Cold Plunge Tubs: Breaking the Ice on Accessible Design

Cold plunge tubs are growing in popularity as part of both workout regimes and spa therapies, they are common to see at commercial gym facilities but now they are even popping up as tenant amenities in residential projects.

Whether they are built-in cold plunge tubs or self-contained stand alone models, the accessibility requirements for both types are the same. So let's go over the accessibility requirements and some other factors that could affect their installation at hotels, commercial facilities (gyms, spas, clinics), and at multifamily residential projects. The information discussed below does not pertain to cold plunge tubs installed at single family residences.

Apply the 5% scoping requirement found in the code either ICC ANSI A117.1-2009, Section 1109.1.3 (for residential) or 2010 ADA Standards, Section 242.4 (for hotels or commercial facilities). Where spas are provided in a cluster 5 percent but not less than one spa in each cluster shall be accessible. If cold plunge tubs are being separated by different types of features or by gender, then 5 percent of each type and gender would have to be accessible.

If the guest or public has access to the controls, then those controls are required to be within an accessible reach range from an adjacent 30” x 48” clear floor space. Controls would also have to be operable with one hand without the need for tight grasping, pinching, or twisting of the wrist to operate; which means knob style controls are not acceptable.

If controls are only to be used by staff, then controls do not have to be accessible. But in this case, MAPS does suggest providing signage clearly stating who is permitted to operate the controls.

A 30” x 48” clear floor space on an accessible 36” wide route needs to be provided adjacent to the cold plunge tub (parallel to the tub's long axis) so that someone in a wheelchair or mobility device can approach and position themselves next to the tub for entry.

Grab bars are not required since these are not tubs used as a bathing fixture. However MAPS would still recommend providing some grab bars in order to help facilitate people getting in and out of the water.

Removable or permanent tub seats are not required at cold plunge tubs since these are not tubs used as bathing fixtures.

Are the cold plunge tubs located at publicly funded residential, a hotel / resort, or a commercial business (spa, bathhouse, gym) or any other place open to the general public?

If you answer yes to any of these, you will need to provide an accessible means of entry into the cold plunge tub at initial occupancy. The 2010 ADA Standards apply and they require either a pool lift per Section 1009.2, transfer walls per Section 1009.4, or a transfer system per Section 1009.5.

What if the cold plunge tubs are an amenity provided at privately funded residential? Well in this case the answer is not a simple yes or no, but one that will vary based on your project's location. Normally you would refer to IBC for scoping which requires that swimming pools, hot tubs, and spas be provided on an accessible route; but it contains an exception when they are serving Type A & B dwelling units. This exception states that you are not required to provide an accessible means of entry into the water. (IBC 2018, Section 1110.4.14, Exception 3)

Whether or not you need to provide a pool lift or other accessible means of entry at your cold plunge tub -in privately funded residential- is determined by the city & state swimming / spa codes applicable to your project's location.

It’s not surprising to see why self-contained cold plunge tubs are a popular choice over built-in versions, they are relatively easy to install and have no special construction requirements other than providing a nearby plumbing connection and an outlet.

However before specifying the self-contained tubs on a project, we strongly advise checking with your city or state health department. The self contained models will typically lack the ability to meet the water conditioning and filtering requirements set by numerous health departments across the country.

Take for example the state of Illinois; the self contained models are not legal to install since they don't meet Sections 820.200 and 820.210 of the state Swimming Facility Code, which includes items like water conditioning, filtering, and ‘minimum’ water temperature.

At Illinois indoor spas a minimum water temperature of 60° F is allowed only when the tubs are supervised by a licensed physical therapist / physician and a variance is granted; otherwise the water temperature is not allowed to go below 76° F. 

If these accessibility items are taken into consideration early in the design process, a lot of legal risk and design issues can be avoided later. If there's questions or comments about anything discussed feel free to contact us.

Did you know that MAPS offers accessibility presentations on various topics, interested in having us present to your company or group? Let us know.