Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Com menta ry on the 201 0 A DAStandards that saunas and steam rooms in existing of an accessible route. The 2010 Standards facilities be exempt from the section 224.1.2 add a new scoping requirement that permits requirement and that the requirement be platform lifts to be used to connect levels made applicable to new construction only. within transient lodging guest rooms and dwelling units with mobility features. The exemption to the section 224.1.2 requirement for a 32-inch wide clearance 806 Transient Lodging Guest Rooms at doors to shower and saunas applies only to those showers and saunas in guest In the NPRM, the Department included floor rooms which are not required to have plans showing examples of accessible guest mobility features. Showers and saunas in rooms and bathrooms designs with mobility other locations, including those in common features to illustrate how compliance with use areas and guest rooms with mobility the 2010 Standards could be accomplished features, are required to comply with the with little or no additional space compared to 32-inch clear width standard as well as designs that comply with the 1991 Standards. other applicable accessibility standards. Saunas come in a variety of types: portable, Commenters noted that the Department’s pre-built, pre-cut, and custom-made. All plans showing accessible transient lodging saunas except for custom-made saunas guest rooms compliant with the 2010 are made to manufacturers’ standard Standards were not common in the transient dimensions. The Department is aware that lodging industry and also noted that the plans creating the required 32-inch clearance omitted doors at sleeping room closets. at existing narrower doorways may not always be technically feasible. However, The Department agrees that the configuration the Department believes that owners and of the accessible bathrooms is somewhat operators will have an opportunity to provide different from past designs used by the the required doorway clearance, unless industry, but this was done to meet the doing so is technically infeasible, when an requirements of the 2010 Standards. The alteration to an existing sauna is undertaken. plans were provided to show that, with some Therefore, the Department has retained redesign, the 2010 Standards do not normally these requirements. increase the square footage of an accessible sleeping room or bathroom with mobility Platform Lifts in Transient Lodging Guest features in new construction. The Department Rooms and Dwelling Units. The 1991 has also modified several accessible guest Standards, at section 4.1.3(5), exception 4, room plans to show that doors can be and the 2010 Standards, at sections 206.7 installed on closets and comply with the 2010 and 206.7.6, both limit the locations where Standards. platform lifts are permitted to be used as part Department of Justice Guidance on the 2010 Standards: Titles II and III - 125