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§242 / §1009

Swimming Pool Accessibility

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Which Pools Are Covered?

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Public swimming pools must be accessible. This includes pools at hotels, parks, gyms, and apartment complexes.

Private pools at houses are not covered, but shared pools at condo buildings are.

All public and commercial swimming pools, wading pools, and spas are covered — including:

  • Hotel and resort pools
  • Community and municipal pools
  • Water parks and splash pads
  • Health clubs and fitness centers
  • Apartment complex pools (common areas)

The requirements apply to new construction AND existing facilities. Existing facilities must remove barriers where readily achievable. The DOJ issued specific guidance in 2012 confirming these obligations.

Official Standard

§242 — Swimming Pools, Wading Pools & Spas

"Where swimming pools, wading pools, or spas are provided, accessible means of entry shall be provided." Applies to Title II (government) and Title III (public accommodations) facilities.

Means of Entry — Large Pools

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Large pools (over 300 feet around) must have two ways to enter the water:

  • A pool lift or sloped entry (primary)
  • A second lift, sloped entry, or transfer wall (secondary)

Pools with over 300 linear feet of pool wall must have two accessible means of entry:

  • At least one must be a pool lift or sloped entry
  • The second can be a pool lift, sloped entry, transfer wall, transfer system, or accessible pool stairs

Official Standard

§242.2 — Swimming Pools

"Where a swimming pool has over 300 linear feet of swimming pool wall, at least two accessible means of entry shall be provided. At least one accessible means of entry shall comply with §1009.2 (Sloped Entries) or §1009.3 (Pool Lifts)."

Means of Entry — Small Pools

Pools with 300 linear feet of pool wall or less must have one accessible means of entry:

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Small pools (300 feet around or less) need at least one accessible way to enter.

This can be a pool lift, a sloped entry, or a transfer wall.

  • Must be a pool lift or sloped entry

How to Measure

Measure the total perimeter of the pool wall at the water line. A standard 25-yard lap pool (75 ft × 42 ft) has about 234 linear feet — so it would need one accessible entry. An Olympic-size pool (164 ft × 82 ft) has about 492 linear feet — so it needs two.

Pool Lifts

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A pool lift is a seat that lowers you into the water. ADA pool lifts must:

  • Be able to hold at least 300 pounds
  • Lower the seat to at least 18 inches below the water
  • Have a footrest and armrests
  • Be operable by the person using it
  • Must be fixed/permanent — portable lifts do not comply
  • Seat must be at least 16 inches wide
  • Footrest must be provided
  • Must be operable without an attendant — from both deck and water levels
  • Must lower to at least 18 inches below the water surface
  • Must be located where water depth does not exceed 48 inches
  • Must support a minimum weight of 300 pounds

Official Standard

§1009.2 — Pool Lifts

"Pool lift seats shall be 16 inches wide minimum. The deck-to-seat height shall be 16 inches minimum and 19 inches maximum." "Pool lifts shall be capable of unassisted operation from both the deck and water levels."

Sloped Entries

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A sloped entry is a ramp going into the water. It must:

  • Be no steeper than 1:12 (one inch of rise for every 12 inches of length)
  • Be at least 36 inches wide
  • Have handrails on both sides
  • Must comply with §405 ramp requirements (1:12 slope max, handrails)
  • Must extend to a depth of 24–30 inches
  • Width: 36 inches minimum between handrails
  • Handrails on both sides extending the full length

Official Standard

§1009.3 — Sloped Entries

"Sloped entries shall comply with §405 (Ramps) except as modified. The sloped entry shall extend to a depth of 24 inches minimum and 30 inches maximum below the stationary water level."

Wading Pools & Spas

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Wading pools must have a sloped entry into the water.

Spas (hot tubs) must have a pool lift, a transfer wall, or an accessible seat.

Transfer walls must be 16 to 19 inches above the deck.

  • Wading pools: Must have a sloped entry into the deepest part
  • Spas: Must have at least one accessible means of entry — a pool lift, transfer wall, or transfer system
  • Spa means of entry is NOT required to be a lift — transfer walls and transfer systems are acceptable

Official Standard

§242.3 & §242.4

"At least one accessible means of entry shall be provided for wading pools." "At least one accessible means of entry shall be provided for spas." Spa entry may be a lift, transfer wall, or transfer system.

Existing Pool Obligations

For existing pools at hotels, health clubs, and other Title III entities:

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Pools that already exist must still follow the ADA. Owners must add a pool lift or other accessible entry if possible.

The change must be made unless it is too expensive or too difficult. This is called the readily achievable standard.

  • Must remove barriers where "readily achievable"
  • If a permanent lift is not readily achievable, a portable lift may be acceptable temporarily
  • The DOJ has stated that at minimum, entities must evaluate whether a lift is readily achievable
  • Cost of a pool lift (typically $3,000–$5,000) is generally considered readily achievable for most commercial facilities

DOJ Guidance (2012)

"The Department expects that the vast majority of public accommodations that own or operate swimming pools will be able to comply with the accessible means-of-entry requirements by providing a fixed pool lift." Entities that cannot must document why a lift is not readily achievable.

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