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This is an interim handbook to assist program managers throughout GSA in
providing meaningful access for individuals with disabilities and
Limited English Proficiency.

To obtain this handbook in an alternative format (large print,
electronically, audiotape, Braille), contact the Office of Civil Rights
at 202-501-0767 (voice); 1-888-267-7660 (TDD); Federal Relay at
1-800-877-8339; or email <OCR@gsa.gov>.

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The General Services Administration (GSA) is committed to providing
meaningful access for individuals with disabilities and individuals with
Limited English Proficiency (LEP) to GSA's programs and activities. As
one of the primary guardians of the public trust for the government's
management of federal buildings, technology solutions, supplies and
governmentwide policy, GSA is in a unique position to promote and
facilitate a culture of inclusiveness.

Federal laws require that federally conducted programs and activities
provide meaningful access to individuals with disabilities. Executive
Order 13166 requires all Federal agencies to take reasonable steps to
provide meaningful access to their programs and activities for
individuals with LEP. Additionally, Executive Order 13160 prohibits
discrimination in federally conducted training and education programs on
the basis of race, color, national origin, sex, religion, age,
disability, sexual orientation, and status as a parent.

# A. What is a federally conducted program or activity?  {#a.-what-is-a-federally-conducted-program-or-activity .Style1Yellow}

A federally conducted program or activity is anything a Federal agency
does. Aside from employment[^1], there are two major categories of
federally conducted programs or activities covered: (1) those involving
general public contact as part of ongoing agency operations and (2)
those administered for program beneficiaries and participants.

# B. What are some examples of federally conducted programs and activities?  {#b.-what-are-some-examples-of-federally-conducted-programs-and-activities .Style1Yellow}

Some examples of GSA's federally conducted programs and activities
include, but are not limited to:

1.  [Communication with the public]{.underline} (i.e., telephone
    contacts with the public or customer agencies, office walk-ins,
    emails and websites);

2.  [Public's use of GSA's facilities or equipment]{.underline} (i.e.,
    auditorium, meeting rooms, vending areas, kiosks, common use areas);

3.  [Public events]{.underline} (i.e., building dedication ceremonies,
    public hearings, auctions, expos, conferences, training, outreach
    activities);

4.  [Other programs/activities]{.underline}, such as shuttle
    service/transportation of individuals, and building
    management/security (i.e., common areas, access to GSA-controlled
    facilities/property).

# C. What is the purpose of this handbook?  {#c.-what-is-the-purpose-of-this-handbook .Style1Yellow}

The purpose of this handbook is to: (1) show the interrelationship among
the different organizations within GSA that have played and continue to
play key roles with regard to program accessibility; (2) bring together
one ready reference tool with information and resources for program
managers to use; and (3) facilitate compliance with applicable laws and
Executive orders that apply to GSA's federally conducted programs and
activities.

# D. What are the applicable laws, regulations and guidance that apply to federally conducted programs and activities? {#d.-what-are-the-applicable-laws-regulations-and-guidance-that-apply-to-federally-conducted-programs-and-activities .Style1Yellow}

1.  [Federal Statutes that Apply to Federally Conducted Programs and
    Activities]{.underline}:

> a\. [Section 504 of the Rehabilitation Act of 1973, as
> amended](http://www.section508.gov/index.cfm?FuseAction=Content&ID=15):
> requires Federal agencies to make their programs and activities
> accessible to people with disabilities.
>
> b\. [Section 508 of the Rehabilitation Act of 1973, as
> amended](http://www.section508.gov/index.cfm?FuseAction=Content&ID=14):
> requires Federal agencies to ensure that electronic information
> technology (EIT) is accessible to people with disabilities.

2.  [Regulations that Apply to Federally Conducted Programs and
    Activities:]{.underline}

> a\. 41 CFR 105-8 is GSA's implementing regulation for Section 504 of
> the Rehabilitation Act of 1973, as amended: The regulation addresses
> Agency requirements and general prohibitions of discrimination,
> establishes a complaint process, requires GSA to conduct
> self-evaluations of all programs and to develop transition plans to
> address structural modifications required to make GSA's programs
> accessible to individuals with disabilities.

b.  36 CFR 1194 is the [standards for Section
    508](http://www.access-board.gov/sec508/508standards.htm) of the
    Rehabilitation Act of 1973, as amended, issued by the U. S.
    Architectural and Transportation Barriers Compliance Board (i.e.,
    hereinafter referred to as the Access Board).

c.  [48 CFR Parts 2, 7, 10, 11, 12 and
    39](http://www.section508.gov/index.cfm?FuseAction=Content&ID=13)
    are the sections of the Federal Acquisition Regulation, regarding
    the procurement of Electronic Information Technology, which
    incorporate the Section 508 standards issued by the Access Board to
    ensure compliance with Section 508 of the Rehabilitation Act of
    1973, as amended.

3\. [Executive Orders that Apply to Federally Conducted Programs and
Activities]{.underline}:

> a\. [Executive Order 13160](http://www.usdoj.gov/crt/cor/13160.htm):
> requires that no person, on the basis of his/her
>
> race, sex, color, national origin, disability, religion, age, sexual
> orientation, and status as a parent, shall be excluded from
> participation in, be denied the benefits of, or be subjected to
> discrimination in a federally conducted education or training program
> or activity.
>
> b\. [Executive Order
> 13166](http://www.usdoj.gov/crt/cor/Pubs/eolep.htm): requires all
> Federal agencies to take reasonable
>
> steps to provide meaningful access to their programs and activities
> for individuals who, because of their national origin, are limited
> English proficient.

4\. [Other Guidance, Information and References]{.underline}:

a.  The Uniform Facility Accessibility Standards
    ([UFAS](http://www.access-board.gov/ufas/ufas-html/ufas.htm#intro)),
    applicable to Federal buildings.[^2]

b.  GSA [Interim Complaint Procedures for 508
    Complaints](http://www.gsa.gov/civilrights).

c.  [Section 508 website](http://section508.gov/).

d.  [Disability Info website](http://www.disabilityinfo.gov/).

e.  [Section 508 Information Technology Accessibility Program and
    Technical Guides](http://insite.gsa.gov/_cio/section508).

f.  [U. S. Department of Justice\'s (DOJ)
    guidance](http://www.usdoj.gov/crt/cor/13160.htm) regarding
    implementation of Executive Order 13160.

g.  [DOJ\'s guidance](http://www.usdoj.gov/crt/cor/13166.htm) regarding
    implementation of Executive Order 13166.

h.  [Limited English Proficiency website](http://www.lep.gov/).

i.  [The Access Board website](http://www.access-board.gov/).

j.  [A Planning Guide: Accessible Temporary
    Events](http://www.sedbtac.org/), produced by The Center for
    Universal Design, College of Design, North Carolina State University
    (1998).[^3]

k.  [GSA Language Services
    Schedule](http://www.gsa.gov/Portal/gsa/ep/programView.do?pageTypeId=8211&ooid=10122&programPage=%2Fep%2Fprogram%2FgsaDocument.jsp&programId=8640&channelId=-13004)
    provides access to vendors that provide interpretive/translation
    services, Braille, LEP services, etc.

[Other Guidance, Information and References (continued)]{.underline}

l.  [Usability.gov](http://www.usability.gov/) website, offers training
    to improve the usability of Federal websites and other communication
    technologies.

# E. Who are the key players at GSA that work to ensure that GSA's programs are accessible? {#e.-who-are-the-key-players-at-gsa-that-work-to-ensure-that-gsas-programs-are-accessible .Style1Yellow}

All of GSA's associates and program managers play a critical role of
ensuring that GSA's programs and activities are accessible to the public
that we serve and to our customer agencies. Also, the following
organizations within GSA play key roles in making GSA's programs and
activities accessible.

1.  [The Public Buildings Service (PBS),]{.underline} [Office of Chief
    Architect
    (OCA)](http://www.gsa.gov/Portal/gsa/ep/contentView.do?contentType=GSA_OVERVIEW&contentId=8152)
    ensures access to Federal facilities for persons with disabilities
    by designing and building them in compliance with Federal laws.[^4]
    The National Accessibility Officer within OCA ensures that buildings
    occupied by Federal tenants or receiving Federal funds are
    accessible under applicable laws and guidelines. He or she also
    responds to complaints of inaccessibility regarding GSA's buildings
    and those under GSA's authority. Regional Accessibility Officers
    investigate the complaints and report to the National Accessibility
    Officer.

2.  [The Office of Governmentwide Policy (OGP), Center for IT
    Accommodation]{.underline} sponsors the [Assistive Technology
    Showcase](http://www.gsa.gov/Portal/gsa/ep/contentView.do?contentType=GSA_OVERVIEW&contentId=9815),
    which displays state-of-the-art assistive technologies and ergonomic
    solutions, and supports government managers, supervisors, employees,
    and the public with a wide range of assistive technology and
    ergonomic equipment. The Showcase provides worksite assessments for
    disability and ergonomic needs, in addition to providing product
    information for individuals outside the Washington, DC area.

3.  [The Office of the Chief Information Officer,]{.underline}
    [Information Technology Planning
    Division](http://insite.gsa.gov/_cio/section508/GR/ITAccessibilityGuide103002.doc)
    coordinates GSA's Section 508 compliance and ensures GSA's website
    is Section 508 compliant. The Office published 508 accessibility
    program and technical guides, which provides information and
    resources regarding 508 compliance.

> [Key Players at GSA (continued)]{.underline}
>
> 4\. [Citizen Services and
> Communications](http://www.gsa.gov/Portal/gsa/ep/contentView.do?programId=9605&channelId=-13326&ooid=10161&contentId=12811&pageTypeId=8199&contentType=GSA_BASIC&programPage=%2Fep%2Fprogram%2FgsaBasic.jsp&P=XAE)
> developed and manages FirstGov en Español,
> [www.espanol.gov](http://www.espanol.gov/), a Spanish-language website
> to meet the needs and preferences of the estimated 28.1 million
> Spanish-speaking residents in the United States. Their services also
> include telephonic information in Spanish.
>
> 5\. [The Federal Telecommunications Service]{.underline} manages the
> [Federal Relay Service
> (FRS)](http://www.gsa.gov/Portal/gsa/ep/contentView.do?contentType=GSA_BASIC&contentId=8136).
> The FRS was established under Public Law 100-542, the
> Telecommunications Accessibility Act of 1988. FRS provides
> Communication Assistants (CAs) who act as intermediaries for
> telecommunications between hearing individuals and individuals who are
> deaf, hard-of-hearing, deaf-blind, and/or have speech disabilities.
> FRS is also available for Spanish-speaking individuals who are deaf,
> hard-of-hearing, deaf-blind and/or have speech disabilities.
> Additional offerings include the Federal CapTel (Captioned Telephone);
> Federal Video Relay Service; Federal Relay Conference Captioning; and
> Federal Relay Service Online.
>
> 6\. [The Office of Civil Rights\'](http://www.gsa.gov/civilrights)
> responsibilities include the following:\
> (a) ensures compliance with Sections 504 and 508 of the Rehabilitation
> Act of 1973, as amended, Executive Order 13166 and Executive Order
> 13160; (b) provides technical assistance to GSA's program managers and
> responds to questions from the general public and customer agencies
> regarding meaningful access to GSA's programs and activities; (c)
> processes complaints of non-compliance with applicable laws, Executive
> Orders, regulations and guidance that apply to GSA's programs and
> activities; and (d) develops regulations, policies and procedures with
> respect to civil rights compliance and enforcement.

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Disabilities affect us all at some point in our lives---either as a
person with a disability or as a person with a family member or friend
with a disability. The Census Bureau reports that there are 49.7 million
people with some type of long lasting condition or disability. This
represents 19.3 percent of the 257.2 million people 5 years of age or
older, and does not count the institutionalized population.[^5] This
number represents roughly 1 in 5 people who have one or more
disabilities. The Census report showed the number of individuals with
disabilities increasing with age. Generally, the types of disabilities
include sensory, cognitive, physical and speech.

Pursuant to Section 504 of the Rehabilitation Act of 1973, as amended,
Federal agencies are prohibited from discriminating on the basis of
disability in their programs and activities. GSA's implementing
regulation for Section 504, 41 CFR 105-8, was published in March 1991,
and applies to ALL programs or activities conducted by GSA. The
Associate Administrator of Civil Rights is the designated responsible
official for ensuring compliance with the regulation.

# A. Who is an individual with a disability for purposes of Section 504? {#a.-who-is-an-individual-with-a-disability-for-purposes-of-section-504 .Style1Yellow}

A person with a disability is defined as one who 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. Major life activities include functions such as
caring for one's self, performing manual tasks, walking, seeing,
hearing, speaking, breathing, learning and working.

# B. What does GSA's 504 implementing regulation, 41 CFR 105-8, require? {#b.-what-does-gsas-504-implementing-regulation-41-cfr-105-8-require .Style1Yellow}

> 1\. Requires that each program or activity, when viewed in its
> entirety, be readily accessible to and usable by individuals with
> disabilities (i.e., meaningful access). This includes programs and
> activities offered by GSA through contracts or other arrangements.
> Agreements between GSA and other entities for the provision of
> programs or activities should be carefully written to ensure that
> access for people with disabilities is explicitly required in the
> statement of work.
>
> 2\. Requires GSA to conduct a self-evaluation of all programs and
> activities to identify both physical and non-physical barriers to
> access for individuals with disabilities.
>
> 3\. Requires GSA to develop transition plans to address structural
> barriers that limit or exclude program access to individuals with
> disabilities.
>
> 4\. Requires GSA to provide notice to the public apprising them of
> their rights and protections afforded by Section 504.
>
> [What does GSA's 504 implementing regulation, 41 CFR 105-8, require?
> (continued)]{.underline}
>
> 5\. Requires GSA to take appropriate steps to ensure effective
> communication with personnel of other Federal entities and members of
> the public.
>
> 6\. Requires GSA to administer its programs and activities in the most
> integrated setting appropriate to the needs of individuals with
> disabilities.
>
> 7\. Makes GSA jointly responsible with a tenant agency for resolving a
> complaint that alleges a tenant agency's program is inaccessible
> because of a facility under GSA's control being inaccessible.
>
> 8\. Establishes a complaint process, which includes an investigation
> and hearing, if the complaint cannot be resolved informally.

# C. What makes a program "readily accessible and usable by individuals with disabilities"? {#c.-what-makes-a-program-readily-accessible-and-usable-by-individuals-with-disabilities .Style1Yellow}

In order for individuals with disabilities to access one of GSA's
programs or activities, there are, in essence, two different types of
access to address:

> 1\. [Structural access]{.underline}: Each building or part of a
> building that is constructed or altered for the use of GSA is required
> to be designed, constructed, or altered so as to be readily accessible
> to and usable by individuals with disabilities. ([See]{.underline} 41
> CFR 105-8.151) New construction or alteration of buildings must follow
> the Uniform Facilities Accessibility Standards (UFAS), established by
> the Access Board.[^6] PBS is responsible for ensuring that buildings
> comply with applicable standards.[^7] For the purpose of the remainder
> of this handbook, it is assumed that the physical structure of the
> building is readily accessible to and usable by individuals with
> disabilities. Any areas of concern related to the accessibility of
> physical structures should be referred to your Regional Accessibility
> Officer located within PBS.
>
> 2\. [Non-structural access]{.underline}: The program manager should
> assess the nature of the programs or activities within his/her control
> and evaluate the different ways in which individuals access the
> program/activity. For instance, individuals may access a GSA program
> physically, electronically\--via GSA's website, by email/regular mail,
> or by telephone. Therefore, program managers must ensure that (a) an
> accessible route of travel is available at all times for individuals
> with disabilities, and that (b) policies, procedures and practices are
> established and
>
> [What makes a program readily accessible to and usable by individuals
> with disabilities? (continued)]{.underline}
>
> implemented to ensure effective communication and access to programs
> and activities.

# D. What are some ways to comply with the requirements of program accessibility? {#d.-what-are-some-ways-to-comply-with-the-requirements-of-program-accessibility .Style1Yellow}

GSA may comply with the requirement of program accessibility through
such means as redesign of equipment, reassignment of services to
accessible buildings, assignment of aides to beneficiaries/customers,
home visits, delivery of services at alternate accessible sites,
alteration of existing facilities and construction of new facilities,
allowing individuals with disabilities to use service animals, or any
other methods that result in making its programs or activities readily
accessible to and usable by individuals with disabilities.

41 CFR 105-8.150.2 provides that GSA is not required to make structural
changes in *[existing facilities]{.underline}* (prior to July 31, 1984)
where other methods are effective in achieving accessibility.

# E. What is meant by "accessible route of travel"? {#e.-what-is-meant-by-accessible-route-of-travel .Style1Yellow}

Accessible route of travel refers to the physical path that an
individual must travel to access the location inside a building or other
location where the program or activity is located. Generally, the
program manager's area of responsibility (with respect to route of
travel) begins at the point of entry to the program office\--where an
individual leaves the common space of a building or other location
(i.e., hallway, elevators, etc.) and arrives at the "front door" of a
specific program (i.e., the door or entry point from the hallway leading
into the program's space). It continues to the point(s) where
individuals normally go in order to access the program, including
reception areas, waiting areas/meeting rooms and passageways (i.e.,
aisle leading to a particular program).

> [Example]{.underline}: A program is being conducted within a larger
> suite of offices on the fifth floor of a building in Room 5127. Once
> an individual gains entry through the main entrance of the building,
> (s)he must access the program by taking the elevator (or stairs) to
> the fifth floor, and walking down a long, wide hallway having several
> doors, one of which is marked "Room 5127". This door opens into the
> program office. (S)he opens the door marked "5127" and is greeted at
> the program office's reception desk and then taken to a waiting area.
> A staff member later meets her/him in the waiting area, where (s)he is
> then led down a 30-foot passageway to a meeting room.

[What is meant by "accessible route of travel"? (continued)]{.underline}

> [Question]{.underline}: What is the program manager's area of
> responsibility in regard to the "route of travel" in this example?
>
> [Answer]{.underline}: The program manager's area of responsibility
> begins at the program's entry point (i.e., door marked "5127"---front
> door to the program office), and continues through the doorway, to the
> reception area, waiting area and ultimately down the passageway
> leading into the meeting room.

# F. What are some considerations regarding accessible route of travel? {#f.-what-are-some-considerations-regarding-accessible-route-of-travel .Style1Yellow}

[Section 504 of the Rehabilitation Act of 1973, as
amended](http://www.section508.gov/index.cfm?FuseAction=Content&ID=15),
and the [UFAS](http://www.access-board.gov/ufas/ufas-html/ufas.htm)
require that the route of travel be physically accessible. In the event
that the route of travel cannot be physically changed to be made
accessible (i.e., historic preservation exception, fundamental
alteration, undue burden, etc.), the program manager must either (1)
relocate the program or (2) establish alternative means of providing
program access to individuals with disabilities. An alternative means
might include providing program information to an individual with a
disability at an accessible location within the building.

The questions to consider in determining whether the route of travel is
accessible include:

> 1\. [Can the door be easily opened by an individual with a physical
> impairment]{.underline}? Round doorknobs are not accessible. Doors
> should be equipped with an automatic door opener or lever handles. If
> possible, have the door hardware modified for accessibility.
> Otherwise, an alternative measure might be to simply prop the door
> open to allow ease of passage for individuals with mobility
> impairments who would otherwise not be able to open the door. [UFAS
> 4.13](http://www.access-board.gov/ufas/ufas-html/ufas.htm#4.13).
>
> 2\. [Is there a sign/plaque beside the door identifying the room
> number and/or offices]{.underline}? If interior signage is provided,
> they must comply with UFAS sections with regard to the width/height
> ratio and color contrast of characters used on signage, UFAS [4.30.1,
> 4.30.2 and
> 4.30.3](http://www.access-board.gov/ufas/ufas-html/ufas.htm#4.30). In
> addition, permanent signage that identifies rooms and spaces shall
> also comply with UFAS [4.30.4 and
> 4.30.6](http://www.access-board.gov/ufas/ufas-html/ufas.htm#4.30) by
> using raised characters and international symbols of accessibility.
> Interior signage must be located alongside the door on the latch side
> and mounted at a height of between 54 and 66 inches above the finished
> floor.
>
> 3\. [Is the doorway entrance wide enough to accommodate a
> wheelchair]{.underline}? Most wheelchair users need a 30-inch width
> clear opening for doorways, gates, and the like---unless there is a
> passageway---which must be a minimum of 36 inches wide. [UFAS
> 4.13](http://www.access-board.gov/ufas/ufas-html/ufas.htm#4.13). If
> the doorway entrance and/or passageway do not comply, an alternative
> accessible route must be established. Additionally, UFAS requires 32
> inches for the minimum clear width for single wheelchair passage.
> However, passageways that exceed 2 feet of travel require 36 inches
> minimum width.
>
> [Considerations regarding accessible route of travel
> (continued)]{.underline}
>
> This can be accomplished by widening the doorway or passageway. [UFAS
> Appendix A4.2.1](http://www.access-board.gov/ufas/ufas-html/ufas.htm).

If widening the doorway or passageway cannot be readily achieved, the
program or activity should be either (a) re-located to an accessible
location or (b) procedures should be established and communicated
clearly to the staff, wherein the staff knows to use an alternative
location/meeting room that is accessible when providing program
information or assistance to individuals with disabilities in
wheelchairs.

> 4\. [Is the reception desk/counter accessible]{.underline}? If a
> program has a reception desk or counter, is it low enough to
> accommodate an individual in a wheelchair (i.e., can they see the
> receptionist and make use of the counter space)? If not accessible,
> the reception desk/counter should be lowered and made accessible, or
> alternative procedures established. For instance, the receptionist
> could move around the counter to better assist and communicate with
> individuals in wheelchairs.
>
> 5\. [Is there adequate space in the waiting area for the individual in
> a wheelchair to maneuver and wait]{.underline}? The space required for
> a wheelchair to make a 180- degree turn is a clear space of 60 inches.
> [UFAS 4.2.3](http://www.access-board.gov/ufas/ufas-html/ufas.htm#4.2).
>
> 6\. [Is the carpet pile low enough to allow maneuverability of
> wheelchairs]{.underline}? The maximum pile height shall be 1/2 inch.
> Ground and floor surfaces along accessible routes and in accessible
> rooms and spaces, including floors, walks, ramps, stairs, and curb
> ramps must be stable, firm, and slip-resistant, in compliance with
> [UFAS 4.5.3](http://www.access-board.gov/ufas/ufas-html/ufas.htm#4.5).
>
> 7\. [Are protruding objects over the path of travel or objects
> obstructing the path of]{.underline} [travel?]{.underline} Protruding
> objects (i.e., wall light fixtures) over the route of travel must be
> located no less than 80 inches high to ensure a safe, barrier-free
> route of travel for persons with visual impairments who use canes.
> Boxes, file cabinets, and office equipment that are obstructing the
> passageway of travel must be moved and kept clear of the path of
> travel. [UFAS
> 4.4](http://www.access-board.gov/ufas/ufas-html/ufas.htm#4.4).
>
> 8\. [Are there steps leading up or down located within the route of
> travel]{.underline}? If so, a UFAS-compliant ramp ([UFAS
> 4.5](http://www.access-board.gov/ufas/ufas-html/ufas.htm#4.5)) must be
> installed. An alternative measure could be either relocating the
> program, or providing program access at another accessible location
> when the ramp prevents access for persons with disabilities.

# G. Are there any exceptions to program accessibility? {#g.-are-there-any-exceptions-to-program-accessibility .Style1Yellow}

> 1\. With regard to *[new construction or major
> alterations]{.underline}* (i.e., after July 31, 1984) must comply with
> the UFAS---there are no exceptions.[^8]
>
> 2\. 41 CFR 105-8.154 provides that for *[existing
> facilities]{.underline}* GSA is not required to take any action that
> it can demonstrate would result in a fundamental alteration in the
> nature of a program or activity, or result in undue financial or
> administrative burdens.
>
> 3\. In historic preservation programs, GSA is not required to take any
> action that would result in a substantial impairment of significant
> historic features of an historic property. See 41 CFR 105-8.150-1(b).

However, these exceptions do not relieve GSA of all obligations to
individuals with disabilities. Although GSA is not required to take
actions that would result in a fundamental alteration in the nature of a
program or activity, or in undue financial and administrative burdens,
it nevertheless must take any other steps necessary to ensure that
individuals with disabilities receive the benefits and services of the
federally conducted program or activity. The decision that compliance
would result in such alteration or burdens must be made by the
Administrator of General Services Administration or his/her designee,
and must be accompanied by a written statement of the reasons for
reaching that conclusion.

# H. What are the first steps that a program manager should take in determining program accessibility?  {#h.-what-are-the-first-steps-that-a-program-manager-should-take-in-determining-program-accessibility .Style1Yellow}

> 1\. [Conduct a Self-evaluation]{.underline}**:** Program managers must
> conduct a self-evaluation of all programs and activities under their
> control to ensure accessibility for individuals with disabilities,
> pursuant to 41 CFR 105-8.110. A self-evaluation checklist is located
> at Appendix A of this guidebook. Where structural changes are
> required, a transition plan should be developed, setting forth the
> steps necessary to complete such changes.
>
> 2\. [Develop a Transition Plan]{.underline}: The plan should identify
> physical obstacles in the facilities that limit accessibility to the
> program/activity for individuals with disabilities; describe in detail
> the methods that will be used to make the facilities accessible;
> specify the schedule for taking the steps necessary to achieve
> compliance; and designate the official responsible for implementation
> of the transition plan. ([See]{.underline} 41 CFR 105-8.150-4).
>
> [What are the first steps that a program manager should take in
> determining program]{.underline}
>
> [accessibility? (continued)]{.underline}
>
> 3\. [Re-evaluate periodically]{.underline}: Program managers should
> periodically re-evaluate the accessibility of a program or activity
> whenever the nature of the program has changed or the location of the
> program has changed.

# I. What is required to ensure effective communication with individuals with disabilities?  {#i.-what-is-required-to-ensure-effective-communication-with-individuals-with-disabilities .Style1Yellow}

41 CFR 105-8.160 requires GSA to take appropriate steps to ensure
effective communication with individuals with disabilities. These steps
include procedures for determining when auxiliary aids are necessary to
afford an individual with disabilities an equal opportunity to
participate in and enjoy the benefits of a program or activity.

Effective communications include the following:

> 1\. Procedures that provide an opportunity for individuals with
> disabilities to request an auxiliary aid.[^9]
>
> 2\. Primary consideration is given to the auxiliary aid requested by
> the individual, unless it can be shown that either another effective
> means of communication exists or that use of the means chosen would
> result in a fundamental alteration in the nature of a program or
> activity, or in undue financial and administrative burdens.
>
> 3\. Where it is established that a fundamental alteration or undue
> burden exists, alternative assistance must be provided. The program
> must still ensure, to the maximum extent possible, individuals with
> disabilities receive the benefits and services of the program or
> activity.
>
> 4\. Where the Agency communicates with individuals by telephone, a
> telecommunication device for deaf persons (TDD), sometimes referred to
> as the TTY machine, must be used to communicate. An equally effective
> system might be the Federal Relay Service (FRS).
>
> 5\. Ensure that wherever voice telephone numbers are on documents,
> either the TDD/TTY or FRS toll free number is included, along with the
> program's email address. If an individual uses assistive technology,
> it may be easier for them to communicate via email.

# J. What are some examples of auxiliary aids/assistive technology that facilitate effective communication?  {#j.-what-are-some-examples-of-auxiliary-aidsassistive-technology-that-facilitate-effective-communication .Style1Yellow}

Auxiliary aids are services or devices (to include assistive technology)
that enable persons with impaired sensory, manual, or speaking skills to
have an equal opportunity to participate in and enjoy the benefits of
programs or activities conducted by GSA.

Examples include, but are not limited to, auxiliary aids useful for
persons with impaired vision (i.e., readers, materials in Braille, audio
recordings); auxiliary aids for persons with impaired hearing (telephone
handset amplifiers, telephones compatible with hearing aids,
telecommunications devices --TDD/TTY, interpreters, notetakers, written
materials).

Examples and Suggestions:

> 1\. In some instances, a note pad and written materials may be
> sufficient to permit effective communication with a person with
> hearing impairments for short periods of time. Whereas, encounters for
> more than a few minutes may require a hearing interpreter to ensure
> effective communication.
>
> 2\. Generally, people who are deaf or hard of hearing request
> assistive listening devices, captioning, CART (Communication Access
> Realtime Translation -- similar to captioning but confined to a laptop
> or projection screen), or sign language interpreters. Captioning,
> CART, and sign language interpreters are services that are frequently
> contracted from outside vendors. Become aware of the availability of
> these services in your local service area since it is not unusual for
> such services to be in high demand, thereby limiting availability.
> Assume that as much advance notice as possible is needed to assure
> that appropriate services can be acquired. [See]{.underline} [GSA
> Language Services
> Schedule](http://www.gsa.gov/Portal/gsa/ep/programView.do?pageTypeId=8211&ooid=10122&programPage=%2Fep%2Fprogram%2FgsaDocument.jsp&programId=8640&channelId=-13004).

# K. What are some effective communication tips? {#k.-what-are-some-effective-communication-tips .Style1Yellow}

> 1\. When developing forms, publications, press releases, or
> disseminating tools and processes, be sure to consider the
> accessibility of both the content and the medium you elect to use.
>
> 2\. Choose a font style and size that is easy to read. There are no
> hard and fast rules guiding the selection of font styles and sizes. In
> fact, publication manuals and guidelines vary dramatically in their
> rules and preferences. There is, however, some general agreement on
> the following principles:
>
> a\. For print documents, serif fonts are easier to read. Serif fonts
> have little "feet" attached to each letter; Times New Roman is an
> example of a serif font.

[What are some effective communication tips? (continued)]{.underline}

> b\. For electronic displays, sans serif fonts are easier to read. Sans
> serif fonts lack the little "feet" attached to each letter; Arial is
> an example of a sans serif font.
>
> c\. For large print, the size of type required will vary with the
> needs of the reader. For generically produced large print, a font size
> of 16 to 18 is preferred.
>
> d\. Use high contrast colors when possible. It may be difficult for
> people with low vision to see information that is presented in colors
> that do not contrast strongly.
>
> 3\. Remember that some people are colorblind. For many people, the
> colors red and green look essentially alike. Keep this in mind when
> designing color documents.
>
> 4\. Remember to include a statement similar to the following in any
> documents you disseminate:
>
> 5\. The severity and type of a speech disability can vary dramatically
> as can the communication modes individuals choose to use. Some people
> with speech disabilities choose to speak for themselves while others
> opt for using an interpreter or assistive technology to help them in
> being understood.
>
> 6\. Regardless of the severity of disability or the method of
> communication, patience and careful listening are of paramount
> importance. When talking with people who have speech disabilities, do
> not pretend to understand what they are saying. Allow people to
> complete their thoughts; do not presume to end sentences for them. If
> you do not understand what has been said, admit it and ask for a
> repetition. If you are unsure, but think you understand part of what
> has been said, repeat what you thought you heard and ask for
> confirmation.
>
> 7\. People may have disabilities or combinations of disabilities that
> you are not familiar with. In those situations, remember to focus on
> the **person** first, not his or her disability. Use courtesy and
> common sense and ask the person with a disability for his or her
> advice on how to proceed.
>
> [What are some effective communication tips? (continued)]{.underline}
>
> 8\. Do not assume that all people with similar disabilities will want
> identical accommodations. If you are unsure of what to do, ask the
> person with a disability for guidance.

# L. What should program managers know with regard to building security, emergencies/building evacuations? {#l.-what-should-program-managers-know-with-regard-to-building-security-emergenciesbuilding-evacuations .Style1Yellow}

1.  Remember that individuals with hearing impairments may not be able
    to hear instructions by security personnel or broadcasts over the
    public address system. If you know of someone in your area who is
    deaf or hard of hearing, make sure that you pass along information
    about emergency situations.

2.  Before attempting to help people who are blind, introduce yourself
    and ask them if they would like assistance. If they accept your
    offer of help, allow them to take your arm; do not push or drag them
    along with you. If you are uncertain about what to do, ask the
    person how they would like to proceed.

3.  When giving directions in emergency or high stress situations, do
    not assume that people who are non-responsive are being
    uncooperative. People with hearing impairments may be unable to hear
    spoken instructions. Even people who have substantial residual
    hearing may have difficulty hearing instructions coming from behind
    them or orders given in areas with background noise such as fire
    alarms or the chatter from crowds of people.

> 4\. Some individuals with disabilities have assistive devices that are
> not easily removed. Some devices, such as cochlear implants to improve
> hearing or metal rods to strengthen bones are surgically implanted and
> cannot be taken off or detached. Be aware that such devices may set
> off metal detectors and be prepared to use courtesy and good judgment
> in dealing with such situations.
>
> 5\. When expecting individuals with disabilities, notify security so
> that they can be prepared to respond appropriately. This allows
> security officers to prepare themselves for alternative communication
> modes and reminds them to expect visitors with assistive devices that
> may require special handling when going through metal detectors.

# M. When are service animals, such as guide dogs, allowed in federally conducted programs and activities? {#m.-when-are-service-animals-such-as-guide-dogs-allowed-in-federally-conducted-programs-and-activities .Style1Yellow}

Service animals perform some of the functions and tasks that individuals
with disabilities cannot perform for themselves. For example, \"seeing
eye dogs\" are one type of service animal, used by some individuals who
are blind. This is the type of service animal with which most people are
familiar. However, there are service animals that assist persons with
other kinds of disabilities in their day-to-day activities. Some
examples include

[When are service animals, such as guide dogs, allowed in federally
conducted programs and activities? (continued)]{.underline}

alerting persons with hearing impairments to sounds; pulling wheelchairs
or carrying and picking up things for persons with mobility impairments;
and assisting persons with mobility impairments with balance.

Thus, the service animal must be permitted to accompany the individual
with a disability to all areas of the facility where people are normally
allowed to go. An individual with a service animal may not be segregated
from other customers.[^10]

Program managers should ensure that all staff is aware that service
animals are allowed in Federal buildings.

# N. How do you distinguish between a service animal and a pet? {#n.-how-do-you-distinguish-between-a-service-animal-and-a-pet .Style1Yellow}

Some, but not all, service animals wear special collars and harnesses.
Some, but not all, are licensed or certified and have identification
papers. If you are not certain that an animal is a service animal, you
may ask the person who has the animal if it is a service animal required
because of a disability. However, the individual may not have
documentation with them. Therefore, such documentation generally may not
be required as a condition for providing service to an individual
accompanied by a service animal. Although a number of states have
programs to certify service animals, you may not insist on proof of
state certification before permitting the service animal to accompany
the person with a disability.

# O. Who is responsible for the animal during the time it is on GSA property? {#o.-who-is-responsible-for-the-animal-during-the-time-it-is-on-gsa-property .Style1Yellow}

The care or supervision of a service animal is solely the responsibility
of his or her owner. You are not required to provide care or food or a
special location for the animal.

# P. What if a service animal barks or growls at other people, or otherwise acts out of control? {#p.-what-if-a-service-animal-barks-or-growls-at-other-people-or-otherwise-acts-out-of-control .Style1Yellow}

You may exclude any animal, including a service animal, from your
facility when that animal\'s behavior poses a direct threat to the
health or safety of others. For example, any service animal that
displays vicious behavior towards others may be excluded. You may not
make assumptions, however, about how a particular animal is likely to
behave based on your past experience with other animals. Although the
Agency may exclude any service animal that is out of control, we must
give the individual with a disability who uses the service animal the
option of continuing to participate in the GSA program/

activity without having the service animal on the premises. You can only
exclude the service animal in this situation, not its owner.

![](media/image2.png){width="0.5637795275590551in"
height="0.5637795275590551in"}![](media/image3.png){width="0.5618110236220473in"
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height="0.5618110236220473in"}![](media/image7.png){width="0.5637795275590551in"
height="0.5625984251968504in"}![](media/image8.png){width="0.5598425196850394in"
height="0.5618110236220473in"}![](media/image9.png){width="0.5618110236220473in"
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height="0.5610236220472441in"}![](media/image11.png){width="0.5220472440944882in"
height="0.49921259842519683in"}

# A. What is Section 508?  {#a.-what-is-section-508 .Style1Yellow}

[Section 508](http://www.section508.gov/) refers to a statutory section
in the Rehabilitation Act of 1973 (found at 29 U.S.C. 794d). Congress
significantly strengthened Section 508 in the Workforce Investment Act
of 1998. Its primary purpose is to provide access to and use of Federal
executive agencies' electronic and information technology (EIT) by
individuals with disabilities.

Section 508 requirements are separate from, but complimentary to,
requirements in [Sections 501 and
504](http://www.section508.gov/index.cfm?FuseAction=Content&ID=21) of
the Rehabilitation Act that require, among other things, that agencies
provide reasonable accommodations for employees with disabilities,
provide program access to members of the public with disabilities, and
take other actions necessary to prevent discrimination on the basis of
disability in their programs.

# B. What does Section 508 require with regard to the public? {#b.-what-does-section-508-require-with-regard-to-the-public .Style1Yellow}

Accessibility to EIT for individuals with disabilities. Members of the
public who have disabilities and are seeking information or services
from the Federal Government must have access to and use of information
and data that are comparable to that provided to members of the public
who do not have disabilities.

These requirements must be met unless GSA can prove that it would
experience an \"undue burden\" attempting to meet the law\'s
requirement. However, the program is still responsible for finding
alternative strategies to make information accessible to those with
disabilities.

# C. Are there regulations implementing Section 508? {#c.-are-there-regulations-implementing-section-508 .Style1Yellow}

Yes, there are two regulations addressing the requirements of Section
508.

> 1\. [Access Board Standards]{.underline}. The first regulation
> implementing Section 508 was issued by the Architectural and
> Transportation Barriers Compliance Board (the \"Access Board\"), an
> independent Federal agency, whose primary mission is to promote
> accessibility for individuals with disabilities. This regulation is
> referred to as the Access Board's \"standards.\" The standards are
> codified at [36 CFR Part
> 1194](http://www.access-board.gov/sec508/508standards.htm).
>
> 2\. [FAR Rule](http://www.arnet.gov/far/). The second regulation
> issued to implement Section 508 amends the Federal Acquisition
> Regulation (FAR) to ensure that agency acquisitions of EIT comply with
> the Access Board's standards. Section 508 affects *what* agencies
> acquire (i.e., the requirements development process), generally not
> *how* they acquire it (i.e., source selection). See FAR 7.103(o)
> (addressing acquisition planning), FAR 10.001(a)(3)(vii) (addressing
> market research), FAR 11.002(f) (addressing needs descriptions), FAR
> 12.202(d) (addressing requirements documents for commercial item
> acquisitions), and FAR Subpart 39.2 (addressing the acquisition of
> EIT).

# D. What is EIT? {#d.-what-is-eit .Style1Yellow}

EIT is information technology, as defined at FAR 2.101, and any
equipment or interconnected system or subsystem of equipment that is
used in the creation, conversion or duplication of data or information.
In addition to IT, EIT includes:

telecommunication products, such as telephones; information kiosks;
transaction machines; websites; multimedia (including videotapes); and
office equipment, such as copiers and fax machines.

# E. How is Section 508 enforced? {#e.-how-is-section-508-enforced .Style1Yellow}

> Congress provided that persons may file an administrative complaint
> with the Federal agency alleged to be in non-compliance with Section
> 508. Congress further provided that Section 508 complaints will be
> processed using Section 504 complaint processing guidelines. GSA's
> Interim 508 Complaint Processing Procedures are posted on the [Office
> of Civil Rights
> website.](http://www.gsa.gov/Portal/gsa/ep/programView.do?pageTypeId=8199&ooid=11553&programPage=%2Fep%2Fprogram%2FgsaDocument.jsp&programId=9612&channelId=-13328)

# F. Where can I learn more about Section 508's requirements? {#f.-where-can-i-learn-more-about-section-508s-requirements .Style1Yellow}

> Visit the Section 508 website at
> [http://www.section508.gov](http://www.section508.gov/).

![](media/image12.png){width="3.0729166666666665in" height="0.8125in"}

# A. What does Executive Order 13166 require? {#a.-what-does-executive-order-13166-require .Style1Orange}

Executive Order 13166 requires all Federal agencies to take reasonable
steps to provide meaningful access to their programs and activities
(i.e., federally conducted programs and activities) for individuals with
Limited English Proficiency (LEP).

# B. Who is an individual with LEP? {#b.-who-is-an-individual-with-lep .Style1Orange}

An individual with LEP is one who does not speak English as their
primary language and who has a limited ability to read, write, speak, or
understand English because of his/her national origin.

# C. Does Executive Order 13166 apply to Federal procurement procedures? {#c.-does-executive-order-13166-apply-to-federal-procurement-procedures .Style1Orange}

The removal of language barriers is not required in those programs where
English is an essential aspect of the program or a substantial
legitimate justification exists. Thus, current contracting procedures
under the Federal Acquisition Regulation (FAR) will not be altered by
Executive Order 13166 due to the large volume of Federal contracts that
require English as an essential part of the contracting process.

Therefore, based on GSA\'s assessment, procurement procedures will not
be modified due to the need to conduct contracting activities in the
English language, and the negligible number or proportion of contracting
entities who are LEP and are themselves attempting to find and respond
to announcements of contracts.

# D. What steps should program managers take to determine whether LEP assistance is required in a particular program/activity? {#d.-what-steps-should-program-managers-take-to-determine-whether-lep-assistance-is-required-in-a-particular-programactivity .Style1Orange}

Federal agencies are required to take reasonable steps to ensure
meaningful access to their programs and activities by LEP persons. While
designed to be a flexible and fact-dependent standard, the starting
point is an individualized assessment that balances the following four
factors. This framework was established by the U. S. Department of
Justice (DOJ) pursuant to Executive Order 13166 to guide Federal
agencies on the implementation of and compliance with the Order. DOJ's
guidance and other information/resources can be accessed at
http://www.lep.gov.

**Factor 1**. The number or proportion of eligible LEP persons. The
number or proportion of eligible LEP persons who will be excluded from
the federally conducted program or activity absent efforts to remove
language barriers is the first factor to consider. The key here is to
focus on persons eligible to use or access the particular program or
activity within the serviced area. This will narrow the scope to the
appropriate pool of eligible LEP persons.

[What steps should program managers take to determine whether LEP
assistance is required in a particular program/activity?
(continued)]{.underline}

Various resources are available to assist in determining the number or
proportion of eligible LEP persons in a given location. For example, a
program or activity that has contact with the general public may find
the local census data helpful in determining the LEP population. The
local Yellow Pages may assist in identifying organizations in the
community that represent ethnic populations in the area. These
organizations may be able to provide information regarding the English
proficiency of their represented communities. Other sources of
information in estimating the LEP population of a particular location
include local and State government offices, such as schools, Mayor\'s
office, elected officials, and the State\'s refugee resettlement office.
Health clinics, health care providers and hospitals may also be able to
provide LEP data, as they are required by law to provide language
services.

An example of a more narrow and targeted population is an outreach
program with small and disadvantaged businesses. The targeted group in
this example is the small and disadvantaged businesses in the area.
Thus, the local Small Business Administration (SBA) may be a good source
of information regarding LEP population(s) in this group.

**[Factor 2]{.underline}**. Frequency of contact. The frequency of
contact between the program or activity and eligible LEP persons is
another factor to be weighed. For example, if LEP persons access the
program or activity on a daily basis, there may be a greater
responsibility to provide more immediate LEP assistance through on-site
bilingual staff, than when such contact is unpredictable or infrequent.
When contact is unpredictable or infrequent, setting up a contract with
a language line service may be adequate, in lieu of having bilingual
staff available.

Although past experience may be helpful in determining the frequency of
contact, it should not be used as the exclusive criteria because the
lack of prior notice regarding the availability of LEP assistance may
have contributed to such minimal or non-existent contact.

**[Factor 3]{.underline}**. Nature and importance of the program or
activity. The nature and importance of a particular program or activity
to the serviced population will affect the determination of the types of
LEP assistance provided. More affirmative steps are required in those
programs where the denial or delay of access may have health, safety or
welfare implications than in programs that are not as crucial to one's
day-to-day existence. For example, the nature and importance of access
to a Federal building that houses agencies such as the Departments of
Health and Human Services or Immigration and Naturalization Service
differs from access to an auction of used vehicles or a tour of a
building.

Program officials must also consider both the short and long-term
effects, if any, of not providing LEP assistance to the eligible LEP
population.

[What steps should program managers take to determine whether LEP
assistance is required in a particular program/activity?
(continued)]{.underline}

**[Factor 4]{.underline}**: Availability of resources. Generally, the
availability of resources may have an impact on the types of LEP
assistance to be provided and the nature of the steps to be taken. For
instance, the availability of resources may affect the kinds of LEP
assistance provided where the total costs of providing language
assistance is relatively high and/or where the program is not crucial to
an individual\'s day-to-day existence. However, where there is an LEP
responsibility, the lack of financial resources will be difficult to
justify by a Federal agency program, in light of the budgeting process.

# E. What are the next steps if the four-factor analysis indicates that some form of LEP assistance is required? {#e.-what-are-the-next-steps-if-the-four-factor-analysis-indicates-that-some-form-of-lep-assistance-is-required .Style1Orange}

1\. Develop tailored procedures to address LEP responsibilities, based
on both oral and written communications used in the program. These
procedures need not be intricate where the number or frequency of
contact is small in number, and may be as simple as being prepared to
use one of the commercially available language lines to obtain
interpreter services within a reasonable period of time. However, more
affirmative steps may be appropriate where there are a larger number of
LEP persons, the frequency of contact with LEP persons is more often,
and/or the importance of the program or activity affects the day-to-day
safety/existence of the serviced population.

2\. Train the program staff. Such procedures will be effective only if
the staff understands the reason for LEP procedures and how to use them.
A very important part of implementation is to ensure that program staff
is knowledgeable of the Agency's LEP responsibilities and the specific
program procedures established to provide LEP assistance. The LEP
responsibilities and procedures should also be included as part of any
new associate orientation.

3\. Notify the LEP population that you serve. Written notice should be
provided to the LEP population(s) regarding the availability of LEP
assistance at no cost to the LEP person. This may be done through the
use of a brochure or poster in the relevant language(s), placed in a
conspicuous place to ensure that LEP persons will see it. It may also
include posting such notice on websites applicable to the specific
program or activity. Written postings should be placed in waiting rooms,
reception areas or initial points of entry. Sample language that may be
used as an appropriate notice is as follows: \"Language assistance is
available upon request if you cannot speak or write English very well.\"

4\. Monitor effectiveness of LEP procedures on a periodic basis. LEP
assistance requirements may change over a period of time. It is
recommended to monitor on an annual basis, which should include an
evaluation of current LEP population in the

> service area, and a review of LEP policies, procedures and practices
> with the program staff. Feedback from the LEP population will also be
> useful.

# F. What are some examples in applying the four-factor analysis? {#f.-what-are-some-examples-in-applying-the-four-factor-analysis .Style1Orange}

The following examples are provided to discuss application of the four
factors to specific fact situations:

**Example 1**: A regional Office of Enterprise Development (OED)
conducts four informational presentations per year about contracting
opportunities available to small and disadvantaged businesses throughout
its region. On an occasional basis, LEP persons are encountered, all of
which have been in need of Spanish language assistance. Local SBA data
reflects that there is three small businesses in the area are LEP and
speak Spanish. OED has provided timely translation assistance through
the use of bilingual GSA associates in the past. Informational program
brochures are also translated in Spanish. No problems have been reported
in the past regarding LEP assistance.

**[Application of the four factors to Example 1]{.underline}**:

[Factor 1]{.underline}: The number of small businesses (OED's targeted
audience) with LEP needs is few, and past experience reflects an
occasional request for language assistance. Current population
information for eligible small and disadvantaged businesses in the
targeted area shows no significant change in the LEP population;

[Factor 2]{.underline}: The informational presentations occur four times
per year, with past experience showing an occasional LEP contact;

[Factor 3]{.underline}: OED\'s presentations provide the targeted
audience with information pertaining to contracting opportunities with
the Federal Government, eligibility criteria and information about the
procurement process. Failure to provide appropriate LEP assistance may
prevent or limit access to the program that is related to livelihood;

[Factor 4]{.underline}: Generally, where there is an LEP responsibility,
the lack of financial resources will be difficult to justify by a
Federal agency program, in light of the budgeting process. However, in
this scenario, OED has an arrangement with the local Hispanic
organization that has offered to provide language assistance, and the
regional GSA office has three bilingual employees that speak fluent
Spanish and are considered competent interpreters. OED will probably be
viewed as being in compliance with Executive Order 13166.

**Example 2**. A private contractor provides security for one of GSA's
buildings in a large metropolitan area where the surrounding population
has 12,500 Spanish-speaking only and 3000 Chinese-speaking only persons.
Federal agency tenants in the buildings consist of the Immigration and
Naturalization Service, the Internal Revenue Service, and the Social
Security Administration. The contractor has six (6) bilingual security
guards that speak Spanish, where at least two (2)

[What are some examples in applying the four-factor analysis?
(continued)]{.underline}

of them are on duty at any given time. A local Chinese immigrant
organization has volunteered to provide language assistance in the
community. No complaints of inadequate LEP assistance have been made in
the past**.**

[***Application of the four factors to Example 2***:]{.underline}

[Factor 1]{.underline}: The number or proportion of persons who may be
excluded (i.e., denied access to important Federal services in the
building) absent efforts to offer translation assistance is relatively
significant;

[Factor 2]{.underline}: The possibility exists for both Spanish and
Chinese-speaking persons to seek entrance into the building on a daily
basis;

[Factor 3]{.underline}: The importance of the federally conducted
programs/activities inside the building relate to a person\'s day-to-day
existence (i.e., immigration, social security, and taxes) and is
significant considering the nature of the tenants\' operations;

[Factor 4]{.underline}. GSA should make appropriate arrangements to
ensure both Spanish and Chinese-speaking persons (who are LEP) have
meaningful access. This may be accomplished by posting signs in Spanish
and Chinese, explaining the procedure for checking bags and going
through the metal detector, along with vital documents translated and
placed in plain view for easy access. Another option to consider in this
scenario could be making arrangements with tenant agencies for the use
of their language assistance services and a standing contract with a
language line service as backup.

Note: Once the LEP person accesses one of the tenant agencies' programs,
GSA's LEP responsibilities end and the tenant agencies' LEP
responsibilities begin.

# G. What are some considerations in providing language assistance?  {#g.-what-are-some-considerations-in-providing-language-assistance .Style1Orange}

If after completing the four-factor analysis, you determine that
language assistance is required, you need to look to what mix of written
and oral language assistance is required to provide meaningful access to
your program.

> 1\. [Oral interpretation]{.underline}. Depending on the need, options
> for providing oral interpretation range from hiring bilingual staff or
> on-staff interpreters, contracting for interpreter services as needed,
> engaging community volunteers, or
>
> contracting with telephone interpreter services (i.e., language line).
> Oral communication between program staff and the serviced population
> often is a necessary part of the exchange of information. Proper
> analysis should include identifying the kind of communication (oral or
> written) that is normally provided to an English speaking person in
> order to fully communicate the program to them.

[What are some considerations in providing language assistance?
(continued)]{.underline}

> 2\. [Written Translation]{.underline}. In determining what written
> information or documents should be translated, vital documents and
> non-vital documents should be identified.
>
> a\. Vital documents must be translated when a significant number or
> percentage of the eligible population needs information or assistance
> in a language other than English in order to communicate
> effectively*.* [A document or information will be considered vital if
> it contains information that is critical for accessing the agency\'s
> program(s) and/or activities, or is required by law]{.underline}.
> Thus, vital documents include, for example, applications; consent
> forms; letters and notices pertaining to the reduction, denial or
> termination of access to a program; and letters or notices that
> require a response from the individual seeking access. Non-vital
> documents need not be translated.
>
> b\. For many larger documents (i.e., regulations, handbooks)
> translation of only the vital information within the document is
> appropriate (i.e., a translated summary), as opposed to translating
> the entire document. It may be difficult to distinguish between vital
> and non-vital documents especially when considering outreach or
> awareness documents. Although meaningful access to a program requires
> an awareness of the program\'s existence, translating every piece of
> outreach material into every language may not be practical or
> cost-effective. Thus, it is important to continually assess the needs
> of the program population to determine whether certain critical
> outreach materials should be translated into other languages.
>
> c\. The same analysis is to be used in determining the translation of
> website information, forms, etc. The decision to place an agency\'s
> information on the Internet will not affect whether the document must
> be translated. For example, placement on the website should not change
> the agency\'s original assessment regarding the number or proportion
> of LEP persons that comprise the intended
>
> audience for that document or information. Generally, entire website
> need not be translated.
>
> d\. Where the frequency of contact is unpredictable and minimal, or
> the number or proportion of eligible LEP persons is small, oral
> translation of vital documents may be used in lieu of written
> translation. Oral translation assistance must also be provided to
> those persons who are LEP whose language does not exist in written
> form. This oral translation assistance will explain the contents of
> vital documents.

# H. How do I ensure reliability of translation and interpretive services? {#h.-how-do-i-ensure-reliability-of-translation-and-interpretive-services .Style1Orange}

In order to provide effective services to LEP persons, it is important
to ensure the use of competent interpreters and translators. Although it
is not a requirement, membership in or accreditation by the American
Translators Association (ATA) is one indicator regarding the reliability
and professionalism of language assistance vendors. However, competency
does not necessarily mean formal certification as an interpreter,
although certification is helpful.

Competency refers to more than being bilingual. It refers to
demonstrated proficiency in both English and the other language,
orientation and training that includes the skills and ethics of
interpreting (i.e., issues of confidentiality), fundamental knowledge in
both languages of terms or concepts peculiar to the program or activity,
and sensitivity to the LEP person\'s culture.

It is also important to note that in some circumstances verbatim
translation of materials may not accurately and appropriately convey the
substance of what is contained in the written language. An effective way
to address this concern is to reach out to community-based organizations
to review translated materials to ensure that the translation is
accurate and easily understood by LEP persons.

To ensure the reliability of translated documents of a highly technical
or complex nature, it is recommended that a different contractor conduct
a second review of the document, as translated. Another recommendation
is to have the document translated back into English to determine if the
source document lost important meaning due to the foreign translation.

# I. Can I require the LEP individual to provide his/her own interpreter? {#i.-can-i-require-the-lep-individual-to-provide-hisher-own-interpreter .Style1Orange}

It is not good practice to require the LEP person to provide his/her own
translation services (i.e., interpreter). Requiring an eligible LEP
person to provide his/her interpreter may sometimes leave the LEP person
no choice but to ask a friend, relative or stranger to translate program
information. This may put the LEP person in an uncomfortable situation
where the interpreter may not have formal training or an obligation to
observe confidentiality. Such an interpreter may not possess adequate
language and comprehension skills, and his/her presence may actually
obstruct the flow of critical program information. The LEP person may
also be naturally reluctant to be forthcoming with personal information
where the interpreter is his/her child or other relative,
friend/neighbor or a stranger. Therefore, it is not good practice to
require the LEP person to provide his/her own translation services,
unless the LEP person is the one that requests the use of his/her own
interpreter. In the instance where the LEP

person requests use of his/her own interpreter, the program official may
consider having an agency interpreter present if the subject relates to
a legal or technical matter.

# J. Is there a list of language assistance vendors available? {#j.-is-there-a-list-of-language-assistance-vendors-available .Style1Orange}

Yes, [GSA Language Services
Schedule](http://www.gsa.gov/Portal/gsa/ep/programView.do?pageTypeId=8211&ooid=10122&programPage=%2Fep%2Fprogram%2FgsaDocument.jsp&programId=8640&channelId=-13004)
provides program officials with the ability to acquire multilingual
translation services in native languages to include, but not limited to,
the translation of business, legal, medical, technical documents,
software, manuals, web sites, Intranet, video and audio in written,
graphic, electronic, multi-media and various other forms of
communication. It also provides multilingual interpretation services in
native languages for meetings, conferences, seminars, litigation
proceedings, briefings, training, escort and various other forums of
voice communications.

Translated documents should include the following statement on the front
page both in English and in the language of translation: \"This is a
translation of an English-language document provided as a courtesy to
those not fluent in English. If differences or any misunderstandings
occur, the document of record shall be the related English-language
document. English is the only language of official record.\"

# K. Must documents requested through FOIA or Privacy Act be translated?  {#k.-must-documents-requested-through-foia-or-privacy-act-be-translated .Style1Orange}

Executive Order 13166 has little impact on the processing of requests
under the FOIA or Privacy Act laws. For instance, neither FOIA nor the
Privacy Act requires an agency to create a document that does not
currently exist. When, for instance, a requested document is illegible
due to poor copy quality, a copy of the document is provided, indicating
that it is the best available copy. When poor handwriting makes a
document difficult to read, an agency is not required to try and
reconstruct or \"translate\" that handwriting. When a document is in a
foreign language, it is not required to translate the document for the
requester (although an internal translation may be necessary in order to
assure that the record does not contain sensitive material).

# L. What are some other LEP Resources? {#l.-what-are-some-other-lep-resources .Style1Orange}

> 1\. [http://www.lep.gov](http://www.lep.gov/) website.
>
> 2\. The [GSA Language Services
> Schedule](http://www.gsa.gov/Portal/gsa/ep/programView.do?pageTypeId=8211&ooid=10122&programPage=%2Fep%2Fprogram%2FgsaDocument.jsp&programId=8640&channelId=-13004),
> Federal Supply Schedule 738 II, provides contract support for
> translation, interpretation, and language training and/or educational
> materials.
>
> 3\. [\"I Speak\"
> card](http://www.usdoj.gov/crt/cor/Pubs/ISpeakCards.pdf): The U. S.
> Department of Commerce has made available to all Federal agencies the
> "I Speak" language card, which was used by the Census Bureau during
> the 2000 Census. Program managers are encouraged to use the card to
> assist them in identifying the language spoken by a "walk-in" that
> does not speak English.
>
> ![](media/image12.png){width="3.0729166666666665in" height="0.8125in"}

# A. What does Executive Order 13160 require? {#a.-what-does-executive-order-13160-require .Style1Orange}

Executive Order 13160 requires Federal agencies to ensure equal
opportunity in federally conducted training and education programs on
the basis of race, sex, color, national origin, disability, religion,
age, sexual orientation, and status as a parent.

# B. What are the types of GSA programs and activities covered by Executive Order 13160? {#b.-what-are-the-types-of-gsa-programs-and-activities-covered-by-executive-order-13160 .Style1Orange}

Executive Order 13160 covers education and training programs or
activities that are conducted by GSA.

# C. What are some examples of covered education and training programs at GSA? {#c.-what-are-some-examples-of-covered-education-and-training-programs-at-gsa .Style1Orange}

Programs and activities that fall within the scope of the Executive
Order include, but are not limited to, school partnership agreements,
student internships, scholarships, executive training programs,
workshops for small businesses, PBS Academy, and temporary student
employment activities.

# D. How will complaints under Executive Order 13160 be processed? {#d.-how-will-complaints-under-executive-order-13160-be-processed .Style1Orange}

Executive Order 13160 provides for filing of complaints by any
individual who believes he or she has been discriminated against in
violation of the nondiscrimination provisions of the Executive Order. To
this effect, GSA is obligated to investigate complaints that allege a
violation of the Executive Order, if the complaint cannot be resolved
through alternative dispute resolution.

Complaints filed by GSA employees or applicants for employment will
generally be processed according to the Equal Employment Opportunity
Commission discrimination complaint procedures, located at 29 CFR 1614.

Complaints filed by members of the public or employees of another
Federal agency will be processed by the Office of Civil Rights. For more
information, contact the Office of Civil Rights at <OCR@gsa.gov>.

# E. Is there any guidance that further explains the Order? {#e.-is-there-any-guidance-that-further-explains-the-order .Style1Orange}

Yes, the U. S. Department of Justice (DOJ) issued detailed
[guidance](http://www.usdoj.gov/crt/cor/Pubs/13160guid.pdf) to assist
Federal agencies in complying with the Order.

APPENDIX A

Program Access: Structural Checklist

The following checklists were prepared to assist program managers at GSA
in conducting a self-evaluation of the physical aspects of his/her
program and/or activity:

1.  Physical Accessibility: Rooms and Spaces

2.  Physical Accessibility: Assembly Rooms

3.  Physical Accessibility: Doors and Gates

4.  Physical Accessibility: Signage

5.  Physical Accessibility: Seating, Tables and Work Surfaces

The checklists are for the use of program managers whose programs and/or
activities occupy space within a larger facility.

Generally, program managers are only required to conduct a
self-evaluation of the space that is physically occupied by his/her
programs/activities---where such programs and/or activities are located
within a larger Federal facility. Therefore, this handout omits
checklists related to other elements of structural accessibility---i.e.,
parking, the accessible route of travel from the street/sidewalk, main
entrance, elevators, restrooms and common areas of buildings.

Those managers whose program areas include the main entrance to the
facility, elevator(s), restroom(s), public telephone, drinking
fountains, and/or common areas of buildings should refer to the
[UFAS](http://www.access-board.gov/ufas/ufas-html/ufas.htm) and the
[UFAS checklist](http://www.access-board.gov/ufas/UFASchecklist.txt).
They may be viewed on the U. S. Architectural and Transportation
Standards Board's (i.e., Access Board) website at
http://www.access-board.gov.

Remember, the primary goal is to provide meaningful access to
individuals with disabilities.

**[Areas of a building within a program manager(s) space]{.underline}**:

> Each program manager is responsible for evaluating the area of space
> that is occupied by his/her program or activity, if open to the
> public. Where access is not readily achievable and the structure
> requires modification(s) to make it readily accessible to and usable
> by individuals with disabilities, the program manager must:

1.  Develop a transition plan, identifying the defect(s) and the steps
    that will be required to make the feature accessible and implement;

2.  Relocate the program or activity; or

3.  Develop alternative means to ensure meaningful access for
    individuals with disabilities.

**[Areas of a building not within a program manager(s)
space]{.underline}**:

1\. [Lack of physical access due to a structural barrier:]{.underline}
Where a program manager has been advised of or has personally identified
an area outside of his /her program's space as inaccessible (i.e.,
parking, elevators, main entrance into the building, sidewalk outside of
building), (s)he should report it immediately to his/her regional
accessibility officer.

2\. [Lack of physical access due to a non-structural
barrier]{.underline}: Where a program manager becomes aware of an area
outside of his/her program's space---but still within the same
facility\--as being inaccessible due to a non-structural, physical
barrier (such as boxes, furniture, slippery floors, etc.), (s)he should
report it immediately to the building manager.

**[Definitions]{.underline}**:

1\. [Accessible]{.underline}: Describes a site, building, facility, or
portion thereof that complies with these standards and that can be
approached, entered, and used by individuals with disabilities.

2\. [Accessible Route]{.underline}: A continuous unobstructed path
connecting all accessible elements and spaces in a building or facility.
Interior accessible routes may include corridors, floors, ramps,
elevators, lifts, and clear floor space at fixtures. Exterior accessible
routes may include parking access aisles, curb ramps, walks, ramps, and
lifts.

3\. [Access Aisle]{.underline}: An accessible pedestrian space between
elements, such as, parking spaces, seating, and desks, that provide
clearances appropriate for use of the elements.

4\. [Assembly Area]{.underline}: A room or space accommodating fifty or
more individuals for religious, recreational, educational, political,
social, or amusement purposes, or for the consumption of food and drink,
including all connected rooms or spaces with a common means of egress
and ingress. Such areas as conference rooms would have to accessible in
accordance with other parts of the UFAS, but would not have to meet all
of the criteria associated with assembly areas.

5\. [Common Use]{.underline}*:* Refers to those interior and exterior
rooms, spaces, or elements that are made available for the use of a
restricted group of people (for example, residents of an apartment
building, the occupants of an office building, or the guests of such
residents or occupants.

6\. [Element]{.underline}: An architectural or mechanical component of a
building, facility, space, or site, e.g., telephone, curb ramp, door,
drinking fountain, seating, water closet.

7\. [Entrance]{.underline}: Any access point to a building or portion of
building or facility used for the purpose of entering. An entrance
includes the approach walk, the vertical access leading to the entrance
platform, the entrance platform itself, vestibules if provided, the
entry door(s) or gate(s), and the hardware of the entry door(s) or
gate(s). The principal entrance of a building or facility is the main
door through which most people enter.

**Physical Accessibility**

**Survey Form: Rooms and Spaces**

**Name of
Program/Activity:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**Room or Space
Location:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**City/State:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**Name of Person Conducting
Evaluation:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

+-----------------------------+-----------+----------+-----------------+
| **Question**                | **UFAS**  | **Yes or | **Comment**     |
|                             |           | No N/A** |                 |
|                             | **Re      |          |                 |
|                             | ference** |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 1\. Do the doors comply     | 4.13      |          |                 |
| with 4.13? (Use Survey Form |           |          |                 |
| 9: Doors and Gates to       |           |          |                 |
| determine compliance        |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 2a. Are aisles at least 36  | 4.3.3     |          |                 |
| inches wide except at doors |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 2b. Where the accessible    | 4.3.3     |          |                 |
| pathway makes a U-turn      |           |          |                 |
| around an obstacle which is |           |          |                 |
| less than 48 inches wide,   |           |          |                 |
| does the pathway width      |           |          |                 |
| increase to at least 42     |           |          |                 |
| inches on the approach and  |           |          |                 |
| 48 inches in the turn?      |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 3\. If the aisles are less  | 4.3.4     |          |                 |
| than 60 inches wide, are    |           |          |                 |
| there passing spaces at     |           |          |                 |
| least 60 inches wide and 60 |           |          |                 |
| inches long within          |           |          |                 |
| reasonable intervals not    |           |          |                 |
| exceeding 200 feet?         |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 4a. Is there at least 80    | 4.3.5     |          |                 |
| inches clear head room in   |           |          |                 |
| the accessible space?       |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 4b. If head room in part of |           |          |                 |
| an accessible space is less |           |          |                 |
| than 80 inches, is there a  |           |          |                 |
| cane detectable barrier     |           |          |                 |
| within 27 inches of the     |           |          |                 |
| floor?                      |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 5a. If objects mounted to   | 4.4.1     |          |                 |
| the wall have bottom edges  |           |          |                 |
| between 27 and 80 inches    |           |          |                 |
| from the floor, do they     |           |          |                 |
| project less than 4 inches  |           |          |                 |
| into the space? (Wall       |           |          |                 |
| mounted objects with bottom |           |          |                 |
| edges below 27 inches may   |           |          |                 |
| project any amount so long  |           |          |                 |
| as they do not reduce the   |           |          |                 |
| required clear width of an  |           |          |                 |
| accessible route of         |           |          |                 |
| travel.)                    |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 5b. Do free standing        |           |          |                 |
| objects mounted on posts    |           |          |                 |
| with bottom edges between   |           |          |                 |
| 27 and 80 inches high       |           |          |                 |
| project less than 12 inches |           |          |                 |
| into the route of travel?   |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 5c. Is there an accessible  |           |          |                 |
| path of at least 36 inches  |           |          |                 |
| clear alongside the         |           |          |                 |
| protruding object?          |           |          |                 |
+-----------------------------+-----------+----------+-----------------+

**Page 2**

**Physical Accessibility**

**Survey Form: Rooms and Spaces**

+-----------------------------+-----------+----------+-----------------+
| **Question**                | **UFAS**  | **Yes or | **Comment**     |
|                             |           | No N/A** |                 |
|                             | **Re      |          |                 |
|                             | ference** |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 6\. Are the floors in all   | 4.5.1     |          |                 |
| accessible rooms and spaces |           |          |                 |
| stable, firm, and           |           |          |                 |
| slip-resistant?             |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 7a. Is any level change     | 4.3.8;    |          |                 |
| greater than 1/2 inch       | 4.5.2     |          |                 |
| ramped?                     |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 7b. When floor materials    |           |          |                 |
| change, does the vertical   |           |          |                 |
| difference between them     |           |          |                 |
| meet these provisions?      |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 7c. If carpet or carpet     |           |          |                 |
| tile is used on the floor,  |           |          |                 |
| is it securely attached?    |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 7d. Is it a low pile type   |           |          |                 |
| of carpet with a firm pad   |           |          |                 |
| or no pad underneath it?    |           |          |                 |
+-----------------------------+-----------+----------+-----------------+

**Physical Accessibility**

**Survey Form: Doors and Gates**

**Name of
Program/Activity:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**Room or Space
Location:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**City/State:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**Name of Person Conducting
Evaluation:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

+-----------------------------+-----------+----------+-----------------+
| **Question**                | **UFAS**  | **Yes or | **Comment**     |
|                             |           | No N/A** |                 |
|                             | **Re      |          |                 |
|                             | ference** |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 1\. If a revolving door or  | 4.13.2    |          |                 |
| turnstile is used on an     |           |          |                 |
| accessible route, is an     |           |          |                 |
| accessible door or gate     |           |          |                 |
| provided to facilitate the  |           |          |                 |
| same use                    |           |          |                 |
|                             |           |          |                 |
| pattern?                    |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 2\. Do all gates including  | 4.13.3    |          |                 |
| ticket gates meet all the   |           |          |                 |
| applicable specifications   |           |          |                 |
| for doors?                  |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 3\. If the doorway has two  | 4.13.4    |          |                 |
| independently operated door |           |          |                 |
| leaves, does at least one   | Also see  |          |                 |
| active leaf provide a 32    | Fig. 25   |          |                 |
| inch clear opening width &  |           |          |                 |
| maneuvering space as shown  |           |          |                 |
| in Figure 25 of UFAS?       |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 4a. When a door is open 90  | 4.13.5    |          |                 |
| degrees, is there a clear   |           |          |                 |
| opening at least            |           |          |                 |
|                             |           |          |                 |
| 32 inches measured between  |           |          |                 |
| the face of the door and    |           |          |                 |
| the door stop on the        |           |          |                 |
|                             |           |          |                 |
| latch side?                 |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 4b. If the door does not    |           |          |                 |
| require full user passage,  |           |          |                 |
| such as a shallow closet,   |           |          |                 |
| is the clear opening at     |           |          |                 |
| least 20 inches?            |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 5a. If the door is not      | 4.13.6    |          |                 |
| automatic or power          |           |          |                 |
| assisted, does it have      |           |          |                 |
| maneuvering space relative  |           |          |                 |
| to the direction of         |           |          |                 |
| approach as shown in Figure |           |          |                 |
| 25?                         |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 5b.. Is the floor level and |           |          |                 |
| clear within the required   |           |          |                 |
| maneuvering space?          |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 6a. If there are two doors  | 4.13.7    |          |                 |
| in series, is the clear     |           |          |                 |
| space between the walls at  |           |          |                 |
| either end of the vestibule |           |          |                 |
| at least 48 inches plus the |           |          |                 |
| width of the door?          |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 6b. Do the doors in the     |           |          |                 |
| series swing in the same    |           |          |                 |
| direction? OR               |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 6c. Do they swing away from |           |          |                 |
| the space between them?     |           |          |                 |
+-----------------------------+-----------+----------+-----------------+

**Page 2**

**Physical Accessibility**

**Survey Form: Doors and Gates**

+-----------------------------+-----------+----------+-----------------+
| **Question**                | **UFAS**  | **Yes or | **Comment**     |
|                             |           | No N/A** |                 |
|                             | **Re      |          |                 |
|                             | ference** |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 7a. If there is a raised    | 4.13.8    |          |                 |
| threshold, is it beveled at |           |          |                 |
| 1:2 or less?                |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 7b. Is the threshold no     |           |          |                 |
| higher than 1/2 inch?       |           |          |                 |
| (Exception: An exterior     |           |          |                 |
| sliding door can have a 3/4 |           |          |                 |
| inch threshold.)            |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 8a. Are all handles, locks, | 4.13.9    |          |                 |
| and latches operable with   |           |          |                 |
| one hand? Are they operable |           |          |                 |
| without tight pinching,     |           |          |                 |
| tight grasping or twisting  |           |          |                 |
| of the wrist?               |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 8b. If there are sliding    |           |          |                 |
| doors, is the operating     |           |          |                 |
| hardware exposed and usable |           |          |                 |
| from both sides when the    |           |          |                 |
| doors are fully open?       |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 8c. Is the hardware mounted |           |          |                 |
| no higher than 48 inches    |           |          |                 |
| above floor level?          |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 9\. If the door has a       | 4.13.10   |          |                 |
| closer, does it take at     |           |          |                 |
| least three seconds to move |           |          |                 |
| from 70 degrees open to a   |           |          |                 |
| point 3 inches from the     |           |          |                 |
| latch?                      |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 10\. Do interior doors have | 4.13.11   |          |                 |
| an opening force of 5 lbs   |           |          |                 |
| or less?                    |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 11\. Are doors to hazardous | 4.13.9;   |          |                 |
| areas identifiable to the   | 4.29.3    |          |                 |
| touch by a textured surface |           |          |                 |
| on the door handle, knob,   |           |          |                 |
| pull, or other operating    |           |          |                 |
| hardware?                   |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
|                             |           |          |                 |
+-----------------------------+-----------+----------+-----------------+

**Physical Accessibility Survey**

**Survey Form: Signage**

**Name of
Program/Activity:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**Room or Space
Location:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**City/State:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**Name of Person Conducting
Evaluation:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

+-----------------------------+-----------+----------+-----------------+
| **Question**                | **UFAS**  | **Yes or | **Comment**     |
|                             |           | No N/A** |                 |
|                             | **Re      |          |                 |
|                             | ference** |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 1a. On room signs, do the   | 4.1.1(7); |          |                 |
| letters and numbers have a  | 4.30.2    |          |                 |
| width to height ratio       |           |          |                 |
| between 3:5 and 1:1, and a  |           |          |                 |
| stroke width-to-height      |           |          |                 |
| ratio between 1:5 and 1:10? |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 1b. Does the color of the   |           |          |                 |
| characters and symbols      |           |          |                 |
| contrast with the color of  |           |          |                 |
| the background?             |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 2\. Does the color of the   | 4.30.3    |          |                 |
| characters and symbols      |           |          |                 |
| contrast with the color of  |           |          |                 |
| the background?             |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 3a. Do signs providing      | 4         |          |                 |
| permanent identification of | .1.2(15); |          |                 |
| rooms and spaces have       | 4.30.4    |          |                 |
| raised letters?             |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 3b. Are they mounted on the |           |          |                 |
| wall at the latch side of   |           |          |                 |
| the door between 54 and 66  |           |          |                 |
| inches above the floor?     |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 3c. Are the characters sans |           |          |                 |
| serif?                      |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 3d. Are the characters and  |           |          |                 |
| symbols on signs raised     |           |          |                 |
| 1/32 inch?                  |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 3e. Are the raised          |           |          |                 |
| characters or symbols       |           |          |                 |
| between 5/8 inch and 2      |           |          |                 |
| inches tall?                |           |          |                 |
+-----------------------------+-----------+----------+-----------------+

**Physical Accessibility Survey**

**Survey Form: Seating, Tables and Work Surfaces**

**Name of
Program/Activity:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**Room or Space
Location:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**City/State:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**Name of Person Conducting
Evaluation:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

+-----------------------------+-----------+----------+-----------------+
| # Question                  | **UFAS**  | **Yes or | **Comment**     |
|                             |           | No N/A** |                 |
|                             | **Re      |          |                 |
|                             | ference** |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 1\. Do 5% (but not less     | 4.1.2(17) |          |                 |
| than one) of the built-in   |           |          |                 |
| or fixed seating tables and |           |          |                 |
| work surfaces meet the      |           |          |                 |
| following requirements?     |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 2a. Do the seating spaces   | 4.32.2;   |          |                 |
| which are provided for      | 4.2.4     |          |                 |
| people in wheelchairs have  |           |          |                 |
| a 30 x 48 inch clear space  |           |          |                 |
| which overlaps an           |           |          |                 |
| accessible route?           |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 2b. Is no more than 19      |           |          |                 |
| inches of the 30 x 48 inch  |           |          |                 |
| clear space measured under  |           |          |                 |
|                             |           |          |                 |
| the table?                  |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 3\. Is the knee space at    | 4.32.3    |          |                 |
| least 27 inches high, 30    |           |          |                 |
| inches wide, and 19 inches  |           |          |                 |
| deep?                       |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 4\. Is the top of the table | 4.32.4    |          |                 |
| or work surface between 28  |           |          |                 |
| and 34 inches from the      |           |          |                 |
| floor?                      |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 5 Are the aisles between    | 4.3.3     |          |                 |
| tables at least 36 inches   |           |          |                 |
| wide?                       |           |          |                 |
+-----------------------------+-----------+----------+-----------------+

**Physical Accessibility Survey**

**Survey Form: Assembly Rooms (Use in conjunction with "Rooms and
Spaces")**

**Name of
Program/Activity:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**Room or Space
Location:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**City/State:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**Name of Person Conducting
Evaluation:\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

+-----------------------------+-----------+----------+-----------------+
| # Question                  | **UFAS**  | **Yes or | **Comment**     |
|                             |           | No N/A** |                 |
|                             | **Re      |          |                 |
|                             | ference** |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 1\. Is the required number  | 4.33.1;   |          |                 |
| of wheelchair locations in  | 4.1.2(18) |          |                 |
| assembly spaces provided?   |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 2a. Is the space for 2      | 4.33.2    |          |                 |
| wheelchairs 66 inches wide? |           |          |                 |
| (Please note: There is no   |           |          |                 |
| requirement that wheelchair |           |          |                 |
| spaces must be paired.)     |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 2b. If people must wheel    |           |          |                 |
| into the space from the     |           |          |                 |
| side, are the spaces at     |           |          |                 |
| least 60 inches deep?       |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 3\. If people can wheel     | 4.33.3    |          |                 |
| into the space from in      |           |          |                 |
| front or behind the space,  |           |          |                 |
| are the spaces 48 inches    |           |          |                 |
| deep?                       |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 4\. Are they dispersed      |           |          |                 |
| throughout the seating      |           |          |                 |
| area? (Exception:           |           |          |                 |
| Accessible                  |           |          |                 |
|                             |           |          |                 |
| viewing positions may be    |           |          |                 |
| clustered for bleachers,    |           |          |                 |
| balconies, and other areas  |           |          |                 |
| having sight lines which    |           |          |                 |
| require slopes greater than |           |          |                 |
| 5%.)                        |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 5\. Do they adjoin an       |           |          |                 |
| accessible route that also  |           |          |                 |
| serves as a means of egress |           |          |                 |
| in an emergency?            |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 6\. Are the sightlines from |           |          |                 |
| these seating areas         |           |          |                 |
| comparable to those for all |           |          |                 |
| viewing areas?              |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 7a. Are the floor surfaces  | 4.33.4;   |          |                 |
| at and around these seating | 4.5       |          |                 |
| areas level, stable, firm,  |           |          |                 |
| and slip-resistant?         |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 7b. Are level changes       |           |          |                 |
| greater than 1/2 inch       |           |          |                 |
| ramped?                     |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 7c. Are level changes       |           |          |                 |
| between 1/4 and 1/2 inch    |           |          |                 |
| beveled with a maximum      |           |          |                 |
| slope of 1:2?               |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 7d. If carpet is used in    |           |          |                 |
| the area, is it a low pile  |           |          |                 |
| type with firm padding or   |           |          |                 |
| no padding underneath it?   |           |          |                 |
+-----------------------------+-----------+----------+-----------------+

**Page 2**

**Physical Accessibility Survey**

**Survey Form: Assembly Rooms (Use in conjunction with "Rooms and
Spaces")**

+-----------------------------+-----------+----------+-----------------+
| # Question                  | **UFAS**  | **Yes or | **Comment**     |
|                             |           | No N/A** |                 |
|                             | **Re      |          |                 |
|                             | ference** |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 7e. Where floor materials   |           |          |                 |
| change, is the vertical     |           |          |                 |
| difference between them     |           |          |                 |
| less than 1/4 inch?         |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 7f. If the vertical         |           |          |                 |
| difference is between 1/4   |           |          |                 |
| and 1/2 inch, is it beveled |           |          |                 |
| with a slope of 1:2 or      |           |          |                 |
| less?                       |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 8\. Is there an accessible  | 4.33.5    |          |                 |
| route connecting wheelchair |           |          |                 |
| seating locations and       |           |          |                 |
| performance areas including |           |          |                 |
| stages, arena floors,       |           |          |                 |
| dressing rooms, locker      |           |          |                 |
| rooms, and other spaces     |           |          |                 |
| used by performers?         |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 9a. If the assembly area    | 4.1.2     |          |                 |
| has an audio-amplification  | (18)      |          |                 |
| system, is there a          |           |          |                 |
| listening system for        |           |          |                 |
| persons with severe hearing |           |          |                 |
| loss?                       |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 9b. If the area is used     |           |          |                 |
| primarily as meeting or     |           |          |                 |
| conference space or has no  |           |          |                 |
| amplification system, is    |           |          |                 |
| there a permanently         |           |          |                 |
| installed or portable       |           |          |                 |
| listening system?           |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 10a. If the listening       | 4.33.6    |          |                 |
| system serves individual    |           |          |                 |
| fixed seats, are these      |           |          |                 |
| seats located within a 50   |           |          |                 |
| foot viewing distance of    |           |          |                 |
| the stage or playing area?  |           |          |                 |
+-----------------------------+-----------+----------+-----------------+
| 10b. Do these seats have a  |           |          |                 |
| complete view of the stage  |           |          |                 |
| or playing area?            |           |          |                 |
+-----------------------------+-----------+----------+-----------------+

Program Access: Non-Structural Evaluation Checklist

The following checklists are provided to assist program managers at GSA
in evaluating non-structural program access for individuals with
disabilities.

Non-structural Accessibility: General Obligations

+---------------------------+--------------+-----+--------------------+
| Question                  | Reference    | Yes | Comment            |
|                           |              | or  |                    |
|                           |              | No  |                    |
|                           |              |     |                    |
|                           |              | N/A |                    |
+---------------------------+--------------+-----+--------------------+
| 1\. Has the program staff | Recommended  |     |                    |
| that deals with the       | by OCR       |     |                    |
| public received           |              |     |                    |
| disability awareness      |              |     |                    |
|                           |              |     |                    |
| training?                 |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 2\. Are there any         | 41 CFR 105-8 |     |                    |
| policies or procedures    |              |     |                    |
| that would limit the      |              |     |                    |
| participation of or deny  |              |     |                    |
| access to individuals     |              |     |                    |
| with disabilities?        |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 3\. Are there any         | 41 CFR 105-8 |     |                    |
| policies or practices     |              |     |                    |
| that would result in an   |              |     |                    |
| individual with           |              |     |                    |
| disabilities receiving    |              |     |                    |
| lesser or different       |              |     |                    |
| benefit/service than a    |              |     |                    |
| person without a          |              |     |                    |
| disability?               |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 4\. Is program staff      | OCR          |     |                    |
| required to request       | recommends   |     |                    |
| supervisory approval      | only         |     |                    |
| prior to declining a      | supervisory  |     |                    |
| request for assistance    | staff should |     |                    |
| from an individual with   | make         |     |                    |
| disabilities?             | decision to  |     |                    |
|                           | decline a    |     |                    |
|                           | request for  |     |                    |
|                           | assistance.  |     |                    |
+---------------------------+--------------+-----+--------------------+
| 5\. Is the staff aware of |              |     |                    |
| their responsibility to   |              |     |                    |
| make reasonable           |              |     |                    |
| modifications to policies |              |     |                    |
| and/or provide            |              |     |                    |
| alternative assistance?   |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 6\. Has the staff been    |              |     |                    |
| trained or instructed     |              |     |                    |
| under what conditions or  |              |     |                    |
| situations that           |              |     |                    |
| modifications and/or      |              |     |                    |
| assistance may be         |              |     |                    |
| required in order to      |              |     |                    |
| provide meaningful access |              |     |                    |
| to individuals with       |              |     |                    |
| disabilities?             |              |     |                    |
+---------------------------+--------------+-----+--------------------+

Page 2

Non-structural Accessibility: General Obligations

+---------------------------+--------------+-----+--------------------+
| Question                  | Reference    | Yes | Comment            |
|                           |              | or  |                    |
|                           |              | No  |                    |
|                           |              |     |                    |
|                           |              | N/A |                    |
+---------------------------+--------------+-----+--------------------+
| 7\. Are there any         |              |     |                    |
| instances when members of |              |     |                    |
| the public with           |              |     |                    |
| disabilities are provided |              |     |                    |
| services/assistance       |              |     |                    |
| separate from             |              |     |                    |
| others?[^11] (i.e.,       |              |     |                    |
| segregated)               |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 8\. Has your program      |              |     |                    |
| notified contractors of   |              |     |                    |
| services to the public    |              |     |                    |
| that they are obligated   |              |     |                    |
| to comply with your level |              |     |                    |
| of responsibility under   |              |     |                    |
| Section 504 of the        |              |     |                    |
| Rehabilitation Act of     |              |     |                    |
| 1973, as amended?         |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 9\. Has the program staff |              |     |                    |
| received instruction on   |              |     |                    |
| the requirement to allow  |              |     |                    |
| individuals with          |              |     |                    |
| disabilities with service |              |     |                    |
| animals in the same areas |              |     |                    |
| that those without        |              |     |                    |
| disabilities are allowed? |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 10\. Has the program      |              |     |                    |
| staff been instructed to  |              |     |                    |
| keep the route of travel  |              |     |                    |
| clear of obstructions and |              |     |                    |
| to report any loose       |              |     |                    |
| flooring/carpeting        |              |     |                    |
| immediately to buildings  |              |     |                    |
| management?               |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 11\. Does the program     |              |     |                    |
| hold off-site meetings,   |              |     |                    |
| conferences or other      |              |     |                    |
| temporary events?         |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 12\. If so, does the      |              |     |                    |
| staff ensure that the     |              |     |                    |
| location and site is      |              |     |                    |
| accessible for            |              |     |                    |
| individuals with          |              |     |                    |
| disabilities?             |              |     |                    |
+---------------------------+--------------+-----+--------------------+

Effective communications refer to the way information is received and
transmitted. Section 504 and 41 CFR 105-8 require the provision of
auxiliary aids and services to facilitate meaningful access by
individuals with disabilities. These are devices that can accommodate a
person with a communication disability, such as a hearing impairment, a
visual impairment, or a speech/language problem.

Auxiliary aids and services include qualified sign language interpreters
and communication devices for persons who are deaf or hard of hearing;
qualified readers, taped texts, Braille or other devices for persons who
are blind or with visual impairments; adaptive equipment or similar
services and activities for people with other communication
disabilities.

Preference should be given to the individual's preferred method of
auxiliary aid or service. However, in the event the preferred method is
unavailable or cannot be provided, program managers must ensure that the
selected method provided is effective. GSA Language Services Schedule
may be helpful in locating a vendor to provide an auxiliary aid or
service.

Non-structural Accessibility: Effective Communications

+---------------------------+--------------+-----+--------------------+
| Question                  | Reference    | Yes | Comment            |
|                           |              | or  |                    |
|                           |              | No  |                    |
|                           |              |     |                    |
|                           |              | N/A |                    |
+---------------------------+--------------+-----+--------------------+
| 1\. Can information that  | 41 CFR 105-8 |     |                    |
| is communicated visually  |              |     |                    |
| (brochures, enrollment    |              |     |                    |
| forms, handbooks,         |              |     |                    |
| videotapes, flip charts,  |              |     |                    |
| slides, posters, printed  |              |     |                    |
| directional signs, and so |              |     |                    |
| forth) be provided in an  |              |     |                    |
| alternate format, if      |              |     |                    |
| requested?                |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 2\. Can information that  |              |     |                    |
| is communicated verbally  |              |     |                    |
| be provided in alternate  |              |     |                    |
| format, if requested?     |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 3\. Does the program      |              |     |                    |
| inform                    |              |     |                    |
| participants/members of   |              |     |                    |
| the public with           |              |     |                    |
| disabilities that         |              |     |                    |
| auxiliary aids and        |              |     |                    |
| services are provided     |              |     |                    |
| upon request?             |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 4\. Is there a procedure  |              |     |                    |
| established for staff to  |              |     |                    |
| refer to obtain/arrange   |              |     |                    |
| for auxiliary aids and    |              |     |                    |
| services in a timely      |              |     |                    |
| manner?                   |              |     |                    |
+---------------------------+--------------+-----+--------------------+

Page 2

Non-structural Accessibility: Effective Communications

+---------------------------+--------------+-----+--------------------+
| Question                  | Reference    | Yes | Comment            |
|                           |              | or  |                    |
|                           |              | No  |                    |
|                           |              |     |                    |
|                           |              | N/A |                    |
+---------------------------+--------------+-----+--------------------+
| 5\. Can an individual     |              |     |                    |
| with a hearing or speech  |              |     |                    |
| impairment access a       |              |     |                    |
| TTY/TDD phone system at   |              |     |                    |
| your program site?[^12]   |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 6\. If so, have staff     |              |     |                    |
| members been trained on   |              |     |                    |
| how to use the equipment? |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 7\. If your program does  |              |     |                    |
| not have TTY/TDD, does    |              |     |                    |
| your staff know how to    |              |     |                    |
| use the Federal Relay     |              |     |                    |
| Service and the telephone |              |     |                    |
| number?                   |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 8\. Is there a mechanism  |              |     |                    |
| for ensuring that people  |              |     |                    |
| who are deaf or hearing   |              |     |                    |
| impaired are aware of an  |              |     |                    |
| activated fire or smoke   |              |     |                    |
| alarm?                    |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 9\. Does your program     |              |     |                    |
| have it's own web page?   |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 10\. If so, is it         |              |     |                    |
| accessible?               |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 11\. Does your program    |              |     |                    |
| use videos in outreach    |              |     |                    |
| activities, meetings or   |              |     |                    |
| events dealing with the   |              |     |                    |
| public?                   |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 12\. If so, are they      |              |     |                    |
| closed captioned?         |              |     |                    |
+---------------------------+--------------+-----+--------------------+

Program Access: Limited English Proficiency

Executive Order 13166 requires Federal executive agencies to take
reasonable steps to provide meaningful access to federally conducted
programs and activities for individuals with Limited English Proficiency
(LEP).

+---------------------------+--------------+-----+--------------------+
| Question                  | Reference    | Yes | Comment            |
|                           |              | or  |                    |
|                           |              | No  |                    |
|                           |              |     |                    |
|                           |              | N/A |                    |
+---------------------------+--------------+-----+--------------------+
| 1\. Has the four-factor   | Executive    |     |                    |
| analysis been conducted   | Order 13160  |     |                    |
| to determine whether some | & "The Key   |     |                    |
| form(s) of LEP assistance | to Accessing |     |                    |
| is required in order to   | Federally    |     |                    |
| provide meaningful access | Conducted    |     |                    |
| to LEP individuals?       | Programs and |     |                    |
|                           | Activities"  |     |                    |
|                           | H            |     |                    |
|                           | andbook[^13] |     |                    |
+---------------------------+--------------+-----+--------------------+
| 2\. Did the four-factor   |              |     |                    |
| analysis conclude a       |              |     |                    |
| finding that some form(s) |              |     |                    |
| of LEP assistance is      |              |     |                    |
| required?                 |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 3\. If yes, have the      |              |     |                    |
| necessary processes,      |              |     |                    |
| procedures and practices  |              |     |                    |
| been put in place?        |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 4\. If yes, has the staff |              |     |                    |
| been trained or           |              |     |                    |
| instructed on the LEP     |              |     |                    |
| procedures                |              |     |                    |
+---------------------------+--------------+-----+--------------------+
| 5\. Are procedures in     |              |     |                    |
| place to monitor the      |              |     |                    |
| effectiveness of LEP      |              |     |                    |
| assistance to determine   |              |     |                    |
| whether adjustments need  |              |     |                    |
| to be made?               |              |     |                    |
+---------------------------+--------------+-----+--------------------+

[^1]: This handbook addresses meaningful access in regard to
    *[non-employment]{.underline}* programs and activities. For
    information regarding GSA's Equal Employment Opportunity program,
    visit GSA's Office of Civil Rights website at
    <http://www.gsa.gov/civilrights>, and click on "Equal Employment
    Opportunity" link.

[^2]: GSA is committed to complying with accessibility standards
    developed pursuant to the [Americans with Disabilities Act of
    1990](http://www.access-board.gov/adaag/html/adaag.htm), (i.e.,
    where those standards are stricter than UFAS.)

[^3]: Guide may be obtained through North Carolina State University.

[^4]: [UFAS](http://www.access-board.gov/ufas/ufas-html/ufas.htm) is
    mandatory on all GSA projects. Current GSA policy also encourages
    compliance with the requirements of the Americans with Disabilities
    Act Accessibility Guide
    ([ADAAG](http://www.access-board.gov/adaag/html/adaag.htm)) where
    those requirements are stricter than UFAS. Additionally, GSA
    determines whether there are local accessibility requirements. If
    they exist, the most stringent will prevail between local codes and
    UFAS/ADAAG.

[^5]: U.S. Department of Commerce, U. S. Census Bureau's report,
    [Disability Status:
    2000](http://www.census.gov/prod/2003pubs/c2kbr-17.pdf), issued
    March 2003.

[^6]: Uniform Accessibility Facilities Standards
    ([UFAS](http://www.access-board.gov/ufas/ufas-html/ufas.htm#4.13.)).

[^7]: The UFAS is mandatory on all GSA projects. Current GSA policy also
    encourages compliance with the requirements of the Americans with
    Disabilities Act Accessibility Guide
    ([ADAAG](http://www.access-board.gov/adaag/html/adaag.htm)) where
    those requirements are stricter than UFAS. Additionally, GSA
    determines whether there are local accessibility requirements. If
    they exist, the most stringent will prevail between local codes and
    UFAS/ADAAG.

[^8]: There were applicable standards prior to the UFAS, but is not
    relevant for further discussion in this handbook. Further
    information can be obtained regarding pre-UFAS standards at the
    [Access Board website](http://www.access-board.gov/).

[^9]: The Agency need not provide individually prescribed devices,
    readers for personal use or study, or other devices of a personal
    nature.

[^10]: Also see 41 CFR 102-74.425.

[^11]: Services must be provided to people with disabilities in the most
    integrated setting appropriate.

[^12]: A TTY/TDD (text telephone) is a device that allows individuals
    with hearing or speech impairments to communicate over the
    telephone. The abbreviation TTY is preferred by most users of these
    devices.

[^13]: The handbook may be obtained by contacting the Office of Civil
    Rights, 202-501-0767.