Hotel ADA Compliance: Interiors and Public Spaces

Hotel ADA Compliance: Interiors and Public Spaces

When hotels update room interiors and public spaces to keep their facilities looking fresh, it is important to understand the application of Americans with Disabilities Act standards. Knowing what is and is not required can help avoid the cost and inconvenience of potential complaints or remediation work. This is the first of a two part series about hotel renovations and the ADA.


What the ADA says about alterations

  • Existing facilities permitted before March 15, 2012 are generally regulated by the 1991 ADA accessibility standards.
  • Standards were updated in 2010 and cover new construction and alteration projects permitted after March 15, 2012.
  • Alterations include, but are not limited to, remodeling, renovation, rehabilitation, reconstruction, historic restoration, changes or rearrangement in structural parts or elements, changes or rearrangement in the plan configuration of walls and full-height partitions.
  • Unaltered elements in existing facilities that meet the 1991 Standards do not need to be modified to meet the 2010 standards until altered.
  • Elements that were not part of the 1991 Standards – such as recreation areas – must be modified to the extent readily achievable to comply with the 2010 Standards.
  • Normal maintenance and repairs are not considered an alteration.

What is covered

Guestrooms, meeting spaces, lobbies, and food and beverage amenities receive frequent updates and renovations. While alterations in these areas must comply with ADA 2010, so too must paths of travel to and from these primary function areas.

A path of travel includes a continuous, unobstructed pedestrian passage used to approach, enter, and exit an altered area. It connects the altered area with a facility entrance, other parts of the facility, and an exterior approach – such as sidewalks, streets, parking areas. Compliance modifications to paths of travel need not exceed 20% of the cost of the primary function area alterations.

Other elements that must be made accessible as part of the path of travel include: parking, exterior and interior routes, entrance, and elevators. Restrooms and drinking fountains that serve an altered area also must be accessible.

ADA 1991 and 2010 differences

Many requirements of the 1991 and 2010 Standards are the same. However, there are some changes that affect a number of typical hotel areas, including:

  • Registration desks and service counters
  • Bars
  • Swimming pools and spas
  • Fitness centers
  • Golf courses
  • Playgrounds
  • Water closet clearance (toilet clear floor space)
  • Comparable guestroom vanity countertop sizes
  • Accessible guestroom dispersion (types of rooms dispersed throughout the hotel)
  • Visual alarms for guestrooms with communication feature
Examples of differences include:
  • Space around a water closet has increased from 48” wide to 60” wide. Increased dimensions may lead to a redesign or rearrangement of fixtures in guestroom bathrooms.
  • Vanity counter tops in accessible guestrooms with mobility features now must be comparable in size to those in non-accessible guestrooms. A wall-mounted lavatory met the 1991 standards. But under the 2010 ADA Standards if other guestrooms offer larger vanity counter space, accessible guestrooms also must do so.
  • Access to pools and spas must be provided by means of a lift or other accessible means.
  • Bars with seating are required to provide a lower accessible section with knee space.


LCM has consulted on ADA issues for over 400 hotel properties. Guestroom dispersion is a complex issue. The 1991 and 2010 ADA Standards address types of guestrooms and number of beds. These, and other higher level dispersion factors, will be discussed in the next installment of this series.

Hotel Renovations and ADA Compliance Part II: Guestroom Dispersion
Hotel Renovations and ADA Compliance Part III: Strategies for Avoiding a ‘Tester’ Lawsuit


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