Skip to content


Return to Blog »

The Existing Swimming Pool Dilemma

The new 2010 ADAS has caused much confusion with swimming pool access for facility people and building owners in existing facilities. Although it has been in the Guidelines since 2004 the confusion appears to stem from what is considered Readily Achievable for this specific element for places of public accommodation. The Department of Justice (DOJ) has delayed the required implementation date from March 15, 2012 until May 21, 2012 and is considering further delay until mid-September.*

Small pools with less than 300 linear feet around the circumference are required to have one means of access which is either a pool lift or a sloped entry. Large pools of 300 linear feet or more are required to have two means of entry. In most cases providing a sloped entry into an existing pool is quite difficult so access would in most cases then be required to be by a lift.

So what do you do?

  • You would provide a fixed lift for each pool. If this is not Readily Achievable then;
  • You would use a non-fixed lift that otherwise complies, which is physically attached to the pool decking. If this is not Readily Achievable then;
  • You would use a portable lift that is not attached but is secure. If this is not Readily Achievable then;
  • You would use another means of entry to the pool whether stairs, ramps, or transfer systems.

Definitions of fixed versus non-fixed have also caused some confusion. A non-fixed lift means it is not attached to the decking. A fixed lift is physically attached to the decking, and it can be a portable lift which is physically attached.

Since this is a new requirement for pool entry there is no Safe Harbor. The California Building Codes (CBC) has requirements on pool lifts which differs from the ADAS requirements and in many respects is less stringent. Remember, what may not be Readily Achievable this year might be next year. New products come on the market which can solve installation problems and make it Readily Achievable for the specific condition. What you can not do, is ignore this requirement.

* As of 5/18/2012 DOJ has extended the required implementation date for existing swimming pools, wading pools, and spas until January 31, 2013


Be aware that your local City or County may have additional requirements that are more restrictive than the State or Federal requirements. Also, this article is an interpretation and opinion of the writer. It is meant as a summary – current original regulations should always be reviewed when making any decisions.

© Janis Kent, Architect, CASp 2012