Florida Specific Accessibility Requirements for Guest Rooms

Rationale

There has been some concern expressed by interested parties about the Florida Specific requirements for transient lodging guest rooms. Pursuant to the Florida Statute 553.504(4) and the corresponding Florida Accessibility Code for Building Construction (FACBC Section 224.6.3), Florida requires a minimum of 5% of the guest rooms minus the number of accessible rooms required by the ADA Standards to provide three additional accessible features: an open-framed bed, an accessible water closet and water closet grab bars. The Florida Statute and FACBC sections are shown below for reference.

The need for these additional guest rooms has been questioned as many people who may need this room type are unaware of these specific elements provided and hoteliers do not receive requests for these specific rooms. Three areas of concern have arisen: reservation requests and need for the Florida-specific guest rooms; if deemed to be requested by guests with disabilities, the costs associated with providing the bathroom elements in older hotels or motels where the water closet is segregated from the balance of the bathroom; and, the need to remove the open framed bed requirement from the Florida specific guest rooms, instead, applying the requirement to the ADA mobility rooms.

Overview

1. There has been some discussion amongst hoteliers and disability groups/caregivers as to whether the Florida specific requirements for guest rooms is known, and if these rooms are requested at all. Research can address this by way of a survey to interested groups to determine if the intended use of these rooms is actually being requested by guests with disabilities.

2. Older hotels often have bathroom configurations where the water closet is segregated from the vanity area of the bathroom, with a door separating the water closet and bathtub from the vanity and lavatory area. Providing compliant grab bars for the side and rear walls in these situations requires the removal or relocation of a wall, as well as moving the water closet to a location adjacent to a side wall that can house the side grab bar. The resulting work far exceeds the intent of the statute to simply add grab bars for the water closet. Frequently, complying with this provision of the statute for older transient lodging facilities involves a significant amount of costs, which may be an unintended consequence of the statute’s original intent. As these rooms appear to go unrequested, the additional costs may be unwarranted and unnecessary.

3. The need for the three Florida Specific elements in one guest room is confusing as they address different mobility disabilities. For example, the need for an open-framed bed is intended for the use of a portable lift for a transfer into the bed; however, there are no other mobility elements in the Florida Specific guest rooms. The ADA requirements for maneuvering areas for doors, turn areas in the rooms, and even the 36” accessible route requirements, as well as the bathroom accessible elements, are all applicable to the ADA mobility rooms and not required in the Florida Specific guest rooms. It would seem prudent to apply the open framed bed requirement to the ADA mobility rooms and eliminate the requirement for the Florida specific guest rooms.

Scope of Work

Task 1: Survey hoteliers and disabled users to establish the frequency of reserving a Florida specific guest room. This survey can be conducted through disability groups and the Florida Restaurant and Lodging Association as well as the Central Florida Hotel and Lodging Association.

Questions could include:

1. Disabled Guest: Have you ever requested a Florida Specific guest room when reserving a room at a hotel/motel or time share?

2. Do you know what accessible elements are included in a Florida-specific guest room?

a. If yes, please indicate the elements you are aware of in a Florida Specific guest room?

3. Hoteliers: Estimate the number of reservation requests for a Florida specific guest room in the last 10 years.

Task 2: Determine the costs associated with providing and accessible water closet and associated grab bars to a guest room where walls will need to be removed to accommodate the 36” rear grab bar and the 42” side wall grab bar. These costs should include possible relocation of the water closet including floor plumbing as well as the modifications to adjacent bathroom elements impacted by the wall removal. An example of a typical guest room layout in older facilities is shown below.

Task 3: Evaluate the practical application of the open framed beds to ADA mobility guest rooms in lieu of the current application in the Florida specific guest rooms.

Task 4: Provide an analysis and overview of the collected information to include the costs of providing the Florida specific bathroom elements in older facilities and relating the resulting costs to the actual requests for these elements. Additionally, provide a recommendation for applying the open framed bed element to ADA mobility guest rooms.

Expected Outcome and Impact on Code

It is expected that the outcome of this research will show the requests for the Florida Specific guest rooms are negligible and the costs to provide the additional elements, though on the surface modest in a standard guest room, can be significant in older hotel or motel rooms where the water closet is separated from the balance of the guest bathroom, with limited space to add grab bars. As a result, the costs to add grab bars will include the removal of walls and reconfiguration of the bathroom, which was not the intent of the original legislation. The costs associated with the providing the grab bars may far outweigh the requested use of these specific rooms.

More specifically:

1. It is expected the research will show the overall usage of Florida specific guest room, offering a basis for revisiting the requirement and its application, especially to older facilities. This research could provide a basis for future legislative options, including the elimination of the requirements if it is determined these guest rooms are not requested.

2. It is expected the research will present an analysis of the costs-to-use overview of adding the Florida specific bathroom elements in older facilities. This research will provide a basis for future legislative recommendations, with the possibility of eliminating the requirement, or limiting the requirement to new construction.

3. The research is expected to provide a recommendation as to whether the open framed bed requirements is more appropriately applied to the ADA mobility guest rooms. The results will provide a basis for discussion of future legislative recommendations.