Title III Technical Assistance Manual (with 1994 supplement)

III−4.3400 Telecommunication devices for the deaf (TDD's). In order to ensure effective communication by telephone, a public accommodation is required to provide TDD's in certain circumstances. Because TDD relay systems required by title IV of the ADA (which must be operational by July 26, 1993) will eliminate many telephone system barriers to TDD users, the auxiliary aids requirements relating to TDD's are limited in nature.

III−4.3410 Calls incident to business operations. A public accommodation is not required to have a TDD available for receiving or making telephone calls that are part of its business operations. Even during the interim period between the effective date of title III and the date the TDD relay service becomes available, there is no requirement that public accommodations have TDD's. Of course, the ADA does not prevent a public accommodation from obtaining a TDD if, for business or other reasons, it chooses to do so.

III−4.3420 Outgoing calls by customers, clients, patients, or participants. On the other hand, TDD's must be provided when customers, clients, patients, or participants are permitted to make outgoing calls on "more than an incidental convenience basis. " For example, TDD's must be made available on request to hospital patients or hotel guests where in-room phone service is provided. A hospital or hotel front desk should also be equipped with a TDD so that patients or guests using TDD's in their rooms have the same access to in-house services as other patients or guests.

It is the hotel's or hospital's responsibility to monitor requests for TDD's to ensure that it has a sufficient supply of such devices. The facility should acquire what it reasonably predicts will be an adequate number of TDD's, and then acquire additional TDD's if experience shows that an increase is necessary to meet actual demand.

Newly constructed hotels must have a certain number of rooms that are accessible to persons who are deaf or hard of hearing (the exact number is dependent on the number of rooms in the hotel). This number of rooms is a useful reference point for a facility attempting to gauge the number of TDD's necessary for effective communication.