Public Accomodation
jbnunzio
26 Posts
We are a non-profit credit union who recently merged with a small credit union and acquired a branch that does not have access for those that are disabled. (No ramps or rails, just steps) Our main office is located less than 7 miles from our branch location. (Main office offers all if not more services than the branch). My question is: must we make changes to the branch location now or only if we choose to remodel at some point?
Comments
While I have a working knowlege with Title I issues (employment) of ADA, Title III accommoations do occasionally come up, especially in regard to facilities. My understanding of Title III is that you do not necessarily have to modify your entrance JUST for the access. If and when you do make changes to a facility for any rason, that's when you would need to make the facility accessible for disabled individuals who can not climb stairs.
You should take a look at the Department of Justitce regulations at the DOJ website, which has responsiblity for Titles II and III, of ADA (just as EEOC has responsibility for Title I). The regulations address the ADA Accessibility Guildines for Buildings and Facilities.
Besides making facility changes to accommodate the disabled, you could change your practices and policies to accommodate them and thus remove the barrier that building modification would do otherwise.
What you may want to do is to discuss with the client various options and see what is mutually agreeable. While you could say "our services are accessible to you in our other office and therefore we consider that sufficient," you would probably be considered to be unreasonable since the other office is 7 miles away. But maybe the client is willing to use the other office if transportation were arranged. So, like Title I reasonable accommodations, it may take coming to agreement with the client to implement something short of altering the entrance.