The ADA regulations currently contain no technical specifications for accessible hotel guest room beds.   According to The U.S. Department of Justice (DOJ), travelers with mobility disabilities often complain that beds in many lodging facilities are too high for a transfer to and from a wheelchair.  Other travelers with mobility disabilities have complained that the use of platform beds prevents them from using portable lifts because such lifts require space under the bed. 

In response to these complaints, DOJ stated in 2010 its intention to issue a proposed rule that would regulate beds in mobility-accessible guest rooms in lodging facilities.  The DOJ recently pushed back the date for this proposed rule until July 2014. 

This delay is a bit of a reprieve for the lodging industry, which expressed its concerns about the forthcoming bed regulation in comments it filed in response to the 2010 Advanced Notice of Proposed Rulemaking.  If the DOJ adopts the same height standard for beds as it has for benches and toilet seats (17”-19” above the floor), beds in accessible rooms will be much lower than they are now and travelers without disabilities assigned to these rooms will be even more dissatisfied.  Hotels already receive many complaints from non-disabled guests about being assigned accessible rooms with grab bars and roll-in showers when there are no non-accessible guest room options left.  There is a real economic impact to this possibility:  Hotels must sometimes offer complimentary amenities to non-disabled guests who are unhappy with their accessible room assignments.    

Lowering bed heights will create another problem if the DOJ also tries to provide under-bed clearance for portable lifts.  California law requires 9” of clear height under beds in accessible guestrooms for this purpose but does not limit the height of the bed.  If the DOJ imposes a 9” under bed clearance requirement and a 19” bed height requirement, the combined height of the mattress and box spring could not be more than 10”.    This leaves little room for a premium mattress and box spring.

It will be interesting to see how DOJ deals with these issues if and when it does issue a proposed rule.  In the meantime, lodging facilities should consider these issues when purchasing new bed foundations, mattresses, and box springs.  Beds on frames instead of platforms are much easier to lower (i.e., the frame can be removed) if a guest with a mobility disability asks for the bed to be lowered to a transferable height.  (Frames instead of platforms are also advisable in states, such as CA, which require space under the bed for a lift.)  It may be possible to purchase high quality mattresses with detachable pillow tops that can be removed to make the bed lower.  A hotel that is proactive about this issue will have happier guests with disabilities and potentially less to change when the regulations do come out.