Implementation

Communicating About and Distributing the Plan

Communicating effectively is vital in any emergency preparedness plan. It can impact the establishment of emergency plans, maintenance of an effective plan, and response to drills and/or an actual emergency. In short, it directly affects an individual's ability to remain safe in an emergency, and can mean the difference between life and death, or well-being and injury. One aspect of communication involves ensuring that everyone understands the plan and can easily locate the necessary information. An agency may communicate information about its emergency preparedness plan in a number of ways (e.g., through an internal Web site available to all employees, through written procedures or memoranda, and at staff meetings). Regardless of the methods used, communications to employees with disabilities must be as effective as those to non-disabled employees.

Considerations

• Information distributed through the agency's Web site or intranet should be accessible to blind/low-vision employees who use screen readers, as well as those employees who may use speech recognition technology.
  
  Note: PDF files and PowerPoint presentations may be inaccessible using screen readers. If an agency uses such formats to communicate emergency preparedness information, the documents should also be made available in a word processing application or plain text. Text descriptions should be provided for images, graphics, and charts.
• Hard copy documents should also be provided electronically, whether on e-mail, disk, or CD. Text descriptions should be provided for graphics, images, and charts.
• Use simple language and different formatting techniques to highlight key points and make the document more reader-friendly.
• Locate the plans in a prominent place(s) on the agency's intranet and, if possible, throughout the building.
• Conduct meetings or training sessions for staff in locations accessible to employees who use wheelchairs.
• Ensure effective communication with employees who are deaf or hard of hearing (i.e., by providing qualified sign language interpreters, transliterators, Communication Access Realtime Translation [CART], assistive listening devices, or other aids/services) at emergency preparedness training sessions and meetings.
• For buildings or agencies that issue frequent-visitor identification badges (in order to expedite security clearance each time the non-agency personnel visits the facility), distribute emergency evacuation and shelter-in-place (SIP) information at the time the identification badge is issued.

Critical Questions

• Is emergency preparedness information communicated with the same frequency and level of detail to all employees? If not, what steps will be taken to correct this?
  
  Is the information on emergency preparedness on the agency Web site or intranet easy to locate and available in a text version? Are there text descriptions for every image, graphic, and chart?
• Are emergency preparedness training sessions and meetings in accessible locations? Are qualified sign language interpreters, transliterators, CART, assistive listening devices, or other aids/services provided when necessary to ensure effective communication with deaf or hard of hearing employees?
• Are copies of the plan placed in prominent locations throughout the building?
• Are emergency-evacuation and general SIP information distributed to those who have frequent-visitor identification badges?

Employer Responsibilities and Employee Right to Self-Determination

Each agency must provide a safe workplace for all employees, including those with disabilities. It is incumbent upon managers who oversee employees with disabilities to be aware of specific emergency preparedness guidance outlined in the agency's Occupant Emergency Plan (OEP). Furthermore, managers should be proactive in discussing the topic with all employees. At the same time, people with disabilities must take responsibility for engaging in emergency preparedness.

Neither the Rehabilitation Act of 1973 nor the Americans with Disabilities Act (ADA) specifically require emergency preparedness plans. They do, however, require equal access for people with disabilities to the benefits and privileges of employment, the programs and activities conducted or funded by the Federal Government or state and local governments as well as to the goods and services made available by places of public accommodation. If a plan is in place, it must include people with disabilities. Employers who do not have emergency evacuation plans may still have to address emergency evacuation for employees and/or visitors with disabilities under Sections 501 and 504 of the Rehabilitation Act and under the ADA.

Employers undoubtedly bear much of the responsibility for emergency preparedness, but employees with disabilities must also actively participate in the process. Dr. Richard Horne, Supervisory Research Analyst in the Office of Disability Employment Policy (ODEP) at the U.S. Department of Labor (DOL), stresses that if employees do not plan, then what they need will not be in place when it is needed. A dialogue between employees and employers is essential in successful planning. While an employer should make every effort to ensure the safety of all employees, the reality is that not everyone who may need assistance in an emergency will know that they should or will want to ask for help in advance of an emergency. More importantly, employees should not assume that plans have been made to assist them.

Considerations

• If a person believes he/she does not need assistance, but impedes others during an evacuation drill, talk to the individual directly and privately to try and work out a solution. Generally, the Rehabilitation Act prohibits an employer from requiring that an employee with a disability accept a reasonable accommodation. At the same time, an employer may take appropriate action to ensure that an individual with a disability does not pose a "direct threat" (i.e., a significant risk of substantial harm to the individual or others) in the workplace.
• Reconsider your agency's definition of disability, or at least the means of identifying who will need assistance during an emergency. Think broadly. Do not limit assistance to only those who meet the Rehabilitation Act's definition of "disability." This will maximize the effectiveness of an emergency preparedness program and may encourage individuals who do not consider themselves "disabled" to plan ahead. Additionally, conducting practice drills can be helpful in determining whether or not assistance is needed during an emergency.
  
  Note: June Isaacson Kailes, Associate Director at the Center for Disability Issues and the Health Professions at Western University of Health Sciences, insists, "Many people who need assistance will never, ever identify as having a disability or having ... a special need." She attributes this primarily to the fact that..." Unfortunately, many people still attach a broad amount of stigma to disability and do whatever they can to stay away from that effort."
• Regardless of whether individuals choose to self-identify, they should be encouraged to plan. Avoid the avoidance tendency!
  
  Note: As mentioned earlier, employees must take the initiative to ensure that plans are in place for them. Whether or not people choose to self-identify, plans are essential to mitigating the impact of any emergency. As June Isaacson Kailes explains in Evacuation Preparedness: Taking Responsibility For Your Safety: A Guide For People With Disabilities and Other Activity Limitations, "There is a universal human tendency to avoid thinking about possible emergencies. This avoidance has greater consequences for people with disabilities than for people without disabilities." ¹¹
• Involve people with disabilities in all stages of the process. If you are constructing an individual plan, talking with the employee is key. The disability community motto, "Nothing About Us Without Us," should be a guiding principle in emergency preparedness planning.
  
  Example: During a 1993 fire drill at the U.S. Department of Agriculture (USDA) headquarters, multiple employees with disabilities were either left behind or unable to evacuate. Following that event, a panel consisting of six employees convened to ensure this would not happen again. In 1994, the panel prepared Occupant Emergency Plan Review for Employees with Disabilities. A key recommendation of the report was the call for autonomy and independent decision-making authority in emergency planning.
• Do not exclude individuals with disabilities from employment or employment-related activities because of fears about workplace emergencies. Only when the agency can demonstrate that a person with a disability will pose a "direct threat" can it lawfully exclude the individual from employment or other employment-related activities.
  
  Definition: A direct threat means a significant risk of substantial harm to the individual or others that cannot be reduced or eliminated through reasonable accommodation. Assessments should take into account the needs of individual employees. Avoid making generalizations based on an individual's disability. Concerns about evacuating an individual will rarely, if ever, meet the direct threat standard.
• Keep in mind that the Rehabilitation Act generally prohibits agencies from limiting, segregating, or classifying individuals with disabilities in a manner that discriminates against them.
  
  Example: If an agency places all employees with disabilities, or those needing assistance in the event of an emergency, in a single workspace, this would likely violate provisions of the Act.
• When requested as a reasonable accommodation, an employer may relocate a particular employee with a disability to a different part of the facility (e.g., to the first floor) in order to aid in the evacuation process, as long as it is not an undue hardship for the organization.

Critical Questions

• Are there employees who impede the evacuation of others? Has the issue been addressed privately and directly? Have solutions or alternatives been suggested?
• Have all of the following factors been thoroughly considered when determining whether a particular applicant or employee with a disability would pose a "direct threat"?
  • The nature and severity of the potential harm
  • The likelihood that the potential harm will occur
  • The duration of any risk posed by the individual
  • The imminence of the potential harm
  • The availability of any reasonable accommodation(s) that would reduce or eliminate the risk
• Has every effort been made to ensure that people with disabilities have been included in the emergency planning process? Has every effort been made to ensure that people with disabilities have not been segregated or discriminated against in establishing emergency procedures?
• Has every effort been made to ensure that people with disabilities have not been segregated or discriminated against in establishing emergency procedures?
• Have employees made requests for reasonable accommodations with regard to emergency preparedness? If so, have all these requests been fulfilled? If not, can the agency show that providing the accommodation(s) would impose an undue hardship?

Working with First-Responders: First-Responder Responsibilities and Employee Right to Self-Determination

The priorities of first-responders and people with disabilities sometimes seem at odds. Accounts from September 11, 2001, indicated that several individuals with disabilities decided to wait in the stairwells for rescuers. Rescuers never reached them. Others with disabilities chose to evacuate, with the help of co-workers and rehearsed plans. This situation was not unique, and it exemplifies a common dilemma: To what extent should an agency or individual rely on first-responders to evacuate an employee? By the same token, to what degree should an individual be able to decide how to get out of the building? Remember that choosing whether to wait for first-responders in order to evacuate is a personal decision. Nevertheless, all options should be clearly and thoroughly explained, so the employee can make an informed decision.

Considerations

• Create opportunities for employees with disabilities to make their preferences known, and share the agency's policy with all staff.
  
  Example: Prior to September 11, 2001, at the DOL headquarters, there was a lack of employee knowledge regarding the Frances Perkins Building Evacuation & Emergency Response Handbook, and procedures related to evacuation, what to do once outside, and re-entry into the building. Furthermore, people with disabilities were often told to "stay put" or were confused about exactly where they should go. Now, when appropriate, there is an "everyone out" policy, which means that plans provide a means for all employees to evacuate.
• Inform the local fire department about any particular issues that you have identified with respect to the employees with disabilities.
  
  Example: The U.S. Access Board has learned that the police and fire department go to the front desk first. This gives them an overview of what is happening in the building. It is here the Board maintains a list of all the people with disabilities and their preferences for evacuation (i.e., staff members who preferred to wait in the office's safe area for firefighters or law enforcement officers rather than use an evacuation chair). Briefings regarding the Board's plans have been held for local fire departments.
• Involve first-responders in the planning, implementation, and maintenance phases. This is important to ensure all procedures facilitate getting everyone to safety as quickly as possible.
  
  Example: The U.S. Department of Defense's Defense Intelligence Agency (DOD/DIA) periodically conducts drills in which firefighters go to where the employees are located in the building. The firefighters talk to employees, either as a group or individually, about next steps and give advice in accordance with the employees' specific limitations. DOD/DIA's plan also calls for the provision of counseling, by trained personnel, for individuals who may have a debilitating emotional or psychiatric reaction to the stress of an emergency.
• The Rehabilitation Act "reasonable accommodation" mandate is intended to provide the same level of safety and utility for people with disabilities as is provided to everyone.
• Consider purchasing evacuation chairs, and evacuating any mobility devices (e.g., wheelchairs) that individuals may require once they have been removed from the emergency situation.
  
  Note: Many fire departments have ladders that cannot reach the entire height of a multiple story building. By having evacuation chairs available, people with disabilities can, at the very least, be moved to an area or floor where emergency response personnel can assist them further. Additionally, having a plan in place for evacuating mobility devices makes for a smoother transition for employees who use them. Otherwise, employees will be essentially helpless once they have left the emergency situation.
  
  Example: The DOL headquarters has purchased extra wheelchairs that remain in strategic locations throughout the building (e.g., stairwells and the main lobby). This facilitates the safe and quick evacuation of wheelchair users and others needing assistance.
• Areas of refuge or areas of rescue assistance are a requirement under the Americans with Disabilities Act ( ADA), the Uniform Federal Accessibility Standards (UFAS) and the International Building Code (IBC). Such areas are only necessary in new buildings. Structures with an approved sprinkler system are an exception and do not require an area of refuge. (See Legal Considerations section for more information.)
  
  Note: If an aerial evacuation (fire department equipment with a ladder and/or a "cherry picker") is utilized, be sure the equipment can reach to the room window. The rule of thumb is that the equipment can reach up to the seventh story, assuming the area below the window is perfectly level and has a solid "footing."
• Explore the pros and cons of various evacuation procedures, and involve employees with disabilities and first-responders in the decision-making process.
  
  Note: Agencies must consider such issues as elevator use, areas of refuge, the type of equipment available, and which employees will require assistance. Research, training, and practice are essential in helping both agencies and individuals evaluate the options and determine the most effective practices. When evaluating and prioritizing options, it is also critical to consider the type of emergency.

Critical Questions

• Have first-responders been notified of particular issues related to employees with disabilities? Does all staff have the same level of safety?
• Does the agency have a policy regarding evacuation? Has it been clearly communicated? Have any expressed strong opposition? If so, how has the issue been addressed?
• Have first-responders been involved throughout the process? If not, how will this be addressed?

Re-Thinking the Elevator Policy

Since the September 11th attacks, there has been renewed interest in elevator use for both occupant egress and firefighter access. This seems to be in direct conflict with what we, as a society have been taught. Historically, elevator use has been regarded as dangerous, prohibited in virtually all emergency situations. However, according to current standards, some elevators are indeed operable under certain circumstances. More importantly, fire experts have begun advocating elevator use in high-rise buildings as one method of taking firefighters to the blaze and evacuating building occupants.¹²

Considerations

• Talk with first-responders to get a clearer understanding of both who can operate approved elevators and under what circumstances this can be done.
  
  Note: According to The American Society of Mechanical Engineers (ASME), Phase I is also referred to as Emergency Recall Operation. It is defined as "the operation of an elevator where it is automatically or manually recalled to a specific landing and removed from normal service because of activation of firefighters' service" (ASME A17.1).¹³ Following an emergency (in which an alarm is activated), elevators automatically move to the main floor (or floor exiting to the outside) and lock down in Phase I. Once fire personnel arrive and ensure the elevators are safe to use, authorized personnel can operate them manually (Phase II). Most new elevators have buttons (marked with a red fire hat) that flash when they are unsafe for use.
• Review the agency's current policy on elevator use in the event of an emergency. Keep in mind that elevators may only be operated in certain situations by authorized personnel if they meet the specific criteria and comply with appropriate local codes.
  
  Note: Such elevators share several characteristics intended to ensure safety and reliability. They must be installed in a smoke-proof hoistway constructed to a two-hour fire resistance and pressurized against smoke infiltration. In addition, these elevators must be pressurized and have enclosed lobbies with a two-hour resistance (one-hour in buildings fully equipped with sprinklers). Fire codes in some locations, such as New York, preclude the use of elevators in high rise buildings during fire emergencies.
  
  Example: The U.S. Department of State headquarters has three freight elevators powered by emergency diesel generators. They are specifically designated for people with disabilities, and will continue operating during a fire, even in the event of a power failure. If the fire is near an elevator, the elevator will not operate. As such, employees are encouraged to learn the location of all these elevators. Facility personnel can activate an elevator's override and ensure the operation of elevators, as can the District of Columbia Fire Department.
  
  Some of the over 40 State Department annexes are in leased spaces where all elevators are recalled to the main exit floor and can only be operated by incoming firefighters. Other buildings have elevators that continue operating during emergencies as long as smoke is not detected in the elevator lobbies or in the elevator shaft.
• Establish a policy regarding who will be permitted to use the elevator in an emergency, and how the determination will be made.
  
  Example: At the U.S. Department of Transportation (DOT) headquarters, a ny individual requesting to use the elevator during an emergency evacuation is allowed to do so. DOT believes this is the safest approach because many individuals may have hidden disabilities. In the event of an actual emergency, this saves fire wardens critical time, since they are not in the position of determining whether an individual has an actual need.
• Determine one or more means of evacuating individuals in the event that all the building elevators are inoperable.
  
  Example: At the DOL headquarters, the use of elevators depends on the nature of the emergency. Due to the steel and stone makeup of the elevators, there is a low incidence of burning. In the event of an emergency, some elevators return to the first floor. Others are manually operated by Emergency Elevator Operators (EEOs) and serve as a means of assisting persons with disabilities out of the building.
  
  Note: If all of the elevators are deemed unsafe, Zoë Fearon of DOL's Office of the Assistant Secretary for Administration and Management (OASAM), says, "We would use our last line of defense [the stairwell and an evacuation device] to evacuate people with disabilities from the building."

Critical Questions

• Does the agency have a policy on elevator use during an emergency?
• Have first-responders been consulted in the development of this policy? If so, under what circumstances may elevators be used, and who is permitted to operate them?
• Has a determination been made regarding who gets priority use of the elevators?
• What are the alternative means of evacuating an individual in the event that designated elevators are inoperable?

Emergency Notification Strategies

On a broad level, the need for an accessible, consistent, reliable and redundant multi-platform emergency notification system that effectively serves people with disabilities is recognized by both the Federal Communications Commission (FCC) and the Department of Homeland Security (DHS). People with disabilities, like others, need access to timely information in the event of an emergency. This holds true not only in the community, but also in the workplace. Consider the following example of a deaf employee on September 11, 2001:

Employees were told to evacuate a building and go home. For a deaf individual, a co-worker hand-signed the word "war" and told him to get out. He had no knowledge of what had happened at the Twin Towers or the Pentagon. When he was outside the building, he didn't see any of his co-workers, so he went back into the office. One co-worker, who was still in the building, again spelled out in sign alphabet the word ‘war' and told him to go home. He eventually did but was unable to obtain detailed information about what was going on while at work.

This experience was not unique. Reports from organizations "indicate[d] that widespread difficulties were experienced across the nation."¹⁴A national follow-up survey in Spring 2003 asked what plans or procedures had been implemented. "This second survey found that only a few isolated attempts had been made across the U.S. and that there was little or no sharing of information or coordination of efforts."¹⁵

Considerations

• Implement a variety of systems, rather than just one system to communicate information.
  
  Note: Keep in mind that the specific type of emergency will affect the method of notification. When an emergency is combined with a loss of power, the problem becomes even more severe, as back-up sources of information may not be usable by people with sensory disabilities. Radios and telephones are not an option for many people with hearing loss, and text telephones (TTYs) require power. Web-based information and cell phone menus are often inaccessible to people with vision loss.
  
  Example: Originally, the U.S. Office of Personnel Management (OPM) had provided pagers to employees who were deaf and hard of hearing, so they could be notified during an emergency. However, recently a Mylar coating was applied to the windows of the building, which interfered with the transmission of the alert to the employees using the pagers. OPM then provided wireless hand-held communication devices to alert these employees in the event of an evacuation or shelter-in-place.
  
  OPM has also installed the E-POP system, which when activated by Security and Emergency Actions displays a pop-up screen on every computer, directing employees to evacuate or shelter-in-place or provides other pertinent emergency information.
• Develop strategies for communicating with people who are away from their desk or out of the building.
  
  Example: The USDA uses a pager system to notify deaf or hard of hearing employees during emergencies. These pagers have two numbers, one for the pager itself and the other to let individuals know that there is an emergency. All other pagers are dialed remotely.
• Ensure that the emergency-planning manual has information specific to people who are deaf or hard of hearing.
• Make sure individuals with disabilities who have speech or communication difficulties can convey information quickly to those who need to know. This can be accomplished by whatever means works best for the individual.

Agencies must ensure that a variety of notification systems that are understood by all employees are in place. Below are some systems and situations in which they can be utilized.

• Fire alarms: Evacuation only
• Hearing-Impaired Pager System (HIPS) devices (for persons who are deaf or hard of hearing): Fire alarms only.
• Computer Electronic Notification Systems (CENS): These systems can be used in all situations, but the software system must afford access to all. This will require it to be compatible with screen readers and speech recognition software (a good system for shelter-in-place).
• Warden Phones: These are phones located at elevators that connect to a command center. The command center informs persons with mobility impairments whether or not it is safe to use elevators. A button inside the elevators can allow individuals to contact the command center. Some people believe TTYs (teletypewriters) should also be installed in elevators to ensure similar access for deaf or hard of hearing employees.
• Public Address Systems (PAS)
• Wireless Communication Devices (e.g., pagers, PDAs, cell phones)
• Short-Wave Radios: Floor Monitors and drivers use these radios.
• Emergency Hotline: Concerned individuals or employers may call in (using a phone or TTY) and obtain more information about the situation.
• Web Site Information

Critical Questions

• Have efforts been made to ensure that all employees and visitors — including those who are deaf or hard of hearing and/or blind/low vision — have access to the same information in a detailed and timely manner?
• Are there multiple methods in place to notify individuals of emergency plans and procedures?
• Do these methods account for those who may be away from their desks or the office?
• Do agency plans take the possible loss of electric power into consideration?
• Do the plans take visitors into account?

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