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2010 ADA Standards for Accessible Design Pocket Guide

224 Transient Lodging Guest Rooms

224.1 General.

Transient lodging facilities shall provide guest rooms in accordance with 224.

ETA Editor’s Note:

For, 36.406(c) Standards for New Construction and Alterations; Places of Lodging, 35.151(f) New Construction and Alterations; Housing at a Place of Education, and 36.406(e) Standards for New Construction and Alterations; Housing at a Place of Education see Access Board’s Note to Reader after Section 224.5

Advisory 224.1 General. Certain facilities used for transient lodging, including time shares, dormitories, and town homes may be covered by both these requirements and the Fair Housing Amendments Act. The Fair Housing Amendments Act requires that certain residential structures having four or more multi-family dwelling units, regardless of whether they are privately owned or federally assisted, include certain features of accessible and adaptable design according to guidelines established by the U.S. Department of Housing and Urban Development (HUD). This law and the appropriate regulations should be consulted before proceeding with the design and construction of residential housing.

224.1.1 Alterations.

Where guest rooms are altered or added, the requirements of 224 shall apply only to the guest rooms being altered or added until the number of guest rooms complies with the minimum number required for new construction.

Advisory 224.1.1 Alterations. In alterations and additions, the minimum required number of accessible guest rooms is based on the total number of guest rooms altered or added instead of the total number of guest rooms provided in a facility. Typically, each alteration of a facility is limited to a particular portion of the facility. When accessible guest rooms are added as a result of subsequent alterations, compliance with 224.5 (Dispersion) is more likely to be achieved if all of the accessible guest rooms are not provided in the same area of the facility.

224.1.2 Guest Room Doors and Doorways.

Entrances, doors, and doorways providing user passage into and within guest rooms that are not required to provide mobility features complying with 806.2 shall comply with 404.2.3.

EXCEPTION: Shower and sauna doors in guest rooms that are not required to provide mobility features complying with 806.2 shall not be required to comply with 404.2.3.

Advisory 224.1.2 Guest Room Doors and Doorways. Because of the social interaction that often occurs in lodging facilities, an accessible clear opening width is required for doors and doorways to and within all guest rooms, including those not required to be accessible. This applies to all doors, including bathroom doors, that allow full user passage. Other requirements for doors and doorways in Section 404 do not apply to guest rooms not required to provide mobility features.

224.2 Guest Rooms with Mobility Features.

In transient lodging facilities, guest rooms with mobility features complying with 806.2 shall be provided in accordance with Table 224.2.

Table 224.2 Guest Rooms with Mobility Features
Total Number of Guest Rooms Provided Minimum Number of Required Rooms Without Roll-in Showers Minimum Number of Required Rooms With Roll-in Showers Total Number of Required Rooms
1 to 25 1 0 1
26 to 50 2 0 2
51 to 75 3 1 4
76 to 100 4 1 5
101 to 150 5 2 7
151 to 200 6 2 8
201 to 300 7 3 10
301 to 400 8 4 12
401 to 500 9 4 13
501 to 1000 2 percent of total 1 percent of total 3 percent of total
1001 and over 20, plus 1 for each 100, or fraction thereof, over 1000 10, plus 1 for each 100, or fraction thereof, over 1000 30, plus 2 for each 100, or fraction thereof, over 1000

224.3 Beds.

In guest rooms having more than 25 beds, 5 percent minimum of the beds shall have clear floor space complying with 806.2.3.

224.4 Guest Rooms with Communication Features.

In transient lodging facilities, guest rooms with communication features complying with 806.3 shall be provided in accordance with Table 224.4. [S.H. 9.1.3]

Table 224.4 Guest Rooms with Communication Features
Total Number of Guest Rooms Provided Minimum Number of Required Guest Rooms With Communication Features
2 to 25 2
26 to 50 4
51 to 75 7
76 to 100 9
101 to 150 12
151 to 200 14
201 to 300 17
301 to 400 20
401 to 500 22
501 to 1000 5 percent of total
1001 and over 50, plus 3 for each 100 over 1000

224.5 Dispersion.

Guest rooms required to provide mobility features complying with 806.2 and guest rooms required to provide communication features complying with 806.3 shall be dispersed among the various classes of guest rooms, and shall provide choices of types of guest rooms, number of beds, and other amenities comparable to the choices provided to other guests. Where the minimum number of guest rooms required to comply with 806 is not sufficient to allow for complete dispersion, guest rooms shall be dispersed in the following priority: guest room type, number of beds, and amenities. At least one guest room required to provide mobility features complying with 806.2 shall also provide communication features complying with 806.3. Not more than 10 percent of guest rooms required to provide mobility features complying with 806.2 shall be used to satisfy the minimum number of guest rooms required to provide communication features complying with 806.3. [S.H. 9.1.4]

Advisory 224.5 Dispersion. Factors to be considered in providing an equivalent range of options may include, but are not limited to, room size, bed size, cost, view, bathroom fixtures such as hot tubs and spas, smoking and nonsmoking, and the number of rooms provided.

ETA Editor’s Note:

This Access Board note was taken from 36.406(c) Standards for New Construction and Alterations; Places of Lodging. 

Access Board’s Note to Reader:

The Department of Justice’s ADA standards also require the following:

Places of lodging. Places of lodging subject to this part [of the title III regulation] shall comply with the provisions of the 2010 Standards applicable to transient lodging, including, but not limited to, the requirements for transient lodging guest rooms in sections 224 and 806.

(1) Guest rooms. Guest rooms with mobility features in places of lodging subject to the transient lodging requirements of 2010 Standards shall be provided as follows--

(i) Facilities that are subject to the same permit application on a common site that each have 50 or fewer guest rooms may be combined for the purposes of determining the required number of accessible rooms and type of accessible bathing facility in accordance with Table 224.2 to section 224.2 of the 2010 Standards.

(ii) Facilities with more than 50 guest rooms shall be treated separately for the purposes of determining the required number of accessible rooms and type of accessible bathing facility in accordance with Table 224.2 to section 224.2 of the 2010 Standards.

(2) Exception. Alterations to guest rooms in places of lodging where the guest rooms are not owned or substantially controlled by the entity that owns, leases, or operates the overall facility and the physical features of the guest room interiors are controlled by their individual owners are not required to comply with § 36.402 or the alterations requirements in section 224.1.1 of the 2010 Standards.

(3) Facilities with residential units and transient lodging units. Residential dwelling units that are designed and constructed for residential use exclusively are not subject to the transient lodging standards.

The Department of Justice's title II and title III regulations include requirements for social service center establishments which are noted in section 233 (Residential Facilities). 

ETA Editor’s Note:

This Access Board note was taken from 35.151(f) New Construction and Alterations; Housing at a Place of Education and 36.406(e) Standards for New Construction and Alterations; Housing at a Place of Education.

Access Board’s Note to Reader:

The Department of Justice’s ADA standards also require the following:

Housing at a place of education. Housing at a place of education that is subject to this part [of the title III regulation or to this section of the title II regulation] shall comply with the provisions of the 2010 Standards applicable to transient lodging, including, but not limited to, the requirements for transient lodging guest rooms in sections 224 and 806, subject to the following exceptions. For the purposes of the application of this section, the term "sleeping room" is intended to be used interchangeably with the term "guest room" as it is used in the transient lodging standards.

(1) Kitchens within housing units containing accessible sleeping rooms with mobility features (including suites and clustered sleeping rooms) or on floors containing accessible sleeping rooms with mobility features shall provide turning spaces that comply with section 809.2.2 of the 2010 Standards and kitchen work surfaces that comply with section 804.3 of the 2010 Standards.

(2) Multi-bedroom housing units containing accessible sleeping rooms with mobility features shall have an accessible route throughout the unit in accordance with section 809.2 of the 2010 Standards.

(3) Apartments or townhouse facilities that are provided by or on behalf of a place of education, which are leased on a year-round basis exclusively to graduate students or faculty and do not contain any public use or common use areas available for educational programming, are not subject to the transient lodging standards and shall comply with the requirements for residential facilities in sections 233 and 809 of the 2010 Standards.

The Department of Justice's title II and title III regulations include requirements for social service center establishments which are noted in section 233 (Residential Facilities).  

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