ADA assistive listening rules and where Auracast fits

Who the Standards apply to

The 2010 Standards set minimum requirements for "newly designed and constructed or altered" state and local government facilities, public accommodations and commercial facilities. The Department of Justice also uses them as the reference point when existing facilities make structural changes to provide access. Which rules apply to your building, and from when, is a question for your adviser.

Where a system is required

Section 219.2: "In each assembly area where audible communication is integral to the use of the space, an assistive listening system shall be provided." The Standards' definition of an assembly area lists, among others, "classrooms, lecture halls, courtrooms, public meeting rooms", theaters, concert halls, arenas, stadiums and convention centers.

The exception: "Other than in courtrooms, assistive listening systems shall not be required where audio amplification is not provided." A courtroom needs one either way.

How many receivers

Section 219.3 requires receivers in each assembly area according to Table 219.3, and adds: "Twenty-five percent minimum of receivers provided, but no fewer than two, shall be hearing-aid compatible."

Part of a step counts as a whole one ("or fraction thereof" in the Standards). The table counts seats, not expected attendance.

Worked examples (our arithmetic):

• 120 seats: 2 + 3 = 5 receivers, 2 of them hearing-aid compatible.
• 300 seats: 2 + 10 = 12 receivers, 3 of them hearing-aid compatible.
• 800 seats: 20 + 10 = 30 receivers, 8 of them hearing-aid compatible.

Two exceptions

1. Shared pool. Where a building has several assembly areas "under one management", the receivers may be calculated on the total seats, "provided that all receivers are usable with all systems."
2. Full induction loop. "Where all seats in an assembly area are served by an induction loop assistive listening system", the hearing-aid-compatible receivers are not required. This exception names induction loops only, so an Auracast system on its own does not qualify for it.

What the receivers must do (§706)

• 706.2: "a 1/8 inch (3.2 mm) standard mono jack".
• 706.3: hearing-aid-compatible receivers "shall interface with telecoils in hearing aids through the provision of neckloops." The advisory note adds that earbuds are not hearing-aid compatible.
• 706.4: the system must be "capable of providing a sound pressure level of 110 dB minimum and 118 dB maximum with a dynamic range on the volume control of 50 dB."
• 706.5: signal-to-noise ratio for internally generated noise of "18 dB minimum".
• 706.6: peak clipping no more than 18 dB relative to the peaks of speech.

These are properties of the receivers and the system. Ask for them on the datasheet.

Signs (§216.10)

"Each assembly area required by 219 to provide assistive listening systems shall provide signs informing patrons of the availability of the assistive listening system." The signs include the International Symbol of Access for Hearing Loss.

Religious organizations

Title III of the ADA "shall not apply to ... religious organizations or entities controlled by religious organizations, including places of worship" (42 U.S.C. 12187).

That exemption is in the ADA, not in building codes. The International Building Code contains its own assistive listening requirement with the same receiver table. The U.S. Access Board's ADA-IBC comparison shows the two side by side; it compares an older IBC edition, so check the one your jurisdiction uses. Where a building code like this has been adopted, new construction and alterations of a place of worship can still require assistive listening. Ask your building official which code and amendments apply.

Where Auracast fits

The 2010 Standards do not require a particular technology. They define an assistive listening system as one that works "by means of induction loop, radio frequency, infrared, or direct-wired equipment." The advisory note describes induction loop, infrared and FM systems. Bluetooth is not mentioned, which is no surprise in a text from 2010.

What the organizations involved say:

• The Bluetooth SIG says Auracast "is fully recognized as a compliant ALS technology under the ADA." That is the SIG's own position, not a ruling by a regulator.
• HLAA says venues can meet their ADA obligations with many technologies, including Auracast, and that the key question is whether the deployment "meets the ADA's legal and technical standards."
• The Center for Hearing Access: "It is too soon to say if each installation can meet the ADA", partly because the international standards are not expected until late 2027.

Read the text and an Auracast installation still needs the receiver count from Table 219.3, neckloops for a quarter of them, receivers that meet §706, and signs under §216.10. The Standards do not mention visitors' own phones or hearing aids, so plan the receivers in full and treat personal devices as an extra. Our guide to how listeners join Auracast covers phones, hearing aids and loan receivers, and our comparison with loops, FM and infrared explains why many venues keep a loop as well.

A checklist for a US venue

From the text of the Standards:

• Each assembly area with amplification (and every courtroom) has assistive listening.
• Receivers per Table 219.3, sized on seating capacity.
• A quarter of them, at least two, with neckloops.
• Receivers with the 1/8 inch (3.2 mm) mono jack of §706.2, and §706 performance on the datasheet.
• Signs with the International Symbol of Access for Hearing Loss.

Good practice on top (our advice, not a requirement in the text):

• Reception checked at the seats, with the room in use.
• Staff who know where the receivers are, and keep them charged.

Common questions

Do visitors' own phones count toward the receiver number?

The Standards do not say they do. Table 219.3 sets a minimum number of receivers to provide, and §706 describes those receivers. Plan the full count.

We are a church. Do we need to do any of this?

The ADA's Title III does not apply to religious organizations. A local building code may still require assistive listening for new work. Check with your building official.

Do we need assistive listening if we have no sound system?

Outside courtrooms, the ADA does not require it where audio amplification is not provided.