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Note that for rooms with mobility features, roll-in showers will be required where the total number of guest rooms provided exceeds 50.

In alterations and additions, the minimum required number of accessible guest rooms required is based on the total number of guest rooms being altered or added instead of the total number of guest rooms provided in a facility.

This interpretation is based on the concept of “equivalent facilitation” from section 103 of the 2010 ADA Standards which states that alternative standards for the use of designs, products, or technologies can be used as long as they result in substantially equivalent or greater accessibility and usability.If a person with a disability is not employed and is not seeking employment, then that person would not necessarily be covered by that part of the ADA, although the person would be covered by other parts of the ADA.No, as of March 15, 2012, the applicable standards for alterations and additions are the 2010 ADA Standards for Accessible Design. It is important to remember that the 1991 Standards are still relevant after March 15, 2012.Elements not altered after March 15, 2012 that comply with the requirements for those elements in the 1991 Standards, do not need to be modified, even if the new standards have different requirements for these elements.This provision is called “Safe Harbor.” However, if your business chooses to alter elements that were in compliance with the 1991 Standards, the safe harbor no longer applies to the altered elements which must now comply with the 2010 ADA Standards.

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