AN EMPLOYEE-OWNED FIRM

ADA at a Glance

2010 ADA Guidelines for Recreation Facilities

(as applied to the Great Lakes Region)

The following notes were generated from a June 2011 phone conversation between Ramaker & Associates and the Disability and Business Technical Assistance Center (DBTAC Great Lakes ADA Center). Anyone pursuing ADA compliance should contact the DBTAC along with their local pool licensing agency for specific questions regarding the application of ADA requirements.

The compliance date established is March 15, 2012. This is not a hard and absolute date, but a marker point for what could be considered a "Readily Achievable" timeframe.

"Readily Achievable" is the magic phrase that surrounds this regulation in regards to existing facilities. It encompasses all the factors that can come into play, and more or less means that each facility has its own situations, circumstances, and limitations; therefore, each facility needs to be looked at and considered individually.

Title II Government facilities are the most burdened by the 2010 ADA Standards. These facilities include School Districts, Municipalities, Park Districts, non-private Hospitals or Athletic Centers, or any State or Federally Owned facilities. Title II facilities will be held to the compliance date more strictly and will most likely be under more scrutiny from the general public.

The 2010 ADA Regulations state that any modifications or alterations will require the standards be put into affect. This is only in regards to the specific modifications or alterations being performed. Any modifications that occurred for VGBA compliance do not affect the need for ADA compliance. Likewise, general maintenance modifications or alterations in a pool room, or any other areas of the building, do not affect the swimming pool.

Depending on the extent of the modifications or alterations, the path of accessibility will need to be brought into compliance. For example, if a hotel remodels and redesigns their lobby area, the accessibility paths to other areas (pool area) will need to brought up to the 2010 ADA Standards. If the same hotel chooses to expand their indoor swimming area, any new pools will need to be designed to current 2010 ADA Standards. However, if the existing pools are not altered, the existing pools may only need to add a lift, but will not have to fully conform to the new standards.

In general, the guidelines that exist for the design of a new pool do not necessarily apply to existing pools. For example, a competition lap pool (greater than 300 LF) that was designed and built in the 1960s with no access points in the pool (you have to jump in if you want to swim), will satisfy the ADA regulation by installing one lift. Similarly, a 12-inch deep baby pool without zero depth entry may not require anything, because it could be argued that creating a zero-depth entry pool is not Readily Achievable due to area available and/or cost associated.