Accessible Lodging

The Department of Justice (DOJ) has issued revised ADA regulations under Title III, which covers many types of private businesses, or “places of public accommodation.” Many of these revisions apply to places of lodging, such as new requirements for reservation systems, and revised standards for facility access.

Definition: What is a “Place of Lodging”?

Places of lodging include:

Revised Standards for Buildings and Facilities

The 2010 ADA Standards for Accessible Design include revised minimum requirements for newly and constructed or altered facilities so that they are accessible to and usable by individuals with disabilities. Minimum requirements:

Newly designed and constructed places of lodging must comply with the new 2010 ADA Standards, and alterations to an existing building must comply to the maximum extent feasible. For existing buildings that are not undergoing alterations, owners still have an obligation to remove barriers to the extent that is readily achievable.

For those existing elements of a facility that were constructed or altered in compliance with the 1991 ADA Standards, no changes are necessary even if the new 2010 ADA Standards have different requirements for those elements. This situation is referred to as “safe harbor.” Safe harbor does not apply to those elements of a facility, like swimming pools, saunas and playgrounds that were not covered in the 1991 ADA Standards. However, when an alteration is performed, it must comply with the new 2010 ADA Standards. In cases where the nature of the facility makes full compliance with the 2010 ADA Standards virtually impossible, the alteration must provide the maximum physical accessibility that is feasible.

Reservation Systems Requirements for Places of Lodging