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

Americans with Disabilities Act

GUIDE FOR PLACES OF LODGING: SERVING GUESTS WHO ARE BLIND OR WHO HAVE LOW VISION

The Americans with Disabilities Act (ADA) requires places of public accommodation, including hotels, motels, and other places of transient lodging, to ensure that everyone regardless of disability has an equal opportunity to enjoy their services and facilities.

Your establishment is covered by the ADA as a place of public accommodation if it is a private entity and is a place of lodging (including inns, hotels, and motels), regardless of whether it is a for-profit or nonprofit establishment. The ADA does not cover owner-occupied establishments renting five or fewer rooms.

Your ADA Obligations

Places of lodging, like other places of public accommodation, must provide their services to the public in a way that gives people who are blind or who have low vision a full and equal opportunity to enjoy the services that are provided to others. You must, for instance:

• Follow accessibility standards when constructing or altering facilities;


• Remove architectural or structural communication barriers in existing facilities where it is readily achievable to do so;


• Make reasonable modifications in policies and procedures (e.g., allow person to be accompanied by service animal or guide dog, even if a hotel has a ‘no pets’ policy);


• Eliminate discriminatory eligibility criteria (e.g., allow a guest to use alternative state ID to substitute for driver’s license at check-in); and


• Provide auxiliary aids and services leading to effective communication if it is not an undue burden and does not fundamentally alter the nature of the goods or services provided (e.g., provide alternate format materials such as Braille, large print, and audio tape when guest cannot read standard print materials due to a disability).

This publication is designed to help you and your staff to understand these obligations.

The ADA gives businesses a certain degree of flexibility in meeting these obligations. If some steps are too costly or burdensome for you to undertake, you must use alternative methods that are not so costly or burdensome in order to afford people with disabilities as much access as possible to your goods and services.

To make sure your hotel and the services you offer do not discriminate against people who are blind or who have low vision, it is helpful to think about how guests use your hotel:

How do guests arrive at your hotel and what do they do once they get there?

How do guests check-in and check-out?

How do they move about your facilities?

How are the rooms set up?

What in-room guest services are provided?

What other amenities are available?

People Who Are Blind or Who Have Low Vision

Approximately 2.5 million people in the United States are “legally blind” – meaning that even with corrective lenses, they have less than 20/200 visual acuity or that their visual field is 20 degrees or less, regardless of acuity. Many of them have some residual vision. Only about 5% of blind people use Braille for reading; many people who are legally blind are able to read large print.

Many have “low vision.” Many have eyesight that is better than 20/200 or a visual field that is greater than 20 degrees, but they have some significant impairment that substantially limits their ability to see well under different circumstances. In some people, the center of the field of vision is obscured. In others, the peripheral vision is obscured, as though they are looking through a tunnel. Others have conditions that cause glare to produce rapid eye strain.

Many people who are blind or who have low vision wear very thick glasses or very dark sunglasses. Others carry white canes. Still others use service animals such as guide dogs. Some walk with another person who serves as a sighted guide. Some who are legally blind or who have low vision do not use a cane or a guide dog or wear glasses of any kind.

Arriving At the Hotel

Shuttle Buses. If you provide shuttle bus services, those services are subject to the ADA. Your shuttle bus drivers should be trained to offer assistance to people who are blind or who have low vision. Staff should inform guests who are blind or who have low vision of the presence of the shuttle bus. Drivers should announce all stops to riders who are blind or who have low vision. Service animals such as guide dogs should be permitted to accompany their handlers. For other requirements applicable to shuttle buses, please contact the Department of Transportation at 1‒888‒446‒4511 (voice; TTY users should use relay service) or review their information online (www.fta.dot.gov/office/civ.htm).

Wayfinding. Staff who assist guests at the front door should offer assistance to guests who are blind or who have low vision in finding the Registration Desk or other hotel facilities.

Check-In and Check-Out Procedures

Front Desk. Hotel staff working with guests who are blind or who have low vision should introduce themselves by giving their names and functions.

Do not make assumptions about the extent of a person’s visual acuity. Instead, you should inform the guest what services – including alternate format materials such as Braille, large print, and audio cassette versions of printed material normally provided to guests – are available, offer assistance, and be guided by his or her response. Many hotels have found it helpful to have a package prepared for guests who are blind or who have low vision. This package might include items such as alternate format materials, a high contrast template to fit over the telephone keypad, and a list of available services, such as increased lighting in a guest room.

If a guest refuses assistance or an offer of a particular accommodation, the law requires you to respect this refusal. If your guest requests assistance, let him or her guide you in the most effective way of responding to the request. You should not ask a guest for documentation that he or she is blind or has low vision. If more than one person is in a party with a person who is blind or who has low vision, you should treat the group as you would any other and communicate directly with whomever approaches and speaks to the desk clerk; if the person who is blind or who has low vision is the one to approach the desk and ask for a room, the staff should talk directly to him or her rather than any travel companions.

Using Appropriate Language. Use disability-sensitive language and etiquette. Using words such as blind, visually impaired, seeing, looking, watching television are acceptable words in conversation. Similarly, using descriptive language, including references to color, patterns, and the like, is appropriate. When referring to guests with disabilities, refer to the person first, then the disability.

Forms and Documents. Upon request, staff should read fully, and provide assistance in completing, registration folios, hotel bills, service request forms, and other documents. You may find it more helpful to your guests to provide frequently used documents – including registration instructions – in Braille, cassette tape or telephone recording, and large print. Many people who are legally blind or who have low vision are able to read documents printed in 18 or 20 point type in a sans serif font such as Arial.

Payment. When handing currency to a guest, bills should be individually identified and counted. Credit cards should be handed to guests after imprint, not simply laid on a counter or table. A piece of cardboard or a plastic or metal signature template can be used to indicate where a signature is required. Train your staff to simply place a cardboard edge horizontally below a signature line or orient the opening of a signature template wherever a signature is required.

Room Keys. Use of a passcard-type room key may be difficult for a guest who is blind or who has low vision. It is often not possible to determine by touch which way to place the card into the locking mechanism. One solution to this problem might be to place a small piece of tape on the card running in the same direction as the visual arrow and inform the guest as to its significance. Alternatively, a small corner of the card – on the side opposite the magnetic strip – can be clipped for easy tactile orientation.

Room Selection. Do not assume that a person who is blind or who has low vision will require or want to be placed in a room designated for people with disabilities. Just as you would with other guests, ask the person about his or her preferences. If someone is traveling with another person but they have requested separate rooms, ask whether they would prefer to be in adjoining rooms. For security reasons, most hotel receptionists inform the guest in writing of his or her room number. While guests who are blind or who have low vision should be told their room numbers orally, care should be taken so third parties do not overhear this information.

Information in Alternate Formats. Guests who are blind or who have low vision should be informed of all front desk information that is available to other guests through visual means – such as posted check-out times and acceptable methods of payment. All information that is available to others should be made available to people who are blind or who have low vision, in Braille, large print, audio recording, or orally. Some hotels have found it helpful to put all relevant information into a single package and inform guests who are blind or who have low vision of its availability at check-in.

Reviewing the Bill. Staff should give the guest a printed copy of his or her bill, even if the person cannot read standard print without assistance. If requested, you should also provide a large print copy. Staff should offer to review the entire bill with the guest in a way that respects the guest’s privacy. When the person has checked out, offer to provide assistance in locating the shuttle bus or a taxi.

Guide Dogs and Other Service Animals

You must allow people with disabilities to go wherever guests are generally allowed, even when they are accompanied by guide dogs or other service animals. For detailed information about services animals, please refer to the Department of Justice’s ADA guide, “Commonly Asked Questions About Service Animals in Places of Business.”

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.

Guest Rooms and In-Room Guest Services

Orientation to the Room. Guests who are blind or who have low vision should be offered a thorough orientation to their guest rooms. If the guest accepts the offer, staff should explain the location of the bed, desk (and associated electrical outlet and data port, if provided), dresser, table and chairs, thermostat, television and remote control, light switches and lighting, closet, suitcase stand, and telephone. Staff should also offer to tell the guest how to operate the drapery controls and explain whether the curtains are open or closed and opaque or see-through. Staff should offer to turn the lights on for guests with low vision. If a microwave oven, coffee maker, or safe is provided, its location and operating instructions should also be given. When orienting the guest to the bathroom, staff should explain how to work the shower, where the linens, ice bucket, and glasses are located, and what complementary toiletries (shampoo, lotion, soap, etc.) are provided and how to distinguish them from each other. Staff may also offer to set up the iron and ironing board.

Staff should always inform guests as to the location of the nearest fire exit, using specific language such as, “In case of a fire, exit your room to the left. The emergency exit stairway will be the fifth door on your right.”

It is also helpful to inform the guest as to the location of ice and soda dispensers, using similarly specific language.

Lighting. Many who are legally blind or who have low vision will appreciate an increase in the amount of available lighting in their rooms. Simply changing light bulbs to a higher wattage or providing extra floor and table lamps may make a significant difference to them. Some hotels inform guests who are blind or who have low vision of the availability of additional room lighting when they check in.

Instructions for Use. During check-in, hotels should inform guests who are blind or who have low vision that the hotel will provide, free of charge, large print, Braille, and recorded instructions for all services for which print instructions are provided for guests. Some of the more common instructions include:

• Telephone – including dialing instructions, local and long distance charges, and a list of the in-house numbers for room service, wake-up calls, etc.;
• Room service menus, hours of operation, and telephone number;
• Television – including a list of available channels, instructions and charges for ordering inhouse movies, etc.;
• Thermostat – including any automatic features, location of ‘on’ and ‘off’ switches, etc.;
• Laundry, valet, and water-conservation policies;
• Security instructions;
• Check-out policy.

Guests may require assistance when ordering movies or using other television features, as choices are only visual and change frequently.

Recorded instructions can be provided on a telephone answering machine or by loaning the guest a cassette recording and cassette player upon check-in. A reasonable, fully refundable deposit may be required for cassette players.

Guest Room Telephones. Many people who are legally blind or who have low vision find it very difficult to see individual numbers on dial pads and important graphics (e.g., for room service, front desk, etc.) on guest room telephones. Most guest room phones are in beige or another neutral color and do not have much contrast between the background color and the color in which graphic information and numbers are displayed. High contrast large print templates can be fashioned to fit over the telephone keypad. Such templates can greatly reduce the number of repeat calls to hotel operators by people who simply cannot see all of the information displayed on the telephone. Some hotels provide such templates in the package of information they provide upon check-in to guests who are blind or who have low vision.

Emergencies. Emergency evacuation instructions should be provided in a way that can be used effectively in the event of an emergency. One way to do this would be to hang Braille and large print evacuation instructions on the back of the door, adjacent to where they are posted for others to see. Audiotapes may not provide effective communication in the event of an emergency.

Restaurants and Lounges

When a guest who is blind or who has low vision is entering, leaving, or maneuvering through a restaurant, you should offer to provide assistance using the techniques described above in the section titled, “Sighted Guide Techniques.”

Seating arrangements. Ask the guest about his or her lighting preferences. Would he or she prefer to be near a window? Would he or she prefer a table with strong lighting? If the guest will be eating from a buffet, would he or she prefer to sit near it? In any case, do not try to “hide” your guests with disabilities by placing them in secluded areas.

Buffets. For buffet service, offer assistance in identifying and serving food on the buffet table. If one of the guest’s hands is occupied by holding a cane or using a service animal, staff may offer assistance in carrying the food to the table.

Menus. Hotels should provide menus in alternate formats including Braille, large print, and audio recording. Additionally, staff should offer to read the menu, including listings and prices. When reading a menu, staff should first read broad categories of items and allow the guest to choose which categories are of interest. Do not rely on sighted companions to provide menu reading assistance, unless your guests indicate that is their preference.

Assistance During the Meal. Staff should ask guests who are blind or who have low vision whether they would like any assistance during the meal. Some guests may ask the wait staff to explain the arrangement of the tableware and describe the placement of food and beverage items as they are being served. One way to assist your guest would be to describe the location of the food or beverage using the face of a clock. For example, “Your meat is at 6 o’clock and your vegetables are at 3 o’clock.” Staff should speak directly to people with disabilities, not to their nondisabled companions, when it their turn to order.

Because some guests who are blind or who have low vision may have difficulty locating their servers, staff should remember to return to the table from time to time, announce their presence, and ask whether the guests need anything else. Staff should also offer to assist guests who are blind or who hve low vision in locating restrooms.

Paying the Bill. With regard to reviewing the bill, handling currency and credit cards, and signing sales slips, restaurant staff should follow the same procedures discussed above in the section entitled “Check-In and Check-Out Procedures.”

Gift Shops

Follow the techniques described above to help guests who are blind or who have low vision shop in your stores. Offer assistance with locating items and reading price tags. Identify individual bills when handing currency to a guest. Hand credit cards back to your guest, rather than leaving them on a counter. Provide signature templates or use a piece of cardboard to indicate where your guest should provide a signature.

Recreational Facilities

Guests who are blind or who have low vision generally have the same right to use your recreational facilities as others. Unless there is a legitimate safety reason why someone cannot use a facility – a sound reason that is not based on stereotypes and that cannot be ameliorated by providing auxiliary aids and services or making reasonable policy modifications – you cannot exclude them from recreational activities. An example of when it might be appropriate to exclude a blind person would be if your hotel offers a go-cart track and requires users to be licensed drivers, and the person is not a licensed driver. You cannot ask people who are blind or who have low vision to sign waivers of liability unless everyone who uses the equipment or amenities is also asked to do so. Any instructions for use – including hours of operation and safety rules – should be communicated orally to persons who are blind or who have low vision. If you use passcard-style keys for recreation areas, you should make those keys accessible to people who are blind or who have low vision, using the simple techniques described in “Check-In and Check-Out Procedures.”

Additionally, it can be difficult or impossible for people who are blind or who have low vision to use electronic exercise equipment, if equipment controls are on a touchscreen or touchpad. Simply putting a piece of tape over the “on/off” button and informing your guests of the tape’s significance can make the equipment more usable.

Business and Conference Facilities

You will find that the techniques described above to assist guests who are blind or who have low vision in moving throughout your hotel will also help them use your business and conference facilities.

Staff Training

Providing good training to your staff is perhaps the single most important step you can take towards meeting your ADA obligations. A training program should include each of the subjects discussed in this publication and should be updated on a regular basis. It is always a good practice to involve people who are blind or who have low vision in the development of your training programs.

Tax Credits and Deductions

To assist businesses with complying with the ADA, Section 44 of the IRS Code allows a tax credit for small businesses and Section 190 of the IRS Code allows a tax deduction for all businesses. The tax credit is available to businesses that have total revenues of $1,000,000 or less in the previous tax year or 30 or fewer full-time employees. This credit can be up to $5,000 annually – reimbursement for 50% of your eligible access expenditures in a year, for expenditures between $250 and $10,250. The tax credit can be used to offset the cost of undertaking barrier removal and alterations to improve accessibility; providing accessible formats such as Braille, large print, and audio tape; making available a sign language interpreter or a reader for guests or employees, and for purchasing adaptive equipment. The tax deduction is available to all businesses with a maximum deduction of $15,000 per year. The tax deduction can be claimed for expenses incurred in barrier removal and alterations.

Sources of Technical Assistance

Department of Justice’s ADA Information Line

The ADA Information Line is available during weekdays to provide technical assistance on the ADA Standards for Accessible Design and other ADA provisions applying to businesses, non-profit service agencies and state and local government programs. It also provides a 24-hour automated service for ordering ADA materials. This free service provides answers to general and technical questions about ADA requirements and is a source for free ADA materials including the ADA Standards for Accessible Design.

You may reach the ADA Information Line at:

800‒514‒0301 (voice)

800‒514‒0383 (TTY)

ADA information is also available on the Department’s ADA Home Page:

www.usdoj.gov/crt/ada/adahom1.htm

Other Documents Available from the Department of Justice

• Self-Evaluation Checklist for Hotels and Motels to Ensure Access to Services and Facilities by Customers Who Are Blind, Deaf-Blind, or Visually-Impaired
• Common ADA Errors and Omissions in New Construction and Alterations | Acrobat PDF format
• Common ADA Problems at Newly Constructed Lodging Facilities | Acrobat PDF format
• ADA Checklist for New Lodging Facilities
• Five Steps to Make New Lodging Facilities Comply With the ADA | Acrobat PDF format
• Title III regulation, including the ADA Standards for Accessible Design
• Title III Technical Assistance Manual
• Tax Incentives Packet on the Americans with Disabilities Act
• Accommodating All Guests: The Americans with Disabilities Act and the Lodging Industry," which was prepared in conjunction with the American Hotel & Motel Association.

Disability and Business Technical Assistance Centers (DBTACs)

Ten regional centers are funded by the Department of Education to provide technical assistance on the ADA. Calling 800‒949‒4232 (voice & TTY) will connect you to the center in your region, or reach them on the Internet, www.adata.org.

Access Board

The Access Board offers technical assistance on the ADA Accessibility Guidelines. Call 800‒872‒2253 (voice) or 800‒993‒2822 (TTY), or reach them on the Internet, www.access-board.gov.

Equal Employment Opportunity Commission (EEOC)

The EEOC offers technical assistance on the ADA provisions for employment which apply to businesses with 15 or more employees.

Employment questions: 800‒669‒4000 (voice) 800‒669‒6820 (TTY)

Employment documents: 800‒669‒3362 (voice) 800‒800‒3302 (TTY)

www.eeoc.gov

Local Libraries

Technical assistance materials including the title III regulations that apply to businesses have been distributed to 15,000 libraries nationwide. This collection is known as the ADA Information File. Contact your local or regional library to find if it has the ADA Information File and where it is located. You may also contact your regional DBTAC (800‒949‒4232) to obtain the name of a local library that has the ADA Information File.

Reproduction of this document is encouraged.

January 2001