There are no specific design, construction, or alterations requirements that apply to covered employers, although many entities are covered both as employers and as public accommodations, commercial facilities, or state/local government agencies, and therefore have separate obligations under Title II or Title III in relation to facility access.

However, the duty to provide reasonable accommodations to qualified applicants and employees may require an employer to make structural modifications in the workplace. Reasonable accommodations are approached in an individualized fashion, though. Rather than merely following standards, an employer may need to modify, in a manner that meets a particular worker’s needs, only those structural elements that present problems for that worker. For example, minimum accessibility standards require a clear width of 32 inches at accessible doors, but an individual worker who uses a larger mobility device may need 34 inches of clear width to get through doors. As long as it is not an undue hardship, an employer may need to widen to 34 inches a number of doors throughout the workplace (the individual’s office, the restroom, the conference room, the employee break room, etc.) to enable the individual to work and gain access to related common spaces.