The Americans with Disabilities Act of 1990 (ADA) established a series of accessible design requirements for the construction of hotels and other lodging facilities that apply to the design of ADA hotel rooms. Most of these regulations remain today, while a few were updated in 2010 to promote greater accessibility. You can access the full text of the 1991 ADA Standards for Accessible Design here and the 2010 standards here.
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 page addresses the accessibility requirements for the most common hotel room features and notes, where possible, which regulations are new to the 2010 standards.
ADA Hotel Room Features & Inventory Requirements
The ADA regulations were developed to protect people of all abilities, not just wheelchair users. As a result, the requirements for accessible hotel design cater to a diverse array of disabilities. Three primary features—bathtubs with grab bars and a seat, roll-in showers with a seat and communication equipment for the hearing and sight-impaired—should be distributed across ADA guest rooms in every hotel.
A hotel’s size dictates the number and types of accessible guest rooms that are required, based on the following chart:
|Size of Hotel (in Guest Rooms)||Required Number of Rooms with ADA Tubs||Required Number of Rooms w/ Roll-in Showers||Total Mobility Accessible Rooms Required||Required Number of Rooms w/ Communication Features|
|2 to 25||1||0||1||2|
|26 to 50||2||0||2||4|
|51 to 75||3||1||4||7|
|76 to 100||4||1||5||9|
|101 to 150||5||2||7||12|
|151 to 200||6||2||8||14|
|201 to 300||7||3||10||17|
|301 to 400||8||4||12||20|
|401 to 500||9||4||13||22|
|501 to 1000||2 percent of total||1 percent of total||3 percent of total||5 percent of total|
|1001 and over||20, plus 1 for each 100, or fraction thereof, over 1000||10, plus 1 for each 100, or fraction thereof, over 1000||30, plus 2 for each 100, or fraction thereof, over 1000||50, plus 3 for each 100 over 1000|
The chart above was assembled based on section 224 (specifically 224.2 and 224.4) of the 2010 ADA Standards.
What if you have both a mobility and hearing/visual impairment? Hotels are required to have at least one room with both mobility features and communication features. In practice, larger hotels often outfit many 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.
“Dispersion” of ADA Guest Rooms
The majority of hotels offer a selection of rooms and suites that differ in size, number of beds, views, amenities and features, and which likely differ in price. The ADA does not prescribe a one-size-fits-all design for accessible guest rooms, but instead demands adherence to a set of design principles and accessibility features that can be applied to guest rooms of all types and sizes.
The ADA requires that accessible rooms be “dispersed among the various classes of guest rooms” and hotels shall provide people with disabilities “choices of types of guest rooms, number of beds, and other amenities comparable to the choices provided to other guests.” In determining if an adequate range of choice is afforded to disabled guests, the regulation advises that hotels consider “room size, bed size, cost, view, bathroom fixtures such as hot tubs and spas, smoking and nonsmoking, and the number of rooms provided,” among other things.
In the event that a hotel cannot achieve complete dispersion of ADA accessible rooms across the entire range of rooms and amenities, the law says that “guest rooms shall be dispersed in the following priority: guest room type, number of beds, and amenities.” This means that accessible rooms must first be dispersed among the various room types (i.e. standard, deluxe, concierge floor, suite, etc.) before they are dispersed according to number of beds, followed by amenities.
Requirements for dispersion are ignored by many hotels, making it exceedingly difficult to find ADA accessible suites.
In the interest of equitable dispersion, hotels should offer accessible guest rooms on a range of floors, both high and low. They may not always be able to accommodate requests for a specific floor and are not required to do so (unless they will guarantee a specific floor to other guests).
Width of Doors, Turn Radius & Accessible Pathways
Users of wheelchairs, walkers and other mobility aids require more space to move and navigate buildings than able-bodied people. The minimum width of doors and entryways in hotel facilities is 32 inches, to allow for the clear passage of people with disabilities. Hallways, ramps and other routes must be at minimum 36 inches wide throughout the hotel.
Bathrooms in accessible guest rooms must provide enough clear floor space for a wheelchair to turn around – specifically in the form of either a 60″ diameter circle or a “T” turn area as shown in the diagram above. A similar turning space is required in the guest room itself.
In hotels with only one bed, a clear space of at least 30 inches wide must exist on both sides of the bed to accommodate parallel positioning of a wheelchair for side transfers. In hotels with two beds, a clear space of at least 30 inches is required between the beds, but is not required on both sides of each bed.
The height of sleeping beds in hotel rooms is of great concern to those with limited mobility who must transfer into the bed from a wheelchair. Trends in hotel design have led to the installation of taller beds, with the top of the mattress often being 30 inches or more from the floor. Platform beds are also becoming quite common, restricting the use of portable transfer hoists like the hoyer lift.
No standard for bed height is mandated or prescribed by the ADA. Section 504 of the Rehabilitation Act suggests a bed height of 17 to 19 inches in accessible jail/prison cells, but that recommendation does not apply to hotels.
Comments relating to this issue were accepted prior to publication of the 2010 rules, but bed height was not addressed by the Access Board in the final regulations. See the section titled Reasonable Modifications & Accommodations later in this article for tips on how to best address this concern.
Accessible hotel rooms with a bathtub have required in-tub seats since the 1991 standards took effect (4.20.3). The majority of hotels do not provide this feature. Section 607 of the 2010 standards permits two designs, which are pictured below.
Bathtub seats can be either permanently fixed at the end of the tub (picture 1) or removable units that can be placed inside the tub (picture 2). Removable seats must be capable of secure placement so that they are fixed and immovable during use. The top of bathtub seats must be between 17 and 19 inches above the bathroom floor.
Parallel grab bars are required on the back wall of the tub, and a single horizontal grab bar must be affixed to the control wall. A grab bar on the second end wall (opposite the control wall) is only required for bathtubs using the removable in-tub seat. The bathtub in picture 2 above fails the grab bar compliance test: the back wall has one bar, not two; and the control wall has a vertical bar, not horizontal.
Many hotels built after 1991 (when these standards came into effect) do not provide the required type of bathtub seat, offering instead plastic shower chairs or stools. In addition to being a regulatory violation, such chairs can be dangerous when used in a bathtub.
Roll-in Shower Specifications
The two most common problems hotel guests face with roll-in showers are (1) a lack of shower seats and (2) controls positioned out-of-reach of a provided seat. The photographs below depict these problematic roll-in shower designs, both of which violate the 1991 and 2010 ADA Standards.
All hotels built since the 1991 standards (9.1.2) took effect are required to provide a shower seat in all accessible rooms with a roll-in shower. These seats must be affixed to and fold down from one of the shower compartment’s side walls. Water controls and a handheld shower nozzle must be placed on the adjacent back wall and within reach of the provided seat. Grab bars must be located on the side wall opposite the shower seat and also along the back wall. Grab bars are not allowed on the side wall to which the shower seat is attached (4.21.3).
The roll-in shower compartment pictured above is an example of ADA compliance. It features the required folding seat, water controls within reach, a handheld showerhead and grab bars placed in the appropriate locations.
In addition to the rectangular roll-in shower pictured above, some hotels may offer a transfer shower as an option.
Transfer type shower compartments are 36 inches square and must contain a folding or fixed seat, grab bars and a handheld shower nozzle (4.21.3). A clearance space of 36 inches wide by 48 inches long for parking a wheelchair must be provided outside of the transfer shower. The transfer shower pictured above meets all of the relevant ADA requirements found in section 608 of the 2010 standards.
Toilets & Sinks
Designers of accessible bathrooms in many older hotels placed toilets (aka water closets) directly alongside the bathroom sink, making side transfers impossible for wheelchair users. Although this was permissible in the 1991 ADA standards, the 2010 standards now prohibit sinks from overlapping the clear floor space that is required next to a toilet.
The diagrams above explain the change in requirements for toilet accessibility, with the 1991 standard on the left and the 2010 standard on the right.
In accessible hotel rooms, the height of the toilet seat from the floor must be at least 17 inches but not more than 19 inches. Grab bars shall be provided on the side wall closest to the toilet and also on the wall behind the toilet.
Communication Devices for Hearing and Sight-Impaired
Hotels must offer guest rooms with equipment adapted for the use of people with hearing and/or sight impairments. Section 806.3 of the 2010 standards describes the requirements for audible and visible alarms, as well as visible notification devices to alert guests of incoming telephone calls and door knocks or bells.
To access section 806.3, click here.
Requests for Reasonable Accommodations
In addition to the basic design requirements discussed here, hotels are also required to fulfill requests for reasonable accommodations that do not place an undue burden or cost on the businesses.
Below, I have listed a few examples of reasonable requests that a hotel should honor:
- A request to remove the bed frame or box spring to lower the bed to a more acceptable height.
- A request to place the bed frame on bed risers provided by the guest, to allow for use of a transfer hoist or hoyer lift.
- A request to relocate a telephone or other equipment to a more accessible position.
- A request to remove additional furniture from the room (like chairs or tables) that may impede access for the wheelchair user.
- A request to provide a mini-refrigerator for the storage of medication.
- A request to remove an interior door in the guest room (such as a bathroom door) that might otherwise impede access for the wheelchair user.
- A request to provide an extension cord to allow for greater access to electricity.
The following is a list of sample requests that are not likely to be honored by hotels, as there is no such requirement for them to do so:
- A request to provide a transfer hoist or hoyer lift.
- A request to provide specialized equipment for use in the bathroom, such as a bedside commode or raised toilet seat.
- A request to adjust the height of a bed where it is not technically feasible to do so.
You have a right to request reasonable accommodations at any point before or during your stay.
To learn how to protect yourself against ADA violations like the ones mentioned here, read the article on resolving ADA disputes.
Questions about the ADA and how it applies to the design of hotel rooms? Ask away in the comments below!