ADA Guide for Places of Lodging: Serving Guests Who Are Blind or Who Have Low Vision

Moving Throughout Your Facility

Guiding Techniques. It is a routine practice in many hotels to offer assistance to guests in finding their rooms and other facilities. It may be a reasonable modification of this practice to assist guests who are blind or who have low vision in wayfinding throughout their stay. If it appears that a guest would benefit from a sighted guide, you may identify yourself and offer assistance. If assistance is accepted, you may offer your arm to the guest. The guest will lightly hold your arm directly above the elbow. You should not pull or push the guest or hold his or her arm. Instead, relax and walk at a comfortable, normal pace. Allow the guest to walk a step or two behind you, and indicate changes in terrain, such as stairs, narrow spaces, and escalators, by hesitating briefly as you approach them and explaining what you are about to do. When seating the guest, ask if you may show him or her the back of the chair. If the response is yes, simply place the guest’s hand on the chair back. When it is time for you to leave, indicate that you are leaving his or her presence. Staff should not touch or remove mobility canes unless requested to do so and should not interfere with service animals such as guide dogs.

Verbalizing Directions. When giving directions, do not point. Instead, explain the directions in words and be specific. Be sure to use right and left as they apply to the person who is blind. What is on your right is on the left of a person facing you. Indicate number of blocks to the department store and whether one proceeds right or left when exiting the hotel. Simply saying, “The department store is about six blocks down in that direction” is ineffective. Provide the address and, whenever possible, indicate such things as the number of doorways from the corner and distance. Similarly, be specific about directions to rooms within the hotel, e.g., “To find the Monroe Room, walk twenty feet forward, turn left, and it’s the fifth room on your right.”

Architectural Barriers. Assuming your place of lodging is not subject to the new construction and alteration provisions (discussed below), you must remove barriers to access for people with disabilities when it is ‘readily achievable’ for you to do so. The term ‘readily achievable’ means “easily accomplishable and able to be carried out without much difficulty or expense.” The Department of Justice’s title III regulation lists factors to determine whether an action is readily achievable. 28 C.F.R. § 36.104.

New construction and alteration requirements. The ADA requires that newly constructed facilities, first occupied on or after January 26, 1993, meet or exceed the minimum requirements of the ADA Standards for Accessible Design (Standards). Alterations to facilities, spaces or elements (including renovations) on or after January 26, 1992, also must comply with the Standards. If you build a new facility or modify your existing one, (for example, work such as restriping the parking area, replacing the entry door or renovating the sales counter), make sure to consult the Standards and the title III regulations for the specific requirements. Renovations or modifications are considered to be alterations when they affect the usability of the element or space. For example, installing a new display counter, moving walls in a sales area, replacing fixtures, carpet or flooring, and replacing an entry door. However, simple maintenance, such as repainting a wall is not considered an alteration by the ADA.

The Standards can be found at Appendix A to the Department of Justice’s title III regulation, 28 C.F.R. pt. 36. The entire regulation, including the Standards, is available online and from the Department of Justice’s ADA Information Line. Contact information is listed below.

Signs. In newly constructed and altered facilities, signs that identify permanent rooms and spaces – including, but not necessarily limited to those identifying rest rooms, exits, or room numbers – must meet the following requirements, 28 C.F.R. pt. 36, App. A, “ADA Standards for Accessible Design,” (Standards) § 4.1.3(16)(a):

• Raised and Braille letters or numbers (Standards § 4.30.4);

• Mounting location (§ 4.30.6);

• Color contrast (§ 4.30.5); and

• Non-glare surface (§ 4.30.5).

Signs that provide direction to, or information about, functional spaces (§ 4.1.3(16)(b)) must comply with requirements for:

• Character proportion (§ 4.30.2);

• Character height (§ 4.30.3); and

• Finish and contrast between the characters and background (§ 4.30.5).

Elevators. In newly constructed or altered facilities, elevators must comply with specific design standards regarding the following:

• Hall call button orientation, mounting location, and visual signals (§ 4.10.3);

• Hall lantern audible and visual signals, size, and mounting location (§ 4.10.4);

• Raised and Braille characters on elevator hoistway entrances (door jambs), including mounting location and size (§ 4.10.5);

• Door protective and reopening devices (§ 4.10.6);

• Door and signal timing for hall calls (§ 4.10.7);

• Door delay for car calls (§ 4.10.8);

• Illumination levels (§ 4.10.11);

• Car control size, mounting height and location, and tactile, Braille, and visual indicators (§ 4.10.12);

• Car position indicators (§ 4.10.13); and

• Emergency communications (§ 4.10.14).

Existing facilities must remove barriers to the extent that doing so is readily achievable.