Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Com menta ry on the 201 0 A DAStandards to a standard 110-volt electrical outlet and of portable visible alarms used in transient are both activated by the building fire alarm lodging guest rooms. These commenters system and provide a visible alarm when the recommended retaining requirements that single station smoke detector is activated. allow the use of portable visible alarms. Section 215.4 of the 2010 Standards no longer includes the portable visible alarm Persons who are deaf or hard of hearing option and instead requires that transient have reported that portable visible alarms lodging guest rooms with communication used in transient lodging guest rooms features be equipped with a fire alarm are deficient because the alarms are not system which includes permanently installed activated by the building fire alarm system, audible and visible alarms in accordance with and the alarms do not work when the building NFPA 72 National Fire Alarm Code (1999 power source goes out in emergencies. or 2002 edition). Such guest rooms with The 2010 Standards are consistent with the communication features are also required by model building, fire, and life safety codes section 806.3.2 of the 2010 Standards to be as applied to newly constructed transient equipped with visible notification devices that lodging facilities. One commenter sought alert room occupants of incoming telephone confirmation of its understanding of visible calls and a door knock or bell. alarm requirements from the Department. This commenter interpreted the exception The 2010 Standards add a new exception for to section 215.1 of the 2010 Standards and alterations to existing facilities that exempts the Department’s commentary to the NPRM existing fire alarm systems from providing to mean that if a transient lodging facility visible alarms, unless the fire alarm system does not have permanently installed visible itself is upgraded or replaced, or a new fire alarms in its communication accessible guest alarm system is installed. Transient lodging rooms, it will not be required to provide such facilities that alter guest rooms are not alarms until such time that its fire alarm required to provide permanently installed system is upgraded or replaced, or a new visible alarms complying with the NFPA 72 if fire alarm system is installed. In addition, this the existing fire alarm system has not been commenter also understood that, if a hotel upgraded or replaced, or a new fire alarm already has permanently installed visible system has not been installed. alarms in all of its mobility accessible guest rooms, it would not have to relocate such Commenters representing small providers visible alarms and other communication of transient lodging raised concerns about features in those rooms to other guest the proposed changes to prohibit the use rooms to comply with the ten percent (10%) overlap requirement until the alarm system is upgraded or replaced. Department of Justice Guidance on the 2010 Standards: Titles II and III - 123