Aquatics and Accessibility

Beyond ADA Compliance

By Chris Gelbach

In 2010, the Department of Justice published updated regulations under the Americans with Disabilities Act (ADA) that for the first time addressed accessibility requirements for aquatic recreational facilities, such as swimming pools, wading pools and hot tubs. For recreation managers, the extended compliance date for existing pools of Jan. 31, 2013, is fast approaching.

To be compliant, state and local governments (considered Title II facilities under the ADA) must make their recreational programs and services, including swimming pool programs, accessible to people with disabilities. And public accommodations, such as hotels, resorts and swim clubs (Title III facilities,) must remove physical barriers in existing pools to the extent that it is readily achievable to do so.

The original ADA guidelines, now more than 20 years old, already addressed accessibility from the parking lot to the edge of the pool. "The only thing that changed in 2010 with the revision is that facilities now have to be concerned with getting people into the water," said John Caden, accessibility specialist for a Canby, Ore.-based manufacturer of swimming pool equipment, including pool lifts.

Caden noted that a barrier-removal analysis is required for Title II facilities and recommended for Title III facilities. This involves making an analysis of each body of water in your facility, looking at the regulations for those types and sizes of pools, and determining whether your existing means of access comply.

According to Caden, if you're not in compliance, you then need to ask yourself two questions. "If it's an existing pool, what's the least expensive way to do this that serves the most number of people? And if it's a new construction, how can I accomplish this and also make it look really slick?"

Swimming pools with less than 300 linear feet of pool wall must provide at least one accessible means of entry, either a pool lift or a sloped entry. Pools with more than 300 linear feet of pool wall must have two accessible entry means, one of which must be a pool lift or a sloped entry. For the secondary means of entry, a transfer wall, transfer system or easy-access pool stairs are also acceptable options.

Doug Anderson, partner for the architecture and accessibility consulting firm LCM Architects, suggested that facilities have a plan in place by the Jan. 31 deadline, even if they can't get their pool up to code by that date. "Because this deadline was pushed back, there's been a lot of anticipation, and there will probably be a lot of attention paid to this by disability groups," he said. "You want a plan you can show people if they ask—either that you've ordered a lift or that you're planning to do a sloped entry."

The updated guidelines also include separate requirements for specific pool types. For example, wave-action pools, leisure rivers, sand bottom pools and other pools where user access is limited to one area are required to provide one accessible means of entry, and catch pools aren't required to provide an accessible means of entry if the pool edge is on an accessible route. The requirements for wading pools, spas, hot tubs and saunas, as well as other aquatic structures, such as fishing piers and recreational boating facilities, are all spelled out in the 2010 Standards document available at www.ada.gov.

Compliance with these regulations is important, and noncompliance can put facilities at risk for a fine or lawsuit. But Anderson stressed that they remain just one element of the overall barrier-removal plan—and not necessarily the most important one for facilities still not ADA-compliant in other areas.

"They just need to be considered when facilities are deciding to spend money on accessibility-related work," he said. "For example, if there's still a major accessibility issue at the front entrance of the facility, that should still be addressed before they get to the pool requirements."

Retrofitting Existing Pools

For existing pools that are not currently compliant, a pool lift is often the most practical addition as a primary means of access, since retrofitting a pool to include a sloped entry (ramp) can be a major construction project.

"A lift is easier to implement, and probably a more economical option, too, as opposed to a ramp, even in a new application," said Tom LaLonde, principal for Williams Architects, an Itasca, Ill.-based architectural firm that has worked on a number of public-sector pool projects. "The ramps can be quite extensive—they need to get you down into about three feet of water. The maximum slope of a ramp is one and twelve [depth to length]. So you're going to need somewhere in the range of 40 feet of ramp." This space requirement also means a pool lift is a more practical option for smaller pools.

For new purchases, portable lifts are only compliant if affixed to the pool deck or apron. The main two types of fixed lifts are sleeve-mounted and deck-mounted lifts. Anderson notes that sleeve-mounted lifts are sometimes favored by his hospitality clients that use the pool area for multiple purposes. "Hotels that have wedding receptions or poolside parties like the idea of a sleeve mount because they can remove the lift for events where people won't use the pool, because they do stand out," he said.

Because they are more readily removable, Anderson also sees advantages to sleeve mounts for facilities in northern climates, since they are easier to remove for offseason storage. But they are not always the best choice, or appropriate for all pool types. "I would recommend consulting with a lift representative to see what type of lift is best depending on the drainage system of your pool," he said.

For larger pools that need two means of entry, it is common to select a different approach for the second entry. For paraplegics and others who aren't ambulatory, a pool lift can provide more independent access into a pool than stairs or even a sloped entry, which can be difficult to traverse without assistance in an aquatic wheelchair. But other patrons with physical limitations often opt for other means of entry when provided the option because they feel self-conscious using a pool lift.

"A lot of people with disabilities would prefer a ramp or stair because the lift draws attention to them," said LaLonde. "There are people who don't need the lift, but can walk with some assistance. If they can walk into the pool as opposed to sit in the chair and be helped into the water, I think they'd prefer that."

At the Chicago Park District, which has 26 indoor and 51 outdoor pools, all of the pools are equipped with a pool lift, and some also have easy-access stairs or a zero-depth ramp. "Our philosophy in terms of disability access and advocacy in the park district is that people with disabilities and physical limitations should have options just like their non-disabled counterparts do. So we try to provide options," said Larry Labiak, disability policy officer for the Chicago Park District.

In his work for clients, LaLonde sees facilities with larger pools almost always opting for a pool lift for one of the two entry options, and estimates that it's a 50/50 split between a sloped entry and a transfer wall or stairs for the second means of entry. "We do see many of our clients opting for the ramp, even though it's a costly proposition for them," he said.

After ensuring the accessibility of the swimming pools, Anderson recommends looking at your hot tubs. For those, a primary means of accessible entrance can be a transfer wall. "If you have a partially raised hot tub, that might only involve mounting a couple of grab bars on the wall to allow the transfer," he said.

For other aquatic features, becoming compliant may be cost-prohibitive, and, therefore, not readily achievable. For example, wading pools are required to have a sloped entry. "If you don't have it now, it's a pretty big deal trying to retrofit a wading pool to have that, so that might be something that goes on your long-term plan for modification," said Anderson.

Accessibility for New Facilities

When considering a new facility, recreation managers typically have more flexibility in their options to create a compliant facility—and to go beyond compliance to build pools that are more inclusive and usable for all audiences.

In selecting inclusive designs, facilities can also go beyond the letter of the law to include accessibility features that offer benefits to all patrons.

For example, the Chicago Park District normally includes a pool lift as the primary means of entry at its older pools built before the ADA's introduction. "For new construction, the pools are at least going to have zero depth and the option for a pool lift and easy-access stairs," said Labiak. "And there could be cases where we would have all three means."

LaLonde's firm has been creating pools with zero-entry designs since the late '80s when they were first introduced to the market. At the time, the firm was surprised to learn just how popular the feature was with all pool visitors. "When we started doing those, we found that 80 percent of people wanted to be in three feet of water or less. And we'd find that a lot of people would literally just sit in six inches of water and enjoy being there with their children playing around them," he said. "Where you can do zero entry, I think it's an advantage."

Since sloped entries require so much additional space, they are practical only for larger pools. "But visually, it looks better," said Anderson. "And if you want to be inclusive and have everybody using the pool the same way, it's definitely more inclusive."

In selecting inclusive designs, facilities can also go beyond the letter of the law to include accessibility features that offer benefits to all patrons. As an example, LaLonde mentioned designs that incorporate a long step-in entry along the whole side of a pool that gets people into 2 feet of water rather quickly. "Parents love it—it gets them into about 2 feet of water in a very safe and comfortable manner," he said. "They can sit on the steps, play with their children. And the steps enable you to get to 2 feet of water in six to eight feet, as opposed to 40 feet with a zero entry."

Designs incorporating stairways that are smaller—yet still wider than normal stairs—can offer similar benefits. "A stairway is usually 3 or 4 feet wide and it becomes a very functional element that gets people in and out of the pool," said LaLonde. "But when you extend that up to 10 or 15 feet or more, it becomes a component that people don't only use functionally to get into the water, but also just enjoy."

Serving Physically Challenged Populations

Once you have an accessible aquatic facility, it's important to keep the adaptive equipment in good working order—and the facility welcoming to physically challenged patrons. For a pool lift, that means having your staff educated on its operation, checking it regularly and keeping battery-powered lifts charged.

Because having a lift may attract more people with disabilities, it can also draw more attention to other areas of your aquatic facility that are not up to code. "If someone comes to use the pool lift, they may find that the shower's not accessible, or there's not an accessible locker, or that the accessible parking out front is not properly striped," said Anderson. "There may be other things that weren't done right in the first place in terms of accessible features—and facilities should address those when they make the pool accessible."

These features also should be prioritized in the handling of maintenance requests. To do this successfully, the Chicago Park District purchased extra lifts so that if one fails, it can quickly be swapped out with another operational unit while it's being repaired. It also places repairs of things like accessible toilets and showers to the top of the queue, since disabled visitors won't be able to use the facility at all if these aren't operational.

Taking the next step to provide programming for disabled patrons can involve specific programs for these audiences, as well as accommodations to help them take part in mainstream offerings.

Another consideration is teaching your staff how to be sensitive to the needs of people with disabilities. At the Chicago Park District, disability awareness and accessibility training was one of the first steps the disability policy department took when making its facilities accessible. Training employees 50 people at a time, the district trained nearly all of its more than 2,000 full-time employees over a two-year period.

For those facilities unsure of how to get started in training their staff, Caden recommends reaching out to disability groups. "There are groups in any community who would be glad to send somebody in a wheelchair or someone who's disabled out to a facility to have a workshop with staff," he said.

While not comprehensive, this kind of training can at least ensure that when someone with physical limitations enters your facility, it's not the first disabled person your staff members have ever encountered.

Programming for Disabled Audiences

Once a pool is accessible, it's helpful to let people know by posting signage and advertising it on your website. Taking the next step to provide programming for disabled patrons can involve specific programs for these audiences, as well as accommodations to help them take part in mainstream offerings. "Our philosophy is, if you want to do it, and we don't have it, we will adapt it or find a way to adapt it to try to suit your needs," said the Chicago Park District's Labiak. "If you want to be in mainstream programming and you have a disability, we'll provide the support you need to be able to do that."

When creating special adaptive classes, the Chicago Park District typically pilots the programs at pools that have a zero-depth entry, according to Kristi Miller, senior program and event coordinator for special recreation at the district. A pool with only a portable lift isn't ideal for these classes because getting multiple people into and out of a pool with a lift can simply take too long. For this reason, the district also sometimes outfits its pool locations that have a lot of senior programming with easy-access stairs in addition to a pool lift to help patrons enter and exit the pool more quickly and independently.

When you look at the sheer numbers of people who can benefit from pool accessibility, it's anything but a niche audience.

Because of its size, the Chicago Park District has extensive special recreation programming of its own. But smaller park districts and organizations are more often able to provide programming for disabled customers by pooling resources with other neighboring facilities in the area.

Kenneth Rippetoe, executive director of One With the Water, a nonprofit that offers adaptive swimming instruction throughout the Los Angeles area, sees his organization get a lot of referrals from park districts and other facilities that are financially unable to provide these services themselves.

"The problem is staffing," he said. "You almost have to have one-on-one instruction, and occasionally two-on-one instruction, depending on the person's disability. A lot of it is being right there beside them and saying, hey, you're going to be OK when you try this; nothing's going to happen. And that's something that a lot of facilities aren't able to do if someone just comes to the facility to swim on their own."

Adaptive swimming coaches also have the knowledge to advise people with disabilities on how to swim in a way that compensates for their disability. "We can teach somebody without a leg, or who's paraplegic, how to rebalance their body in the water," said Rippetoe. "We can help them figure out the little tricks that allow them to swim efficiently given their disability."

Rippetoe suggests that facilities go to the U.S. Paralympics website to find some coaches registered in their area, and then do a financial analysis. "Most likely, they'll end up contracting adaptive swim lessons out at first, but as it grows and people become more aware of the opportunities they have with that audience, then hopefully they can eventually start offering classes through their own facility."

He also recommends veterans hospitals and physical therapy clinics as good places to inform people who might be interested in your adaptive programming. And for those with disabled swimmers who want to compete, Rippetoe recommends U.S. Masters Swimming events where they can compete against able-bodied swimmers. It's something he's done on many occasions with his own swimmers because there aren't many Paralympics competition opportunities.

"The able-bodied swim meets for the masters swimmers have no problem bringing forth a ramp for someone to get into the pool if needed. They make all the accommodations necessary," he said. "They're very welcoming and they love it."

Making Differences Float Away

When you look at the sheer numbers of people who can benefit from pool accessibility, it's anything but a niche audience. Caden estimates that 18 percent of Americans are disabled and that when you also consider seniors, between 25 and 30 percent of the population could benefit from an accessible pool. "If you're a parks and rec department and you're owned by taxpayers, that's a pretty large minority group that you'll want to accommodate," he said.

Moreover, these are the populations that can most benefit from the therapeutic effects of water. Aquatic aerobics are hugely popular with seniors, and pools give them a way to exercise with less joint pain and without worries of breaking a hip. Others with physical limitations can likewise often find relief in the gravity-defying effects of water. "I work with a lot of people with back problems, and they tell me that being in the water swimming is the only time they don't feel pain," said Rippetoe. "Water therapy is just incredible for people."

Other water sports can also effectively diminish the differences between the able-bodied and those with physical limitations. As examples, the Chicago Park District's programming includes adaptive scuba classes, as well as a partnership with the Judd Goldman Adaptive Sailing Foundation that helps more than 1,000 participants experience the joy and independence of sailing each year.

The district has additionally built accessible rowing sites for its growing adaptive rowing program. "If you have a lower-extremity disability, but normal upper-body function, the beauty of being in a kayak is that once you're in, there's no disability," said Labiak. "It levels the waterway for all."

Likewise, the accessible beach walks at 16 of the city's 31 beaches along Lake Michigan also enhance inclusion, while providing tangible benefits to other park visitors. "Guys with coolers who want to get through 400 feet of sand use them, and so do moms with strollers," said Labiak. "So we like to think that if it's a benefit to someone with a disability, it's a benefit to someone else, as well."

And with the nation's 79 million baby boomers poised to turn 65 in the coming years, aquatic accessibility features of all kinds are likely to become even more integral to serving customers over time. "Many of these individuals will become the very people who are primary users of this kind of equipment," said Labiak. "For me, the bottom line is, don't be afraid of the ADA. Don't balk at providing access. Embrace it. Because everybody benefits if we comply."



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