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2022 California Standards for Accessible Design Guide (effective January 1, 2023)

11B-224 Transient lodging guest rooms, housing at a place of education and social service center establishments

11B-224.1 General.

Hotels, motels, inns, dormitories, resorts and similar transient lodging facilities shall provide guest rooms in accordance with Sections 11B-224.1 through 11B-224.6.

[2010 ADA Standards] 224.1 General. Transient lodging facilities shall provide guest rooms in accordance with 224.

DOJ icon
Advisory 11B-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. 

ETA Editor's Note

For transient lodging guest rooms, the CBC scoping requirements are more inclusive.

See U.S. Access Board's Note To Reader after Section 224.5 for ADA scoping requirements of Title III §36.406(c) Standards for New Construction and Alterations; Places of Lodging, and also Title II §35.151(f) and Title III §36.406(e) Standards for New Construction and Alterations; Housing at a Place of Education.

11B-224.1.1 Alterations.

Where guest rooms are altered or added, the requirements of Section 11B-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.

DOJ icon
Advisory 11B-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 Section 11B-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. 

11B-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 Section 11B-806.2 shall comply with Section 11B-404.2.3. Bathrooms doors shall be either sliding or hung to swing in the direction of egress from the bathroom.

[2010 ADA Standards] 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 Section 11B-806.2 shall not be required to comply with Section 11B-404.2.3.

DOJ icon
Advisory 11B-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 11B-404 do not apply to guest rooms not required to provide mobility features. 

11B-224.1.3 Range of accommodations.

Accessible guest rooms or suites shall be dispersed among the various classes of sleeping accommodations to provide a range of options applicable to room sizes, costs, and amenities provided.

11B-224.1.4 Guest room toilet and bathing rooms.

Where toilet and bathing rooms are provided in guest rooms that are not required to provide mobility features complying with Section 11B-806.2, toilet and bathing fixtures shall only be required to comply with Section 11B-603.6.

11B-224.2 Guest rooms with mobility features.

In transient lodging facilities, guest rooms with mobility features complying with Section 11B-806.2 shall be provided in accordance with Table 11B-224.2, as follows.

[2010 ADA Standards] 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 11B-224.2 GUEST ROOMS WITH MOBILITY FEATURES

TOTAL NUMBER OF GUEST ROOMS PROVIDED

MINIMUM NUMBER OF REQUIRED ROOMS WITHOUT ROLL-IN SHOWERS1 MINIMUM NUMBER OF REQUIRED ROOMS WITH ROLL-IN SHOWERS 2

TOTAL NUMBER OF REQUIRED ROOMS

1 1 0 1
2 to 25 1

1

[2010 ADA Standards] 0

2

[2010 ADA Standards] 1

26 to 50

2

[2010 ADA Standards] 0

3

[2010 ADA Standards] 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

1. Provide either a bathtub complying with Section 11B-607 or a transfer type shower complying with Section 11B-608.2.1.

2. Provide either a standard roll-in type shower complying with Section 11B-608.2.2 or an alternate type roll-in shower complying with Section 11B-608.2.3.

DSA logo
Advisory 11B-224.2 Guest rooms with mobility features. In hotels, motels or other transient lodging facilities, Table 11B-224.2 indicates the required total number of mobility accessible rooms, including both rooms without roll-in showers and with roll-in showers. All of these rooms are required to comply with the technical requirements of Section 11B-806.2. Not more than 10 percent of guest rooms required to provide mobility features by Table 11B-224.2 may be used to satisfy the minimum number of guest rooms required to provide communication features by Table 11B-224.4.

For example, a new 275-room hotel must have a total of ten mobility accessible guest rooms; a minimum of three of the ten must have roll-in showers per Table 11B-224.2. In addition to those ten mobility accessible rooms, 17 guest rooms are required to provide communication features per Table 11B-224.4. Only 10 percent of the rooms required to provide mobility features, or one mobility accessible room, may also be used to satisfy the requirements of Table 11B-224.4. Sixteen additional communication accessible rooms must be provided. ◼

ETA Editor's Note

2022 CBC allows a 36” x 36” transfer shower to be used in transient lodging guest rooms, housing at a place of education, and social service center establishments and aligns the CBC requirements with the requirements of the ADA Standards. However, the scoping requirements for facilities with two to fifty guest rooms is more stringent than the 2010 ADA Standards. The differences between the number of guest rooms with particular mobility features required by ADA as compared with CBC can be problematic for small transient lodging facilities (less than 51 guest rooms). ETA considers the ADA requirement for rooms without roll-in showers to be a recognition that some individuals with mobility impairments actually prefer an accessible bathtub or transfer-type shower (36" x 36" – see 11B-608.2.1). In order to comply with the ADA and CBC requirements for transient lodging facilities with 25 guest rooms or less, it is necessary to provide a minimum of two rooms with mobility features, one with a roll-in shower, and one with an accessible bathtub or transfer-type shower (36" x 36" – see 11B-608.2.1). For transient lodging facilities with 26 to 50 guest rooms, it is necessary to provide a minimum of three rooms with mobility features, one with a roll-in shower, and two with either an accessible bathtub or a transfer-type shower (36" x 36" – see 11B-608.2.1).

It should also be noted that the definition of transient lodging in both ADA and CBC excludes residential dwelling units intended to be used as a residence, as well as private facilities occupied by the proprietor as his/her residence, containing no more than five rooms for rent.

11B-224.2.1 Fifty or less guest room facilities.

Facilities that are subject to the same permit application on a common site that each have fifty or fewer guest rooms may be combined for the purposes of determining the required number of accessible rooms and type of accessible bathing facility.

11B-224.2.2 More than fifty guest room facilities.

Facilities with more than fifty guest rooms shall be treated separately for the purposes of determining the required number of accessible rooms and type of accessible bathing facility.

11B-224.3 Beds.

In guest rooms having more than 25 beds, 5 percent minimum of the beds shall have clear floor space complying with Section 11B-806.2.3.

11B-224.4 Guest rooms with communication features.

In transient lodging facilities, guest rooms with communication features complying with Section 11B-806.3 shall be provided in accordance with Table 11B-224.4.

TABLE 11B-224.4 GUEST ROOMS WITH COMMUNICATION FEATURES

TOTAL NUMBER OF GUEST ROOMS PROVIDED

MINIMUM NUMBER OF REQUIRED GUEST ROOMS WITH COMMUNICATION FEATURES

1

1

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

301 to 400

22

501 to 1000

5 percent of total

1001 and over

50, plus 3 for each 100 over 1000

11B-224.5 Dispersion.

Guest rooms required to provide mobility features complying with Section 11B-806.2 and guest rooms required to provide communication features complying with Section 11B-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 Section 11B-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 Section 11B-806.2 shall also provide communication features complying with Section 11B-806.3. Not more than 10 percent of guest rooms required to provide mobility features complying with Section 11B-806.2 shall be used to satisfy the minimum number of guest rooms required to provide communication features complying with Section 11B-806.3.

DOJ icon
Advisory 11B-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 ADA Title III §36.406(c) Standards for New Construction and Alterations; Places of Lodging.

[ADA Title III] U.S. Access Board's Note to Reader:

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

§36.406(c) Places of lodging.  Places of lodging subject to this part 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

          i) 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.

ETA Editor's Note

The following Access Board Note was taken from ADA Title II §35.151(f) New Construction and Alterations; Housing at a Place of Education, and from ADA Title III §36.406(e) Standards for New Construction and Alterations; Housing at a Place of Education. Wording from these two sections is the same.

[ADA Titles II & III] U.S. 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 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).

11B-224.6 Storage.

Fixed or built-in storage facilities within guest rooms required to provide mobility features shall comply with Section 11B-225.

11B-224.7 Housing at a place of education.

Housing at a place of education subject to this section shall comply with Sections 11B-224.1 through 11B-224.6 and 11B-806 for transient lodging guest rooms. For the purposes of the application of this section, the term “sleeping room” is interchangeable with “guest room” as used in the transient lodging standards.

Exception: Housing facilities that are provided by or on behalf of a place of education, with residential dwelling units leased on a year round basis exclusively to graduate students or faculty, and that do not contain any public use or common use areas available for educational programming, are not subject to Section 11B-224 and shall comply with Section 11B-233. 

DSA icon
Advisory 11B-224.7 Housing at a place of education. While the transient lodging requirements in 11B-224.7 and the 2010 ADA Standards state that the term “sleeping room” is interchangeable with the term “guest room”, the U.S. Access Board has clarified in its training on the Standards that a guest room may be either a single room or a suite of sleeping rooms. Therefore, in the CBC, the term sleeping room shall be applied to a sleeping room or a multi-bedroom housing unit, to align with U.S. Access Board guidance and training. This interpretation encompasses the various designs that may be created for housing units that are housing at a place of education. ◼

11B-224.7.1 Multi-bedroom housing units with mobility features.

Multi-bedroom housing units containing accessible sleeping rooms with mobility features shall have an accessible route throughout the unit in compliance with Section 11B-809.2. Kitchens, when provided, within housing units containing accessible sleeping rooms with mobility features shall comply with Section 11B-804.

11B-224.7.2 Multi-bedroom housing units with adaptable features.

Accessible dwelling units with adaptable features shall be provided as required by Section 11B-233.3.1.2. The number of required accessible dwelling units with adaptable features shall be reduced by the number of units with mobility features required by Section 11B-224.2.

DSA icon
 Advisory 11B-224.7.2 Accessible dwelling units with adaptable features. Units with mobility features at housing at a place of education are required to comply with the standards for transient lodging in the ADAS by the United States Department of Justice (USDOJ) in its regulatory requirements in Section 35.151 of 28 CFR Part 35 and Section 36.406 of 28 CFR Part 36 however, housing at a place of education is not a transient lodging facility. As housing, such a facility may also be required to provide residential dwelling units with adaptable features under the Fair Housing Act (FHA), if the scoping requirements of Section 11B-233.3.1.2 apply. ◼

ETA Editor's Note

The following Access Board Note was taken from ADA Title II §35.151(f) New Construction and Alterations; Housing at a Place of Education, and ADA Title III §36.406(e) Standards for New Construction and Alterations; Housing at a Place of Education. Wording from both sections is the same.

[ADA Titles II & III] U.S. 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 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.

11B-224.8 Social service center establishments.

Group homes, halfway houses, shelters, or similar social service center establishments that provide either temporary sleeping accommodations or residential dwelling units subject to this section shall comply with Section 11B-233.3.

11B-224.8.1 More than 25-bed sleeping rooms.

In sleeping rooms with more than 25 beds, a minimum of 5 percent of the beds shall have clear floor space complying with Section 11B-806.2.3.

11B-224.8.2 More than 50-bed facilities.

Facilities with more than 50 beds that provide common use bathing facilities, shall provide at least one roll-in shower with a seat that complies with Section 11B-608. When separate shower facilities are provided for men and women, at least one roll-in shower shall be provided for each group.

ETA Editor's Note

The following Access Board Note was taken from ADA Title II §35.151(e) New Construction and Alterations; Social Service Center Establishments, and ADA Title III §36.406(d) Standards for New Construction and Alterations; Social Service Center Establishments. Wording from both sections is the same.

[ADA Titles II & III] U.S. Access Board's Note to Reader: The Department of Justice’s ADA standards also require the following:

Social service center establishments.  Group homes, halfway houses, shelters, or similar social service center establishments that provide either temporary sleeping accommodations or residential dwelling units that are subject to this part shall comply with the provisions of the 2010 Standards applicable to residential facilities, including, but not limited to, the provisions in sections 233 and 809.

  1. In sleeping rooms with more than 25 beds covered by this part, a minimum of 5% of the beds shall have clear floor space complying with section 806.2.3 of the 2010 Standards.
  2. Facilities with more than 50 beds covered by this part that provide common use bathing facilities shall provide at least one roll-in shower with a seat that complies with the relevant provisions of section 608 of the 2010 Standards.  Transfer-type showers are not permitted in lieu of a roll-in shower with a seat, and the exceptions in sections 608.3 and 608.4 for residential dwelling units are not permitted.  When separate shower facilities are provided for men and for women, at least one roll-in shower shall be provided for each group.

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