36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

The guidelines address rooms required to provide communication features accessible to persons who are deaf or hard of hearing, including visual notification of fire alarms, telephone calls, and door knocks or bells. Telephones in such rooms must have volume controls and nearby outlets for the installation of TTYs. The Board had proposed increasing the minimum number of such guest rooms to 50% of the total number of guest rooms provided. This contrasted significantly with the original ADAAG, which specified the minimum number according to a sliding scale. It required 1 in 25 rooms to comply up to a guestroom count of 100. Scoping successively decreased to 1 for every 50 rooms for the next 101 to 200 rooms and to 1 for every 100 rooms for the next 201 to 500 rooms. For facilities with 501 to 1,000 rooms, 2% of rooms were required to comply, and where the room count exceeded 1,000, the scoping dropped to 1% (ADAAG 9.1.3). The original ADAAG also required that all accessible guest rooms be equipped with communication features in addition to the number of rooms required to provide communication access only (ADAAG 9.2.2(8)).

The Board had proposed the increased scoping for guestrooms with accessible communication for several reasons. The communication features addressed in this requirement address life safety in providing visual notification of fire alarms for people who are deaf or hard of hearing. The Board also felt that the increased scoping would afford greater flexibility in the guest room assignment of people who are deaf or hard of hearing, especially in light of revisions to the technical requirements that effectively preclude the use of portable visual alarm devices. In addition, permanent installation of visual alarm appliances is considerably less expensive and easier to achieve as part of facility design and construction than as a retrofit.