Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Commenta ry o n the 2010 ADAStandards where there are two or more required ground usefulness in providing accessible saunas level play components, while the advisory and steam rooms. The Department believes appears to suggest that all accessible that there is an element of risk in many components must be integrated. activities available to the general public. One of the major tenets of the ADA is that The commenter misinterprets the individuals with disabilities should have the requirement. The ADA mandates that persons same opportunities as other persons to with disabilities be able to participate in decide what risks to take. It is not appropriate programs or activities in the most integrated for covered entities to prejudge the abilities of setting appropriate to their needs. Therefore, persons with disabilities. all accessible play components must be integrated into the general playground 242 and 1009 Swimming Pools, Wading setting. Section 240.2.1 of the 2010 Pools, and Spas Standards specifies that where there is more than one accessible ground level play Accessible Means of Entry to Pools. component, the components must be both Section 242 of the 2010 Standards requires dispersed and integrated. at least two accessible means of entry for larger pools (300 or more linear feet) and at 241 and 612 Saunas and Steam Rooms least one accessible entry for smaller pools. This section requires that at least one entry Section 241 of the 2010 Standards sets will have to be a sloped entry or a pool lift; scoping for saunas and steam rooms and the other could be a sloped entry, pool lift, a section 612 sets technical requirements transfer wall, or a transfer system (technical including providing accessible turning space specifications for each entry type are included and an accessible bench. Doors are not at section 1009). permitted to swing into the clear floor or ground space for the accessible bench. Many commenters supported the scoping The exception in section 612.2 of the 2010 and technical requirements for swimming Standards permits a readily removable pools. Other commenters stated that the cost bench to obstruct the required wheelchair of requiring facilities to immediately purchase turning space and the required clear floor or a pool lift for each indoor and outdoor ground space. Where they are provided in swimming pool would be very significant clusters, five percent (5%) but at least one especially considering the large number of sauna or steam room in each cluster must be swimming pools at lodging facilities. One accessible. commenter requested that the Department clarify what would be an “alteration” to Commenters raised concerns that the safety a swimming pool that would trigger the of individuals with disabilities outweighs the 160 - Guidance on the 2010 Standards: Titles II and III Department of Justice