NOV 18 1997

The Honorable Ernest F. Hollings
United States Senator
1835 Assembly Street
Columbia, South Carolina  29201

Dear Senator Hollings:

     I am responding to your letter on behalf of your
constituent, Mr. XXX              , who asked you to determine if
a person who has fibromyalgia is an individual with a disability
for the purposes of the Americans with Disabilities Act of 1990
(ADA).  Mr. XXX       letter also suggests modifications that he
considers necessary to provide accessibility for people who use
mobility aids, such as canes and walkers.  We apologize for the
delay in responding.

     The ADA does not identify specific diseases or conditions as
disabilities because it would not be possible to guarantee
comprehensiveness by providing a list of specific disabilities.
The ADA provides that an individual will be considered an
individual with a disability for the purpose of ADA coverage if
he or she has a physical or mental impairment that substantially
limits one or more major life activities, has a record of such an
impairment, or is regarded as having such an impairment.  This
definition of "disability" is consistent with the definitions
used in the Rehabilitation Act of 1973 and in the Fair Housing
Amendments Act of 1988.

     The Department of Justice regulations implementing the ADA
provide a broad definition of the term "physical or mental
impairment."  Physical impairments include, among other things,
any physiological disorder or condition, cosmetic disfigurement,
or anatomical loss affecting one or more body systems, including
conditions that affect neurological or musculoskeletal systems.
Therefore, fibromyalgia is a condition that is potentially
covered by the ADA if, in fact, it substantially limits one or
more life activities of an affected individual.

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     With respect to the architectural modifications suggested by
Mr. XXX      I note that the U.S. Architectural and Transportation
Barriers Compliance Board (Access Board) is now in the process of
reviewing its ADA Accessibility Guidelines.  The Access Board
anticipates that it will publish revised guidelines for public
comment in 1998.  If Mr. XXX     wishes to have his suggestions
considered by the Access Board during this process, he may write
to the:

          U.S. Architectural and Transportation
             Barriers Compliance Board
          1331 F Street, N.W.
          Washington, D.C.  20004-1111

     I hope that this information is helpful to you in responding
to your constituent.

                         Sincerely,

                    Isabelle Katz Pinzler
               Acting Assistant Attorney General
                    Civil Rights Division