Our church is sponsoring a seminar that is open to non-church members. An attendee is sensitive to perfumes, lotions, etc. and has asked that we request that all attendees not wear any chemicals or fragrances. Do we have to do this?

Our church is sponsoring a seminar that is open to non-church members, and attendees must purchase a ticket. An attendee is sensitive to perfumes, lotions, after shave, etc. and has asked that we request that all attendees not wear any chemicals or fragrances. Do we have to do this?

  • Is the church-sponsored seminar exempt from the ADA’s title III requirements for places of public accommodation?

Religious organizations, such as churches, are exempt from the ADA's title III requirements for places of public accommodation.  This exemption covers all of the activities of the church, whether religious or secular.  For example, a church sponsors a seminar for members and nonmembers alike. Even though the church is operating facilities that would otherwise be places of public accommodation, its operations are exempt from the ADA’s title III requirements.

The requirements are different if the church rents their facility to a nonreligious business to conduct a seminar.  In this case, the nonreligious business that rents the church's facilities to conduct the seminar must meet ADA's title III requirements for places of public accommodation. 

  • Is the attendee with chemical sensitivity a person with a disability as defined by the ADA?

The ADA does not have specific provisions that address multiple chemical sensitivities.  In order to be viewed as a disability under the ADA, an impairment must substantially limit one or more major life activities. An individual's major life activities of respiratory or neurological functioning may be substantially limited by allergies or sensitivity to a degree that he or she is a person with a disability. When a person has this type of disability, a covered entity may have to make reasonable modifications in its policies and practices for that person. However, this determination is an individual assessment and must be made on a case-by-case basis.