Beds in Accessible Sleeping Rooms

Introduction

The ADA already requires beds that are usable by people with disabilities in accessible sleeping rooms through, at a minimum, its general non-discrimination requirements. Public and private entities that offer sleeping rooms are required to engage in a considered process to provide usable beds. The comments below are the provisions, reasons, and analysis we propose about how to regulate this existing requirement.

16 (a). Should the Department develop a general standard that specifies requirements for beds wherever accessible sleeping accommodations are required?

We strongly support specific DOJ requirements for accessible beds. Beds that are too high have been a significant barrier for travelers with disabilities.

According to a JD Powers customer satisfaction survey that was conducted several years ago, one of the "must haves" in a lodging experience was a comfortable bed. In its eagerness to meet their customer's desires, the lodging industry responded to this survey by installing new beds, and in some cases worked with bed manufacturers to develop their own branded premium beds. These new beds, ranging in heights from 25"-30", are notably higher than the beds previously found in hotels, and in countless instances pose a significant barrier to people with mobility disabilities, including people with paralysis, polio, cerebral palsy, short stature and other disabilities. Due to the increased heights of these beds, rooms that were once considered accessible have become inaccessible. People who rely solely on their arms to transfer into bed may not have the strength to lift their entire body to the top of these mattresses. People with short stature have a limited height they can jump to access a bed. People with restricted movement in their joints may not have the flexibility to lift their legs onto a high bed. This bed height problem has become pervasive across the spectrum of lodging categories, from high-end luxury properties to budget properties. It is not uncommon that people with disabilities need to call multiple properties before they find one that will work for them. In some cases, they must travel with someone who can assist them into bed, or must even cancel their trip altogether.

As our population ages and as more people lose their mobility, it is imperative that the DOJ respond to this issue of increased bed heights.

16 (b). What are appropriate bed heights to ensure accessibility by individuals with mobility disabilities and should there be requirements for mattresses to ensure that the height of the mattress, even when compressed by the weight of a person sitting or laying down on it, remains within a certain range? Are there existing standards that the Department should look to for developing standards for beds in accessible rooms?

The typical seat height of a wheelchair is 19" above the floor, a dimension that was published in the ADA Accessibility Guidelines in 1991,[1] and which can still be seen today in the common 19" to 20" seat height of popular models of wheelchairs.[2] Consequently, a bed that is substantially higher than 20 inches presents a problem for most wheelchair users.

We recommend as follows:

Franchise Systems Inc., a leader in the lodging industry for marketing to travelers with disabilities, recognized early on that their implementation of a new bed initiative might cause problems for people with limited mobility.  "We recognize the importance of comfort for all of our guests so we had to find a bed that would not compromise comfort for access," says Roy. E. Flora, EVP & COO, U.S. Franchise Systems, Inc.

Working with bed manufacturers Sealy, Serta, and Simmons, Franchise Systems was able to design a low-profile box spring (5 1/2") that offers both a high level of comfort while maintaining accessibility for people with mobility limitations. The California building code also requires at least a 7" vertical clearance under the bed for lift access. Franchise Systems was able to achieve that standard as well and still have their beds measure no higher than 23-inches.

Some Hyatt Hotels report intentionally limiting the height of beds in their accessible guest rooms to 19 inches high.[3]

A safe and usable bed height of approximately 21" can be achieved with standard brand stock products, without the need for customized sizes, and still use today's popular thicker mattresses. For example:

16 (c). What is the optimal clearance needed under a bed to accommodate a mechanical lift?

Clearance Under The Bed

We recommend that DOJ adopt a provision that is consistent with California's Title 24 accessibility requirements. Title 24 has a requirement for a seven-inch clearance under the bed. It is based on data gathered by Access Compliance Services in 2000 and updated in December 2010.[7]

Many beds are placed on stationary platforms (AKA stationary box frames). These stationary platforms not only limit access for lifts, they make it impossible to move the bed in any direction if someone should need to move it to create an accessible pathway to either side of the bed (often there isn't the required 36-inch clear width maneuvering space along both sides of a bed). Therefore, we suggest that along with a required clearance underneath, that the bed be required to be moveable.

Maneuvering To The Bed

Operating a lifting device requires adequate space to steer the lift to a position alongside and parallel to the bed, as well as space to then turn the lift 90-degrees so that it is perpendicular to the bed with its support legs underneath the bed.  Since the longest lifts are approximately the same 48-inch length as the ADA standards designate for a wheelchair space, applying maneuvering space requirements for wheelchairs would ensure adequate space for using a lift. For example, the original ADAAG at Section 9.2.2(1) already requires a 36-inch wide space alongside of the beds in transient lodging, as does the 2010 ADA standards at Section 806.2.3. And, both versions of the ADA standards require that in order to navigate a 90-degree turn, both legs of the turn must be 36-inches wide (See original standards at Section 4.3.3, and the 2010 standards at Section 403.5.1). Consequently, adequate space for using a lift could be provided by a 36-inch wide accessible route to alongside a bed or between two beds, that connects to a space under the bed that is 36-inch wide and at least 7-inches high. Requiring that the 7-inch high under-bed clearance to extend 30-inches deep would ensure that the mast of the lift could be brought all the way to the bed for safely picking up or placing an individual. Providing such an under-bed space that extends 30-inches deep can be achieved without conflicting with the common hotel practice of installing a mid-span support under wider beds, since the narrowest beds for which such support would be needed are 60-inch wide queen-size models. (Also see last endnote which includes related California code provision.)

16 (d). Should any such requirements apply to all accessible guestrooms or sleeping rooms or only to a percentage of them?

Requiring all guestrooms to have the same bed height ignores the diverse needs of people with disabilities and people who are elderly. People that require someone to assist them into a bed often prefer a higher bed to minimize back strain for the assistant whereas people with llimited mobility who aren't using outside assistance generally need a lower bed, per the specifications given above. Having the ability to safely and easily adjust the bed to individual requirements is the ideal; however, an alternative would be to offer a majority of rooms with low beds (21 to 24 inches, per above), and the remaining ones with unregulated beds which would be allowed to be the same as in non-accessible guest and sleeping rooms (i.e. higher). The majority of the accessible guestrooms or sleeping rooms should meet the lower standard, since bed heights were not a widespread problem prior to the newer, taller beds. If there is only one accessible room, it should be required to have a lower bed at 20 inches to 23 inches high.

16 (e). What time line should the Department establish for requiring accessible beds in accessible guest rooms and sleeping rooms and should such a time line be phased in?

The lodging industry should have no more than one year to comply with any new bed height standards.

CONCLUSION REGARDING TIMING OF THE REGULATION

Every subject area in this ANPRM is of vital importance to the disability community across the United States. We urge the Department to move ahead with each area of rulemaking independently as it is able, and not allow time delays in one area to hold up rulemaking on the other issues raised in this ANPRM, and in all of the ANPRMs issued by the Department in July 2010.



[1] 19-inch wheelchair seat height from original ADA standards

Figure A3  (28 CFR, Part 36, Appendix A)

[2] 19-inch wheelchair front-edge seat height of popular wheelchair models

The low (L) and high (H) dimensions reflect choices of wheel sizes.

Manual Chairs

Invacare Top End Crossfire          (L) 16"            (H) 21"

Invacare Tracer EX2            (L) 17-1/2"     (H) 29-1/2"

Quickie Breezy Ultra 4        (L) 18"            (H) 18"

Nova Transport chair (all 11 models)     (L) 19"                        (H) 20"

Nova steel wheelchair (all 7 models)     (L) 20"                        (H) 20"

Nova lightweight chair (all 3 models)      (l) 20-1/2"      (H) 20-1/2

Power Chairs

Pride Q600   (L) 16-3/4"     (H) 17-3/8"

Pride Jazzy 600        (L) 17"                        (H) 20"

Invacare 3G Torque            (L) 17-1/2"     (H) 21"          

[3] Personal communication with Bonnie Lewkowicz, Access Northern California, December 8, 2010

[4] Two leading manufacturers, Leggett & Platt, and Hollywood Bed & Spring, provide standard metal bed frames for all sizes that stand 7" to 7-1/2" high, depending on the choice of floor glides, casters, or rug rollers. See more on bed frames in section on portable lifts.

[5] Mattresses can be supported by a low-profile box spring, which is also called a palette board. The standard of the industry across various brands is 1-3/4" thick. Also see products such as the Bunkie Board at www.havertys.com/Product_22503?curIndex=1&resultCount=41.

[6] An 8-inch thick mattress was common ten years ago. Today's trend is toward thicker mattresses that are commonly 10" to 14" thick, but can be as thick as 18-inch.  Among the popular brands, 12-inch thick mattresses are available that include popular features such as non-flip, pillow-top, and latex foam.

Sealy Monogram 400 Plush

2-inch Supersoft Sealyfoam

11-1/2 inch mattress height

Sealy Hotel Executive Limited - Plush

1 oz. Sealy Fiber, 2" Sealyfoam

12-1/2 inch mattress height

Sealy Posturepedic

Alford Cushion Firm-Innerspring Core

12-inch mattress height

Serta Perfect Sleeper

Gold Suite Pillow Top

12-1/2 inch mattress height

Serta Perfect Sleeper

Diamond Suite Plush

11-1/2 inch mattress height

Englander Indulgence

All Foam Mattress

12-inch mattress height

[7] Observations of nine models of lifts (see below) show that most personal lifting devices need 5.5 inches or less of vertical clearance under the bed, while a few that use larger wheels for greater ease of maneuvering on carpet, need 6.5 inches of clearance. The most common metal bed frames provide 7 to 7.5 inches of clearance under the bed, depending on whether they are outfitted with floor glides, casters or rug rollers. That is sufficient clearance for the front legs of even the highest lifting devices.

For example, two leading manufacturers, Leggett & Platt and Hollywood Bed & Spring, provide standard metal bed frames for all sizes that stand 7 inches to 7.5 inches high, depending on the choice of floor glides, casters or rug rollers. While a lower frame could be acquired, the standard 7-inch high models, of which there are many choices, will accommodate the 4-1/2 inch high front forks the common Hoyer Advance portable personal lifting device (www.joerns.com/lifting-repositioning/advance) as well as other lift models. This would allow meeting the requirements of future USDOJ standards and would ensure meeting the current California building code requirement for a clear height of 7 inches under the bed (Section 1111B.4.3):

(2010 CBC) 1111B.4.3 Access to beds. Accessible sleeping rooms shall have a 36-inch (914 mm) clear width maneuvering space located along both sides of a bed, except that where two beds are provided, this requirement can be met by providing a 36-inch-wide (914 mm) maneuvering space located between the beds. In addition, there shall be a clear space under the bed for the use of a personal lift device. The clear space shall be on a long side of the bed adjacent to an accessible aisle. The clear space shall extend horizontally to points not more than 12 inches (305 mm) from each end of the bed, vertically not less than 7 inches (178 mm), and not less than 30 inches (762 mm) deep.

Note: This 12 horizontal inches is a restrictive provision that could be larger to allow for a deeper bedside table.

Lift data:

This lift data was compiled as of December 20, 2010 by Access Compliance Services (http://www.accesscomplianceservices.net/):

PERSONAL LIFTS – 2010 DATA

Invacare 9805P

Vertical clearance needed under the bed: 6.5 inches

Invacare Get-U-Up Hydraulic GHS350

Vertical clearance needed under the bed: 4.5 inches

Invacare Reliant RHL-450 w/low base

Vertical clearance needed under the bed: 4.5 inches

Hoyer Hoy-Advance-H

Vertical clearance needed under the bed: 5.5 inches

Hoyer Classic C-HLA

Vertical clearance needed under the bed: 5.5 inches

Hoyer Hydraulic HML400

Vertical clearance needed under the bed: 5.5 inches

Drive Medical Hydraulic Lift 13010 SV

Vertical clearance needed under the bed: 5.5 inches

Apex Genesis 400 DPL 400H

Vertical clearance needed under the bed: 4 inches

ProBasics LIFT

Vertical clearance needed under the bed: 6.5 inches

Resources:

Hoyer Personal Lift

Ted Hoyer & Company

2222 Minnesota St.

Oshkosh, WI

414-236-3460

800-255-5022

800-211-6522 (tech support)

Quickie Designs Inc.

Sunrise Medical

2842 Business Park

Fresno, CA 93727

209-292-7412 (fax)

800-456-8168

888-739-6059 (tech. support)

Invacare Corporation

899 Cleveland St.

Elyria, OH  44036-2125

800 333-6900