ADA accessible cold plunges

[Ryan Schultz]

Helping a client design a spa. As you can see from the floor plan, each room has a sauna and cold plunge.

The cold plunge looks something like this.

Question: Like the 5% rule for saunas, I assume at least 5% of the cold plunges need to be accessible as well, correct?

If that be the case, does this ADA cold plunge need something like a swimming pool chair lift to make it accessible?

 

[JPohling]

not sure of your location, but in CA I would use this for scoping.

 

[Sifu]

The ANSI standard has commentary about this.
2017 ANSI 117.1 1009.1.3:
 Hot tubs or spas can be constructed so their edges
are at grade or elevated to the height of the pool.
Options for providing entry are by pool lifts, transfer
walls or transfer systems. If there is a group of hot
tubs, then only one in each location is required to
have an entry point.
The text does not address when there may be different
types of spas, such as a cold tub and a hot tub.
These are sometimes provided associated with saunas.
Good design would provide an entry point to
both.

 

[Ryan Schultz]

Could a portable lift, like this, be used, i wonder.

 

[Sifu]

I recently went through a project similar in nature. There were several single user cold therapy tubs, and a single multi-user hot tub, all in a single open space. Normally a portable lift is not acceptable, however they submitted an AMMR to use a portable lift which was approved by the AHJ CBO. In my opinion, in this case, the portable lift offered a greater level of access than if a single stationary lift was installed. If a stationary lift was used, it would have served only one of the tubs in total, either the cold or hot, but not both based on the ANSI standard not differentiating between the two types. With a portable lift, access could be provided to any of them.

 

[JPohling]

Sifu, Think if it was me I would have required a fixed one for the hot tub and a portable to serve the multiple cold pools. If the only portable is in use at one of the cold pools someone could get cooked a little too long in the hot tub.

 

[Sifu]

Sifu, Think if it was me I would have required a fixed one for the hot tub and a portable to serve the multiple cold pools. If the only portable is in use at one of the cold pools someone could get cooked a little too long in the hot tub.

I actually brought that up in the critical thinking exercise for the AMMR with the CBO. The AMMR included language to ensure the staff would constantly attend the spaces containing the tubs.

 

[redeyedfly]

I recently went through a project similar in nature. There were several single user cold therapy tubs, and a single multi-user hot tub, all in a single open space. Normally a portable lift is not acceptable, however they submitted an AMMR to use a portable lift which was approved by the AHJ CBO. In my opinion, in this case, the portable lift offered a greater level of access than if a single stationary lift was installed. If a stationary lift was used, it would have served only one of the tubs in total, either the cold or hot, but not both based on the ANSI standard not differentiating between the two types. With a portable lift, access could be provided to any of them.

Why would a portable lift not be acceptable? I read the sections of A117.1 and ADA but could not find any requirement that the lift could not be portable.

 

[mark handler]

It is an amenity that should be available to all.
New Building (Construction), Shall comply. provide vertical access.

 

[redeyedfly]

It is an amenity that should be available to all.
New Building (Construction), Shall comply. provide vertical access.

How does a portable lift not provide access?

 

[Sifu]

I would say they do provide access, but not equal access. I think it has to do with unassisted operation. If the lift is portable it could be inaccessible to the user, who might be required to seek assistance in getting out of the closet, back room etc. Then they would need to somehow transport the lift and position it in the proper location before they could then operate it. Then, once in, and someone moves it, now they are stuck in the water. Pretty sure the DOJ interpretation is that lifts must be permanent. I seem to remember when the rule first came out that this was an undue hardship and there was a bit of fuss, and I don't remember the details, though it may have been only for existing pools and I think they just backed up the compliance date, which I believe has long passed.

 

[Sifu]

https://archive.ada.gov/qa_existingpools_titleIII.pdf

 

[mark handler]

https://archive.ada.gov/qa_existingpools_titleIII.pdf

Sifu,
I do believe this is a NEW Spa. The doc you provided is for existing pools

 

[Sifu]

Agree. Posted it to show that the elasticity in the rule applied to existing facilities, not new ones.