Ask an ADA Professional Questions RE: The ADA and Places of Lodging

Thursday, July 13, 2023
2:00 PM - 3:00 PM Eastern Time Zone


Places of lodging covered under the ADA have an obligation to provide access and not discriminate against persons with disabilities. During this program, attendees will have the opportunity to ask ADA professionals questions about places of lodging covered by the ADA, such as, hotels, motels, inns, short-term stay facilities, and entities that own or operate such places.

To ensure your question is answered during the session, individuals are highly encouraged to submit their questions ahead of time via the registration website (the option to submit questions is available once you have registered for the session). Sign Language Interpreters and Human Generated Real-Time Captioning will be provided for this session.

Continuing Education Recognition Available

Certificate Credit hours
Certificate of Attendance 1.5


Marisa Demaya, Deputy Director, Southwest ADA Center

Christine Woodell, Training and Technical Assistance, Southeast ADA Center

Questions for presenters:

1 If within the mobility accessible hotel room no protruding objects are allowed in the circulation areas (204.1 & 307.2), and the only obligation in the non-accessible rooms are the obligation to provide 32" clear width at doors requiring passage [206.5.3 & 404.2.3], are protruding objects allowed in the non-mobility rooms? the communication rooms? Vision and blind individuals are not likely to request the hotel rooms designed to help those with mobility issues, so are most likely to be in the non-accessible transient lodging rooms. A similar question would apply to the non-accessible hospital patient rooms in Medical Care Facilities. While obviously not encouraged, would they be allowed? Or in other words, should we inspect for them and call them out in non-accessible rooms as non-compliant barriers?
2 2. A follow-up question/simplification to previously asked question 1: For hotel rooms other than rooms with mobility/communication features, where does the circulation path (and applicability of section 307 protruding object requirements) start and end? Does it end at the doorway into these hotel rooms, or does it extend into the room to every potential circulation path within the room?
3 3. Unlike ICC A117.1, which spells out all of the accessibility requirements for an accessible hotel guest room, the 2010 ADA Standards rely upon the 806.2 advisory to vaguely identify what is required. This leads to many questions regarding the extent and type of accessible features in hotel rooms with mobility features. This potentially includes; refrigerators (including their controls), loose furniture desks, HVAC controls, window shade controls, coffee/hotpot appliances, condiment storage, drawer storage (besides closet storage), safes, switches on mirrors, access to and possible use of ironing boards, irons, and hair dryers. Please comment about this.
4 4. Sections 806.2.6 states that a turning space shall be provided "within" the guest rooms with mobility features, while 806.2.2 states that exterior spaces (including patios, terraces, and balconies) of guest rooms with mobility features shall be accessible. Is a turning space required at exterior spaces for guest rooms with mobility features? This doesn't appear to be the case, based on language of 806.2.6. Note that while a door maneuvering clearance (DMCs) would be required at the exterior side of the door to the patio, there are DMCs less than 60" in depth. Additionally, DOJ's Guidance on the 2010 ADA Standards: Titles II and III does not show an hotel room examples with exterior spaces (see pages 127-139, Plans 1A to 6B).
6 6. When it comes to determining "classes" of hotel guest rooms, are multilevel guest rooms considered to be a separate "class" of units, particularly where they may have the same number of beds and bathrooms, as well as amenities, of a single level unit? Said another way: Does the virtue of being multi-level instead of single-level make a guest room distinct enough to be considered a separate "class" of units.
7 7. Follow up to Question 6: Could you please discuss accessibility requirements for multilevel hotel guest rooms that are designated as guest rooms with mobility features?
8 Pre-pandemic, several hotels in DC officially had ADA-compliant rooms, yet when attempting to register, none were available. Given DC's homelessness issues, it seems possible that these ADA rooms (and other non-ADA-compliant rooms) might be rented to a DC agency for that purpose. Does ADA law itself address this possible conflict between the tourist and the less transient?

Session Questions

This session is accepting questions from registered users. After you have registered to participate in this session you can submit your questions on your Account Manager page. Please note: the number of questions will be limited and submissions will be closed well before the session starts to provide time to prepare answers.