Accessibility Laws for Hotels and
Other Lodging Establishments

Table of Contents

What does the ADA require for telephone accessibility?

Two levels of accessibility are required:

1) Guests who are deaf or hard of hearing must be able to make calls from their guest rooms

TTYs must be available to guests upon check-in to afford them the same telephone service offered to guests who can hear. "A public accommodation that offers a customer, client, patient or participant the opportunity to make outgoing telephone calls on more than an incidental convenience basis shall make available upon request, a TDD for the use of an individual who has impaired hearing or a communication disorder." (Title III, Department of Justice, July 26, 1991, Section 36.303 (d))

2) Specific services within the hotel must be equipped to receive TTY calls. "Hotels should also provide a TDD or similar device at the front desk in order to take calls from guests who use TDDs in their rooms. In this way guests with hearing impairments can avail themselves of such hotel services as making inquiries of the front desk and on dining room service." (Title III, Department of Justice, Federal Register, July 26, 1991, preamble)

Service stations including the front desk, room service, and security should be accessible to guests who use TTYs. A TTY with an internal printer is recommended to provide a record of the conversation. Since an employee must watch the display, it is difficult to take notes at the same time. Or, if they are interrupted and look away from the display, they might miss a portion of the conversation. With an internal printer, everything that is typed (on either end of the conversation) is recorded.

Printing TTYs can include a variety of options from a basic printing unit with no frills to automatic answering of calls, keyboard dialing, memory capabilities, time and date stamping, and a built-in flasher.

How many TTYs do I need to be accessible?

ADA specifies that, in newly constructed and renovated sites, 4% of the first 100 rooms and 2% of every 100 rooms thereafter need to be TTY accessible. If your facility has 200 guest rooms you would need six TTYs on hand to loan to guests upon arrival as well as a TTY for service locations such as the front desk, room service and security. See CHART

Will TTY equipment work with my phone system?

Yes, TTY equipment is FCC approved and designed to be compatible with even the most modern telecommunications systems. When the front desk receives a TTY call, the call can be transferred to the line with the TTY connected to it, or, the operator can put the handset into the acoustic cups of the TTY and handle the call in that manner. TTYs which are connected directly to the phone line are preferred because the handset remains free for taking calls on other lines. It also removes any possibility of background noise interference. A direct connect TTY works with a standard analog RJ11 jack.

How can my staff get instruction on TTY use?

A videotape for training can be purchased for employees to review periodically. It demonstrates the use of a TTY including equipment setup and TTY etiquette.

Do my guests need instructions on TTY use?

Most people who use TTYs are very familiar with them. It is their primary means for using the telephone. You may want to provide the unit's manual when loaning the TTY to your guests

Direct quotes gathered from the ADA Technical Assistance Manual

"A public accommodation shall take those steps that may be necessary to ensure that no individual with a disability is excluded, denied services, segregated or otherwise treated differently than other individuals…"

"A public accommodation that offers a customer, client, patient or participant the opportunity to make outgoing telephone calls on more than an incidental convenience basis shall make available, upon request, a TDD (Text Telephone) for the use of an individual who has impaired hearing or a communication disorder."

"If a total number of four or more public pay phones (including both interior and exterior) is provided at a site, and at least one is an interior location, then at least one interior Public Text Telephone shall be provided".

"Public Text Telephone shall be identified by the international TDD symbol"… "Text Telephones should be permanently affixed within, or adjacent to, the telephone enclosure".

"Hotels should also provide a TDD (Text Telephone) at the front desk in order to take calls from guests who use TDDs in their rooms".

Match the number of rooms in your Facility
with the number of kits required by ADA

The above information can be found in section III of the
Technical Assistance Manual for ADA

How does TTY communication work?

TTY conversations are conducted by two parties, both of whom must use a TTY. So, instead of speaking and listening, the parties type and read back and forth to each other, taking turns in the conversation. The TTY transmits tones (in response to what is typed) through the telephone line to the TTY machine on the other end.

What features will be helpful for my staff?

An internal printer is helpful for record keeping. Memory features are also helpful for pre-recording often used phrases that can then be sent out easily at any point in the conversation. Phrases such as "You have reached the front desk, how may I help you?" or "This is room service, may I take your order?" or "Your order will arrive within 30 minutes."

What features are useful for the guests?

A direct connect TTY with auto-answer capability will allow the guest to receive incoming TTY messages in his/her room when he/she is out. A basic unit with a printer will allow for messages to be recorded on the paper but not in the memory to ensure confidentiality.

If I provide a TTY to the guest, does that mean
the phone service is then fully accessible?

No, you also need to provide a signaling device which will alert the guest to the telephone ringing in the room. A lamp in the room is then plugged into the Master. When the telephone rings, the lamp will flash on and off. A suitcase may be purchased which includes all of the necessary equipment to be placed within a guest's room. The hotel suitcase includes equipment such as a smoke detector, telephone amplification and alarm clock with a signaler or bed vibrator.

Is the built-in red light on the telephone enough to alert the hearing impaired guest to the ringing telephone?

No, the light must be capable of catching a person's attention even when his/her back is turned. A lamp flashing on and off is much more visible.

How can I let people know that my hotel is TTY accessible?

Signs that say "TTYs available here" or "TTY Accessible" posted near the front desk let your guests know (at check-in) that they can request equipment.

You should also mention the availability of equipment in the literature you place in the guest rooms. You should also add the TTY number to all directory listings and advertising and list "TTY" after every service number that is TTY accessible-within the hotel and for outside lines.

The media is also very interested in accessibility (including publications for individuals who are deaf) and will run your press release, especially if it is accompanied with a photograph that helps to tell the story.

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