ADA Final Guidelines for Swimming Pools, Wading Pools and Spas and Related Components

Has anyone done research on what facilities are and are not required to comply with these regulations?

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Hi Louis,


If I am not mistaken, there were no stipulations for amusement parks in the 1991 standards. If these attractions were addressed in 2010, then you must react accordingly. For more information on this, you should contact the DOJ, or search the website.


However, one thing to consider for this, and also for your rooftop golf attraction, is that you are only compelled to provide accessibility to existing facilities if doing so is readily achievable. Depending on the size and revenue generated by your facility, you may be able to make the case that installing either an elevator or platform lift is prohibitively expensive and, therefore, not readily achievable.


Hope this helps,


John Caden

Thank you John. 

I have a Question

What about a wading pools that is 12 ft. dia by 12” deep on outside edge and 18” deep center.

A 12/1 ratio would require a ramp 18 ft long. What is the solution?

Is there some exemption for smaller wading pools?

If this addressed in the law could you point out where please?


John Szymanski

Minnesota John

Alden Pool Co.

Hi John,


There is actually no exemption for existing wading pools. However, keep in mind that barrier removal is only required if it is readily achievable. This means, able to be easily accomplished without much difficulty or expense. The cost to install a safe sloped entry into an existing wading pool with a flat bottom would likely equal the original cost of the pool. This would not be considered to be readily achievable. In this case, the wading pool would not need to be modified until a major renovation were to take place.


If the facility you described decided to bite the bullet and install a sloped entry into their pool anyway, they would need to comply with the Standards to the fullest extent possible. In other words, where there is not enough space to install a ramp with a slope that complies with the Standards, the facility may install a ramp with a slightly steeper slope. However, any deviation from the Standards must not pose a significant safety risk. In the case of your wading pool, this would not create any safety risk, so the steeper slope would be permitted.


The Department of Justice recently released a valuable publication called "A Primer for Small Business" which addresses many of these types of issues. Here is a link to that publication.


Hope this helps.


Best regards,


John Caden

SR Smith


The term "readily available" is in the ADA supplement for small buisness.  I don't think most pools would be included with that. Do you see this somewhere else?

Hi John,


The "Readily Achievable" provision is described in the Specific Requirements section of Title III (III 4.4200). This area affects any barrier removal provision, including pools. 


The existing wading pool situation is a classic case of barrier removal not being readily achievable. This is unlike a swimming pool where, given the relative low cost of a pool lift, it would be difficult to say that this type of barrier removal is not readily achievable.


Hope this helps,




John Caden

SR Smith

Bill  or Peggy Greenwell. 800-872-2253

also there are several webinars on: then click on archive

Also if you are a title 3 facility then you are required to remove those barriers that are readily achievable & easy to accomplish without much difficulty or expense.  You do have a legal obligation to remove barriers.  This can be phased in as a title 3 facility.


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