lodging facilities with more than

50 guestrooms or suites, the

facility must provide a specified

number of accessible guestrooms

that have a roll-in shower with a

permanently attached fold-down

seat. The roll-in shower in these

rooms must comply with specific

requirements contained in Figure

57 of the Standards, shown on

this page.

ADA Standards 9.1.2; 9.2; 4.21;

Figure 57(a) or (b).

Total Guestrooms Required Accessible Guestrooms

 1 to 25 1

 26 to 50 2

 51 to 75 4 (1 with roll-in shower)

 76 to 100 5 (1 with roll-in shower)

 101 to 150 7 (2 with roll-in showers)

 151 to 200 8 (2 with roll-in showers)

 201 to 300 10 (3 with roll-in showers)

 301 to 400 12 (4 with roll-in showers)

 401 to 500 13 (4 with roll-in showers)

 501 to 1000 2% of all rooms (plus 1 room with a

 roll-in shower for each 100 rooms)

 1001 and over 20 plus 1 for each 100 over 1000

 (plus 1 room with a roll-in shower

 for each 100 rooms)

(a)

(b)
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Visual Alarms

Common Problem:

Accessible guestrooms and suites (and an additional number of

rooms specifically for individuals who are deaf or hard of hearing)

are not equipped with visual alarms and other visual notification

devices.

Result:

People who are deaf or hard of

hearing cannot hear fire alarms,

ringing telephones, knocking at

doors or ringing doorbells.

Consequently, when accessible

guestrooms and other guestrooms

do not have visual fire alarms and

visual notification devices, people

who are deaf or hard of hearing

have no notice of fires or other

life-threatening emergencies and

have no means of knowing when

the telephone is ringing, when

someone is knocking on the door,

or when someone is ringing the

doorbell.

Requirements:

All accessible guestrooms and a

specific number of additional

guestrooms for use by persons

who are deaf or hard of hearing

must be equipped with visual fire

alarm strobes that are connected

to the building’s fire alarm system

and visual notification devices to

alert guests who are deaf or hard

of hearing to telephone calls and

to persons knocking on the door

and/or ringing the doorbell. While

visual alarms must be connected

to the fire alarm system,

notification devices (for doors and

telephones) may be provided in

kits available at the lodging

facility’s registration desk. In

addition to accessible guestrooms,

lodging facilities must provide

additional guestrooms for persons

who are deaf or hard of hearing

following the table on this page.

ADA Standards 9.1.3; 9.2.2 (8);

9.3; 9.3.2.

 Guestrooms for Use by Persons

Total Guestrooms Who Are Deaf or Hard of Hearing*

 1 to 25 1

 26 to 50 2

 51 to 75 3

 76 to 100 4

 101 to 150 5

 151 to 200 6

 201 to 300 7

 301 to 400 8

 401 to 500 9

 501 to 1000 2% of all rooms

 1001 and over 20 plus 1 for each

100 over 1000

*Rooms for persons who are deaf or hard of hearing

are required in addition to accessible guestrooms.
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Operating Hardware

Common Problem:

The shape of the hardware on accessible doors, and on faucets,

fixed lamps, drapery controls, and heating and air conditioning

controls in spaces required to be accessible requires tight grasping,

pinching, and twisting of the wrist.

Result:

Persons who have the use of only

one hand or who have limited use

of hands, wrists, or arms are

unable to open doors to get into

rooms, lock doors for security, use

sinks or showers to wash, adjust

draperies for privacy, turn on

lamps, or adjust heating or air

conditioning levels for comfort.

Requirements:

Handles, pulls, latches, locks, and

other operating devices on

accessible doors; faucets; fixed

lamps; and drapery, heating, and

air conditioning controls shall

have a shape that is easy to grasp

with one hand and does not

require tight grasping, tight

pinching, or twisting of the wrist

to operate. Lever-operated

mechanisms, push-type

mechanisms, and U-shaped

handles are acceptable designs.

ADA Standards 4.13.9; 9.2.2(3);

9.2.2(5).

single-lever handle that is

easy to reach and operable

with one hand
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Signage

Common Problem:

For permanent rooms and spaces, identification signage is

mounted in the wrong location and cannot be read by persons who

are blind or have low vision.

Result:

Blind persons and persons with

low vision will have difficulty

locating rooms. If Braille and

raised letter signs are mounted on

doors instead of walls, blind

persons and persons with low

vision may be hurt by someone

who is pushing a door open while

they are trying to read a sign or

they may not be able to find the

sign.

Requirements:

Signs that are provided for all

permanent rooms and spaces in

the lodging facility must be

mounted on the wall (not the

door) adjacent to the latch side of

the door and centered 60 inches

above the floor so that they can be

easily located by persons who are

blind or who have low vision.

Signs must include the same

information in Braille, with raised

lettering that forms a high contrast

with the background of the sign.

Signs should not be made of

reflective materials such as brass,

silver, gold, glass, or mirrored

surfaces unless there is an

additional properly located sign

that complies with the Standards.

ADA Standards 4.1.3(16)(a);

4.30.4; 4.30.5.

60"
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Accessible Routes -- Interior and Exterior

Common Problem:

Both the exterior pedestrian routes (e.g., sidewalks, walkways and

plazas) on a site that people use to travel from public

transportation stops, from accessible parking spaces, from

passenger loading zones, and from public streets and sidewalks to

the accessible entrance(s), and the interior routes (e.g., hallways

and corridors) throughout the lodging facility, are not usable by

persons who use wheelchairs or other mobility aids, or who are

unable to climb steps or stairs.

Result:

Because people who use

wheelchairs, walkers, scooters or

other mobility aids cannot climb

steps or negotiate curbs, people

with disabilities are

often unable to

travel safely into

the lodging facility

from public

transportation,

parking lots,

passenger drop-off

areas, and public

streets and

sidewalks without

using a vehicular

way. Once inside

the lodging facility,

people with

disabilities cannot

get through the

facility to the

guestrooms,

conference rooms, toilet rooms,

restaurants, or other various

accessible elements and spaces.

Requirements:

At least one route that is a

minimum of 36 inches wide

without steps, stairs, or other

abrupt level changes must be

provided within the boundary of

the lodging facility’s property

from an accessible entrance to the

building to public transportation

stops, accessible parking spaces,

accessible passenger pick-up/

drop-off areas, if provided, and

public streets or sidewalks. Once

inside the facility, an accessible

route must be provided between

an accessible entrance, lobby and

the various accessible elements

and spaces in the lodging facility.

ADA Standards 4.1.2 (1);

4.1.3(1); 4.3.

At least one route that is a minimum

of 36 inches wide without steps,

stairs, or other abrupt level changes

must be provided
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Protruding Objects

Common Problem:

In areas inside and outside the lodging facility where people are

expected to walk, objects protrude too far from the side, from

posts, or hang down too low from overhead.

Result:

People who are blind or who have

low vision can be seriously injured

when they are unable to detect an

object in their path by using the

sweep of their cane.

Requirements:

All objects that protrude from

surfaces or posts and all

overhanging objects in areas

where people walk shall comply

with the following requirements:

Objects mounted on walls at a

height above 27 inches and below

80 inches (e.g., fire extinguishers,

telephones) shall protrude no

more than 4 inches into walks,

halls, corridors, passageways,

aisles, or any other areas where a

person walks.

Free-standing objects mounted on

posts or pylons may not project

more than 12 inches into walks,

halls, corridors, passageways,

aisles, or any other area where a

person walks at heights between

27 inches and 80 inches above the

ground or finished floor.

Stairways and escalators with

undersides that are not enclosed

and all objects hanging above

walks, hallways, corridors,

passageways, aisles, and lobbies

cannot hang down below a height

of 80 inches above the ground or

finished floor, unless there is a

cane-detectible barrier that would

alert a person who is blind or who

has low vision to the hazard.

ADA Standards 4.1.2(3); 4.1.3(2);

4.4.
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Elevators

Common Problem:

Lodging facilities with more than two floors of occupiable space --

including any basement levels -- do not have full-size passenger

elevators available for use by guests.

Result:

People with disabilities who are

unable to use stairs and steps

cannot gain access to floors above

and below the ground level and, in

many instances, do not have access

to the amenities provided in the

lodging facility.

Requirements:

At least one passenger elevator

must serve each level of a facility

that has more than two floors of

occupiable space, including

basement levels. If a facility has

less than 3,000 square feet per

floor, an elevator exemption

applies. All passenger elevators

must meet the requirements of the

Standards.

ADA Standards 4.1.3(5); 4.10.
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Parking

Common Problem:

There are an insufficient number of accessible parking spaces

provided, including van-accessible parking spaces, in the proper

locations.

Result:

Persons with disabilities are

unable to park their vehicles and

do not have convenient access to

the lodging

facility. Persons

who use vans

equipped with a

wheelchair lift

have inadequate

space to lower the

lift and exit the

vehicle.

Requirements:

When a lodging facility offers

“self-parking,” it must have the

proper number of standard

accessible parking spaces and

van-accessible parking spaces as

shown in the table below.

Standard accessible parking

spaces must be at least 8 feet wide

and have or share an access aisle

that is at least 5 feet wide.

Van-accessible spaces must be at

least 8 feet wide and have or share

an access aisle that is at least 8

feet wide. The vertical clearance

for van accessible parking spaces

shall be at least 98 inches. The

surface of all standard accessible

parking spaces and all

van-accessible parking spaces

should be level (i.e., no greater

than 1:50 or 2%). Accessible

parking spaces should be

dispersed so that some of those

spaces are the nearest to the lobby

and others are the nearest spaces

to accessible entrances that serve

accessible guestrooms. All

accessible spaces in a parking

garage may be grouped on one

level of the structure. All

accessible parking spaces must

have signs with the international

symbol of accessibility that are

mounted high enough so that they

are not obscured by parked cars.

ADA Standards 4.1.2 (5); 4.6.2;

4.6.3; 4.6.4.

Total Spaces in Required Number of Accessible

 Parking Lot Parking Spaces

 1 to 25 1 van space

 26 to 50 1 standard space + 1 van space

 51 to 75 2 standard spaces + 1 van space

 76 to 100 3 standard spaces + 1 van space

 101 to 150 4 standard spaces + 1 van space

 151 to 200 5 standard spaces + 1 van space

 201 to 300 6 standard spaces + 1 van space

 301 to 400 7 standard spaces + 1 van space

 401 to 500 7 standard spaces + 2 van spaces

 501 to 1000 2 % of total spaces; 1 in every 8

 accessible spaces must be van-

 accessible

 1001 and over 20 + 1 extra space for each hundred

 spaces over 1000; 1 in every 8

 accessible spaces must be

 van-accessible