December 8, 2003

# 

# 

# INSPECTION REPORT

**To:** William Leidinger

Assistant Secretary

Office of Management

**From:** Cathy H. Lewis

Assistant Inspector General

Evaluation, Inspection, and Management Services

**Subject:** Emergency Evacuation of People with Disabilities in
Department of Education Facilities (ED/OIG I13C0017)

## Executive Summary

This memorandum provides the results of our inspection of procedures for
the emergency evacuation from Department of Education (Department)
occupied buildings of Department employees and visitors with
disabilities. Our inspection objectives were (1) determine whether
Occupant Emergency Plans (OEPs) for Department-occupied buildings
provide for the safe evacuation of Department employees and others with
disabilities; and (2) determine whether slow descent devices are present
and available for use in all Department-occupied buildings for the
evacuation of people with disabilities.

A draft of this report was provided to the Office of Management on
November 5, 2003. Comments were due back December 5. None were received
by the due date; however, comments were received several days later and
have been included with this report.

Employee concerns about the evacuation of employees with disabilities in
the event of a catastrophic emergency surfaced in a Department-wide
survey conducted in October 2002 as part of an ongoing effort to
increase Department safety and security.

After the survey results were compiled, OIG posed a series of questions
to OM regarding identified employee concerns, including, "How can
management address the awareness issues and the needs of employees with
disabilities with respect to building safety and security?" The Office
of Security Services (OSS) in OM responded that each Occupant Emergency
Plan (OEP) is designed to meet the needs of people with disabilities;
that Slow Descent Devices (SDDs or "evacuation chairs") were installed
in all Department facilities nationwide for the evacuation of people
with disabilities; and that OM/OSS had begun working with employees with
disabilities and others to develop a comprehensive policy to standardize
procedures for safely and effectively evacuating employees with
disabilities.[^1] OSS issued a bulletin that states that SDDs have been
installed in each of the Department's facilities nationwide, along with
written instructions and that an abbreviated training program has been
conducted.[^2] The Department also provided similar information to the
Office of Personnel Management (OPM) in response to an OPM memorandum.
[^3]

Because of concerns raised by employees in the Safety and Security
survey and because the information provided by OM was not consistent
with information from some Department employees with disabilities, OIG
conducted additional inspection activities to evaluate the apparent
discrepancies.

As a result of our inspection, we determined that, especially since
September 11, 2001, the Department, its managers and staff, and the
Office of Security Services have expended significant effort and
resources to ensure the safety and security of Department employees.
However, we determined that in some cases procedures and systems
described in pertinent documents to address the needs of people with
disabilities during an emergency are inconsistent with conditions in the
facility in question. We determined that some OEPs contemplate the
availability of methods for communication that may not exist.
Additionally, evacuation drills and practices do not attempt to simulate
real emergencies. Although OM:2-104 states that OEPs for all
Department-occupied buildings are found on connectED, we determined that
OEPs for several Department-occupied buildings are not available on the
site, and that two OEPs on connectED, while minimally compliant with
legal requirements for disability access to information technology, are
not readily accessible to users who are blind. We also determined that
there is no systematic procedure for identification of people who may
require assistance in exiting a Department-occupied building during an
emergency evacuation other than new employees who may identify their
need for assistance during their new employee orientation. Although SDDs
have been identified as central to Department emergency evacuation plans
for employees with disabilities, we determined that SDDs are not
available in all Department-occupied buildings or, if present, are not
known to managers or to employees with disabilities who may need to rely
upon them. Further, we were not able to establish that identified SDDs
were maintained and tested or that employees have been trained in their
use.

To address these issues, we recommend that Security Services take
immediate and continuing steps to ensure that the following
recommendations are implemented:

1.  All current Occupant Emergency Plans should be thoroughly reviewed
    for currency and completeness and the procedures described for
    evacuating employees and others with disabilities should be tested.

-   Identified employees with disabilities should participate in the
    review of completed OEPs in the facilities in which they work.

-   All identified employees with disabilities should actively
    participate in testing the effectiveness of OEPs for their
    buildings.

-   Fully accessible copies of OEPs for every ED occupied building
    should be available in an easy to find location on connectED.

-   Areas of refuge should be clearly designated with signage, including
    Braille, and should be equipped with in place two-way communications
    devices. In GSA controlled facilities, the Department should contact
    GSA and resolve any inconsistency issues in signage.

2.  The Department's inventory of SDDs should be verified; all existing
    SDDs should be tested and evaluated for replacement; and functional
    SDDs should be purchased as needed for all Department-occupied
    buildings

-   Consideration of existing SDDs for replacement, and consideration of
    purchasing one or more SDDs where none currently exist, should
    include individualized consideration of the building in question and
    of the impairments of employees who would need to use them in an
    emergency.

-   Before any existing SDDs are removed from service without being
    replaced, employees with disabilities who may have relied on their
    availability should be notified of the removal and informed of how
    they will be evacuated in the event of an emergency.

3.  At least once each year, all Department employees should be formally
    invited to identify themselves as requiring assistance in an
    emergency because of a disability or medical condition.[^4]

4.  Also on a yearly basis, the Department should provide those
    requiring

> special assistance specific information on how they will be evacuated
>
> in an emergency.

5.  OM should recall its letter to OPM and inform Departmental staff of
    the

> erroneous information with which they have been provided.

**[Background]{.underline}**

The Office of Management (OM) and the Office of Inspector General (OIG)
conducted a survey as a part of an ongoing effort to increase safety and
security at the Department in October 2002. Eight hundred sixty-five
Department employees responded. Responses represented 17% of Department
employees, in thirty public and private buildings in eleven states,
Puerto Rico, and the District of Columbia.

After the survey results were compiled, OIG posed a series of questions
to OM regarding identified employee concerns. One of the questions was,
"How can management address the awareness issues and the needs of
employees with disabilities with respect to building safety and
security?" The Office of Security Services in OM responded, on May 14,
2003, that each Occupant Emergency Plan (OEP) is designed to meet the
needs of people with disabilities and includes provisions to address
specific individuals and specific disabilities; that Slow Descent
Devices (SDDs or "evacuation chairs") were installed in all Department
facilities nationwide for the evacuation of people with disabilities;
and that OM/OSS had begun working with employees with disabilities, with
Principal Office Representatives, and with other agencies to develop a
comprehensive policy to standardize procedures for safely and
effectively evacuating employees with disabilities.[^5] OSS also stated
that it intended to provide the same information to the Office of
Personnel Management (OPM) in response to a March 17, 2003, OPM
memorandum, *Security of the Federal Workplace*. In addition, in late
March, OSS had issued a Safety and Security Bulletin, *Update Bulletin
#45 (3/28/03), Summary of Department's Security & Emergency Preparedness
Activities*, which also stated that SDDs have been installed in each of
the Department's facilities nationwide, along with written instructions
and an abbreviated training program.[^6]

The Department's Occupant Emergency Organizations and Plans Directive,
OM:2-104,[^7] outlines the policy and responsibilities for establishing
and implementing Occupant Emergency Organizations (OEOs) and Occupant
Emergency Plans (OEPs) within the Department. It applies to Department
employees located in both Headquarters and in the Regions, and states
that Department policy is to take all steps necessary to minimize the
impact on Department employees of any disasters or emergencies. Under
OM:2-104, the Assistant Secretary for Management (ASM) has overall
responsibility for the Department's emergency planning and
implementation. Pursuant to delegations from the ASM, the
highest-ranking Department official in a Department-occupied building is
responsible for developing, implementing and maintaining an OEP or, in
buildings where the Department is not the primary tenant, for consulting
with the appropriate official of the primary tenant in the development,
implementation, and maintenance of the OEP. The Director of Security
Services in OM is responsible for assuring that each Department facility
complies with the requirements of an OEP. Security Services also
provides guidance, assistance and sample plans to Department officials
to facilitate the development of OEPs.

Section 504 of the Rehabilitation Act of 1973 states that \"no qualified
individual with a disability in the United States shall be excluded
from, denied the benefits of, or be subjected to discrimination under\"
any program or activity that is conducted by, among others, any
Executive agency. Section 501 of the Rehabilitation Act prohibits the
federal government, as an employer, from discriminating on the basis of
disability. Although the Americans with Disabilities Act of 1990 (ADA)
does not cover federal employees directly, as a result of statutory
amendments in 1992 section 501 incorporates by reference the ADA's
standards relative to agencies' treatment of federal employees with
disabilities.

Federal employees with disabilities are entitled under the
Rehabilitation Act to the same level of safety as other employees. As
with other aspects of employment, reasonable accommodation for the
disabilities of Department employees may be necessary to ensure
nondiscrimination with respect to their enjoyment of a safe working
environment and in planning for emergencies in the work place.

### Inspection Results

#### Objective 1: Determine whether Occupant Emergency Plans (OEPs) for Department-occupied buildings reasonably provide for the safe and nondiscriminatory evacuation of Department employees and others with disabilities.

In general, the OEPs reflect a good-faith effort to develop plans that
will maximize the likelihood for the successful emergency evacuation of
staff, including people with disabilities. All of the OEPs contain
provisions specifically intended to ensure that employees and visitors
with disabilities are safely evacuated when other employees are
evacuated from the building. However, we did detect some significant
issues that must be addressed.

Our inspection revealed that OEP and the signage used in stairwells is
inconsistent, thus, occupants may become confused as to which stairwell
they are to use in an emergency; DC Fire Department personnel have to
rely on building staff to inform them of all the locations of persons
with disabilities needing assistance; there are no two-way communication
devices present in the areas of refuge; there is no apparent mechanism
to inform people with disabilities of the status of their evacuation
once monitors and floor wardens are gone; people with disabilities have
no opportunity to practice evacuations since they are not evacuated
during drills; several OEPs are not available on ConnectED; and there do
nor appear to be consistent processes or procedures in place to identify
individuals with disabilities who may need assistance during an
emergency evacuation.

OM:2-104 requires an Occupant Emergency Organization and an Occupant
Emergency Plan for every Department-occupied building. We reviewed OEPs
from FB6, Switzer, ROB3 and several Department-occupied buildings
outside of the District of Columbia. We also obtained information from
people with disabilities, staff expected to assist them, and members of
OEOs.

An "area of refuge" or "area of rescue assistance" is a temporary
staging area that provides relative safety to its occupants while rescue
operations are in progress. The District of Columbia Fire Department
(DCFD) and the United States Fire Administration each include areas of
refuge as one element of emergency planning for the evacuation of people
with disabilities.[^8]

The Switzer Building EOP states, "designated 'Areas of Refuge' are
located at the stairwells on the main corridors of the building, at the
head of the 100 and 600 corridors, and beside the main elevator lobbies
at the 300 and 400 corridors. These stairwells are clearly marked with
signs, designating them as 'Areas of Refuge.'*\"* On the fourth floor of
Switzer, nine stairwells, including the four identified in the EOP, have
8½ x 11 inch photocopied signs on the doors that say: \" NOTICE: This is
a designated area of refuge in the event of an emergency.\" (\"Notice\"
is in red type, making it invisible to those who are red/green
colorblind, and no signs are in Braille.) OM stated that GSA put the
signs in place, not the Department. Regardless of who put them on the
stairwell doors, because the OEP and the signage on the stairwells are
not consistent, confusion on the part of visitors and employees with
disabilities is likely. Although the risk of such confusion is not
limited to people with disabilities, most non-disabled people can
descend the "wrong" set of stairs and exit the building. In contrast,
people with mobility impairments and some other disabilities may find
themselves in the same "wrong" stairway, waiting for rescue. Emergency
personnel need to keep track not only of the four stairwells designated
in the OEP, each with four or more landings above ground level, but also
of another five stairwells with landings on each floor.

U.S. Fire Administration guidelines state that areas of refuge should
have devices in place for two-way communications, with instructions for
use. The Switzer OEP states: "Two-way communications between the Command
Center and each Area of Refuge are available to keep the people located
in these areas informed of the status of the emergency and their
evacuation." We found no two-way communications devices in any of the
areas designated as areas of refuge in the OEP or by signs in the
building. OM stated that the U.S. Fire Administration policy does not
state that the two-way communication has to be electronic, thus allowing
voice communication in the stairwell to be the Department's
communication methodology of choice. OIG disagrees on this point. The
policy states that there should be "devices" with "instructions for
use," which would indicate that something more than vocal communication
is intended. Also, individuals with certain illnesses (such as multiple
sclerosis or muscular dystrophy) may have limited vocal capacity and be
unable to indicate where they are on a stairwell.

The OEP states that radio, telephone or runners are used to maintain
communications. Designated Stairwell Monitors are expected to report the
presence of people with disabilities remaining in the stairwell to the
Floor Monitor and to the Command Center. At the same time, their
responsibilities include leading occupants to safety, and exiting the
building when the flow of traffic ceases. Similarly, the Switzer OEP
provides that Floor Wardens are to report the location of disabled
employees and visitors to the emergency command center established on
the first floor of the building, after which they are not to return to
their floors but are to leave the building. The OEP describes no
mechanism by which people with disabilities awaiting rescue will be kept
informed "of the status of the emergency and their evacuation" once the
Stairwell Monitors and the Floor Wardens have left.

DC Fire Department officials stated that its personnel are dependent on
building staff to inform them of the location of people with
disabilities needing to be rescued, and that successful evacuation of
people with disabilities depends largely on the ability of a particular
building to give accurate information to the responding emergency
personnel.

In the Jackson Federal Building in Seattle, in which Department
employees occupy the 33^rd^ and 28^th^ floors, people with disabilities
who are unable to descend and exit without assistance, are directed to
await rescue in one of two stairwells. The floor warden on the 33^rd^
floor was instructed to use the telephone for two-way communications,
including to report that people with disabilities are awaiting rescue,
but there is no telephone in the stairwell. Further, during and after
the Seattle earthquake in 2001, telephones were largely unusable because
no dial tone was available.

A key person under DM:2-104 and in Department OEPs is the Occupant
Emergency Coordinator for a facility. Under most Department OEPs,
including the Switzer Building's, the Occupant Emergency Coordinator is
responsible for selecting, training (including scheduling drills) and
organizing an adequate staff to conduct emergency operations; and
supervising the activities of the Emergency Command Center Team. During
an emergency, the Occupant Emergency Coordinator reports to the
Designated Official and keeps that person apprised of events. The
current and the previous Switzer Building OEPs, issued in March 2003 and
October 2001, respectively, both list the position of Occupant Emergency
Coordinator as Vacant.

According to Security Services, people with disabilities are not
evacuated during practice evacuations or drills. Instead, they stay in
the area of refuge and then return to their work area. The Occupant
Emergency Coordinator is responsible for reporting any deficiencies
encountered during drills, including problems experienced by individuals
with disabilities and their assistants. When drills are incomplete in
this respect, relevant information is unavailable to members of the
building Occupant Emergency Organization about the effectiveness of its
planning for the evacuation of people with disabilities and, unlike
other employees, people with disabilities and those who assist them do
not have an opportunity to practice or familiarize themselves with the
activities that would be needed in the event of a real emergency.

OM2-104 requires the publication of all OEPs on connectED. At this time,
plans for several buildings occupied by Department employees are not
available at that location. For example, in both Boston and Seattle,
OEPs are listed and linked for only one of the two principal buildings
occupied by large numbers of Department staff. In addition, the OEP for
the River Center in Chicago is missing floor plans and evacuation routes
for the floors occupied by the Department of Education and other federal
agencies in the privately owned building.[^9] Although these omissions
affect people without disabilities too, their impact is likely to be
greater for people with disabilities since many have little or no
ability to rescue themselves; they are wholly dependent for their safety
and survival in an emergency on the procedures in the relevant OEP.

#### 

Procedures for identifying people who, because of disability or physical
impairments, may require assistance in exiting a Department-occupied
building during an emergency evacuation are ambiguous and hit-or-miss.
OEPs generally do not include procedures for the identification of such
people. According to Security Services, identification depends on
supervisors, who are likely only to raise the issue with those for whom
the need is self-evident or who have requested accommodation for the
impact of their disabilities on other aspects of their work. Department
supervisors generally are not trained to determine whether employees
have physical impairments that may be expected to interfere with their
ability to evacuate the building in an emergency. The omission is likely
to be especially true when employees themselves do not regard their
medical condition as a disability because it does not interfere with
their ability to do their jobs or to require reasonable accommodation in
their work. Conditions such as asthma and heart disease, while not
disabling relative to job performance, can prevent unassisted evacuation
in an emergency.

Without significant improvements in the areas identified above, the
individuals with disabilities appear to be at significant risk should
there be an actual emergency.

#### Objective 2: Determine whether slow descent devices (SDDs) are available for use in all Department facilities for the evacuation of people with disabilities. 

Our inspection revealed that, although SDDs have been identified as key
components of the Department's planning for emergency evacuation
employees with disabilities, they are not available in all
Department-occupied buildings, or, if present, are not known to managers
or employees with disabilities who may need to rely on them. Further, we
were unable to establish that identified SDDs were maintained and
tested, or that employees have been trained in their use.

Within the last six months, the Office of Management and more
particularly Security Services has stated on more than one occasion and
has publicized to all Department employees that Slow Descent Devices are
available in all Department buildings nationwide for the emergency
evacuation of employees with disabilities. In July 2003, Security
Services told OIG that Headquarters buildings in the DC area have four
chairs per building and in the regions two per building.

The Mary E Switzer Building has 5 floors above ground level, and 9
stairwells accessible on each floor except the top one. OIG, with
assistance from the Building Manager, was able to locate three SDDs, in
three different stair landings. The current OEP for the Switzer Building
does not identify SDDs as a component of building plans for the
evacuation of employees with disabilities.

The Department of Education Building (FB6) has 6 floors above ground
level. OIG identified six SDDs in different stairwells. The current OEP
for FB6 does not identify SDDs as a component of building plans for the
evacuation of employees with disabilities.

Current and former employees who worked in ROB3, including a senior
manager with a mobility impairment who could not exit the building
unassisted in an emergency, knew of no SSD in Department-occupied
sections of the building or in emergency exit routes designated for use
by Department employees. The current OEP for ROB3 does not identify SDDs
as a component of building plans for the evacuation of employees with
disabilities.

Department managers of large regional staffs in Chicago and Seattle,
each of whom supervises employees with disabilities including mobility
impairments, did not know of and could not identify any SDDs in their
buildings. The floor warden for Department-occupied space in Seattle
also did not know of an SDD. The Chicago office leases space on the 10th
floor of a private building. The Seattle office in question is located
on the 33^rd^ floor of a large GSA-operated Federal Building.

A Department manager in Denver works on the 3rd floor of a privately
owned building. The manager has a mobility impairment and ordinarily
uses a scooter, although she is able to walk, using crutches, with
difficulty. No SDD is available for her use. Her efforts and efforts of
others to obtain one have not been successful.

Between March and May 2003, Security Services reported to Department
employees, to OIG, and to the Office of Personnel Management that Secure
Descent Devices are a key component of Department efforts to ensure the
safety of people with disabilities in the event of emergency evacuation.
In late April or early May, however, Security Services recommended
against the purchase of an SDD for use by the previously described
Denver employee.

In an interview held in July 2003, a Security Services staff member
stated that the SDDs purchased in 1993 are not reliable, and that
Department staff were never trained to use them.

The slow descent chairs located in the Switzer and FB6 Buildings are
designed so that a person assisting the person in control of the chair
must physically weigh more than the person who is being assisted,
thereby eliminating many colleagues including often an aide employed
specifically to assist an employee with a disability. In addition, the
devices are not self-arresting---that is, if a person assisting in an
evacuation with the device were to lose his or her grip on the controls,
the device would continue to descend, out of control.

The Smithsonian Institution uses the same kind of SDD that is installed
in the Switzer Building. The devices are installed on every other floor,
and are used by some employees with disabilities during unannounced,
live, drills designed to simulate a real emergency evacuation as closely
as possible. All employees and all visitors are fully evacuated. The
Safety Coordinator at the Smithsonian reported no injuries or
disruptions of evacuation drills attributable to use of the devices, and
that employees are trained to delay their descent until the major flow
of traffic has passed in the stairwell before using the chairs.

We found no record that the existing SDDs in Switzer or FB6 have been
tested or maintained in recent years, if ever. Although this type of SDD
is supposed to be maintenance free, the Smithsonian found through
experience that they require periodic inspection and routine maintenance
to ensure that they can be used when needed.

We also found no indication that existing SDDs in Switzer or FB6 have
been used in drills or training to simulate as closely as possible the
conditions of a real emergency, and Security Services told us that no
training of employees in the use of the devices has been conducted since
they were purchased a decade ago. Without such training, it is difficult
to anticipate and plan for problems that may arise, or to ensure that
people with disabilities and those who may be required to assist in an
evacuation know what is expected with regard to using SDDs.

The Federal Emergency Management Agency and the United States Fire
Administration include SDDs in technical assistance materials regarding
the evacuation of people with disabilities from office buildings. The
United States Architectural and Transportation Barriers Compliance Board
(the Access Board) purchased SDDs and includes them as part of its own
OEP.[^10] The Department of Housing and Urban Development, after careful
evaluation of available options, recently initiated the purchase of 123
SDDs for employees in its headquarters offices. OSERS currently is
evaluating several models of SDDs for use by employees. The DC Fire
Department advises that SDDs can be used when the devices are available
and employees have been trained to use them.

SDDs are not present in all buildings, and in those where they do exist,
there does not appear to have been adequate training or practice on how
to use them in the case of an emergency.

# Conclusions

Department planning for the emergency evacuation of people with
disabilities is largely untested through drills or practices that
reasonably simulate the conditions of a real emergency. As a result,
Occupant Emergency Plans describe procedures that cannot be implemented
at the various sites. Slow descent devices have erroneously been
promoted inside and outside the Department as being available in all
Department buildings for the emergency evacuation of people with
disabilities. The devices have not been adequately inventoried or tested
to ensure that the ones currently in place are in good working order.
There is no established procedure in the Department for the
identification of people who will require evacuation assistance.
Locations designated for people with disabilities and those assigned to
remain with them to await rescue lack means of communication with those
coordinating rescue efforts. Those requiring assistance during an
evacuation do not have specific information on how they will be
evacuated during an emergency.

**Scope and Methodology:**

This inspection evaluated the effectiveness of procedures for the
emergency evacuation of employees and others with disabilities from
Department-occupied buildings.

We conducted interviews with essential personnel within and without the
Department; gathered pertinent documents; reviewed applicable policies,
regulations, procedures, and pertinent literature; visited
Department-occupied buildings in the District of Columbia and regional
offices, and another federal agency's facility. We also spoke to staff
responsible for emergency planning for people with disabilities in other
federal agencies and to Fire Department personnel. We focused our
inspection on the Mary E. Switzer Building and additionally reviewed
information regarding five other Department-occupied buildings: FB6,
ROB3, the Jackson Federal Building in Seattle, and two privately owned
buildings in which the Department leases space, the River Center
Building in Chicago, and the Parkway Center in Denver.

This inspection took place during June-September, 2003.

#### December 8, 2003

**Response to Draft Inspection Report**

TO : Cathy H. Lewis

Assistant Inspector General

Evaluation, Inspection and Management Services

FROM : William J. Leidinger

SUBJECT : ***[Response and Action Plan]{.underline}*** -- Emergency
Evacuation of People with Disabilities in Department of Education
Facilities (ED/OIG I13C0017)

### Executive Summary

The Office of Management (OM) appreciates the concern and the time spent
assessing the procedures for the evacuation of employees and visitors
with disabilities. The draft inspection report submitted by the Office
of the Inspector General (OIG), dated November 5, 2003, offers some
insights on areas OM will consider in enhancing the Department's
programs.

In response to the areas of concern in the OIG report the following
general comments are offered. The section that addresses areas of refuge
and the use of Slow Decent Device's appears to be based on information
obtained from the United States Fire Administration (USFA) and the
District of Columbia *Evacuation Plan Guide*. While these documents may
prove helpful as reference documents, they were not used to establish
the guidelines for the Department's program. In addition, the use of
SDD's is not a requirement. Current guidelines call for the designation
of a safe location for disabled personnel, until such a time as Fire or
other Emergency service officials can safely evacuate them.

The ED program follows and is in compliance with the guidelines provided
by the following regulatory agencies -- National Fire Protection
Association (NFPA), Uniformed Federal Accessibility Standard (UFAS),
Americans with Disabilities Act (ADA), Code of Federal Regulations (CFR)
and other national guidelines recognized by the General Services
Administration. These guidelines ensure that accommodations afforded to
non-disabled employees are reasonably afforded to disabled employees.

In this report the Inspector General (IG) has indicated that they have
found indications of inconsistency with information from disabled
employees, OEP's that were not current or complete, inconsistent signage
in buildings and other findings. However, the report does not list the
specific buildings or locations. Security Services looks forward to
working with the IG and gaining sufficient information to address the
specific findings cited.

In response to the specific steps suggested in the report, the following
comments are offered:

*\[1\] Survey all Occupant Emergency Plans*

a.  Each Occupant Emergency Plan (OEP) will be reviewed and those plans
    that ED has control over will be brought into compliance with
    government requirements. ED does not in all cases own many of the
    OEP's where ED offices are located. A number of these OEP's (13) are
    controlled by other agencies where ED is not the lead tenant. In
    these cases, the lead tenant is responsible for the development and
    maintenance of the OEP. The lead tenant has a responsibility to
    furnish a copy of their OEP to other tenants in the building.

b.  There are currently programs in place or are being developed in an
    effort to provide safety and security to all ED employees. Security
    Services is currently developing an awareness program for
    distribution to all ED employees. Security Services will develop and
    produce a condensed written guide, which specifies what to do when
    an emergency occurs. This guide when finished will be produced in
    written, Braille and audible formats to accommodate all ED
    employees. To assist in developing this guide, Security Services has
    assembled teams of employees, including those with disabilities to
    provide input to the staff.

c.  Security Services will review the OEP's currently available on the
    web site, if any OEP's are not found on the web, Security Services
    will make every effort to obtain the missing OEP's. As done in the
    past, Security Services will make a written appeal for updates of
    Occupant Emergency Plans from Headquarters and Regional Facilities.
    In those instances where a Headquarters or Regional Facility does
    not have a plan, or the responsible individual (e.g. lead tenant)
    has difficulty developing a plan, Security Services provides a
    "boiler-plate" plan to assist in the completion of the task.

d.  Signage in all ED controlled building will be review for compliance
    with guidelines. In ED buildings signage not meeting the guidelines
    will be reported to GSA with the request for correct signage to be
    posted. In non- ED controlled buildings every attempt will be made
    to work with the building managers to ensure compliance.

> As previously stated, the Department's program is in compliance with
> guidelines. None of the guidelines require the installation of two-way
> communication in existing construction. Security Services will
> continue to work with assessments completed on any new construction to
> ensure compliance with security and safety guidelines, including the
> applicability of two-way communication devices in areas of refuge.

*\[2\] Locate all Slow Decent Devices in Headquarters and Regional
Facilities*

a.  Security Services will ask each Headquarters and Regional site to
    verify the location and condition of SDD's in their facility. In
    order to fully and adequately address the issue of slow decent
    devices (SDD's), there is a need to look at the history of these
    devices within the Department of Education. Approximately 15 years
    ago (1988-1989) the issue of SDD's surfaced, at that time 32 of
    these devices were purchased and distributed within the Department
    of Education. Slow Decent Devices were purchased in 1990 for ED
    facilities in the Headquarters and Regional sites. At the time of
    procurement, it was determined and communicated that the Slow Decent
    Devices were for the use by local fire and rescue personnel. This
    was due to the type of equipment purchased and the liabilities
    recognized by the agency.

As previously stated, the use of SDD's is not mandated. However,
Security Services, as explained below, is working with employees to
evaluate and provide adequate evacuation procedures for all employees.
Security Services provides periodic information, as well as updates
based upon significant changes. As the evacuation program changes,
Security Services will provide information to ED employees.

b.  The use of SDD's in the Department is a complex issue in which
    numerous versions of the devices must be evaluated, differing
    building construction types must be accommodated, and numerous
    variations of disabling conditions require different types of SDD's.
    Security Services, as the lead for the Office of Management, in
    concert with the Office of Special Education and Rehabilitative
    Services (OSERS) has initiated a program by which written guidelines
    have been drafted, SDD's have been purchased and a training process
    is being developed. It is hoped that the program will culminate with
    a written Administrative Directive, which will outline how and when
    SDD's shall be used, who will be qualified to use them, and under
    what authorities and protection this process can be implemented. In
    addition, Security Services will locate and inspect all SDD's to
    ensure they are functional or removed from service if appropriate.

\[3\] Identify employees requiring assistance in an emergency

a.  Security Services will conduct an annual review of persons with
    disabilities, and invite others requiring assistance to identify
    themselves.

\[4\] Provide evacuation information annually

a.  Security Services provides evacuation and other safety information
    continuously on its website and through the Department's e-mail
    system. When new information is available or changes are made,
    announcements are also made. In addition to this always-available
    information, Security Services will provide an annual reminder to
    employees to remind them where the information can be obtained.

\[5\] Provide accurate information

Security Services will continue to provide periodic updates and
information regarding changes in the program to Department staff and
other external offices, including OPM. In addition to the methods of
information dissemination discussed above, Security Services conducts
"town hall" meetings at Headquarters locations and Regions.

[^1]: [oigmis3.ed.gov/Misc/ReportIIJun03.html](../oigmis3.ed.gov/Misc/ReportIIJun03.html)

[^2]: Update Bulletin #45 continues to be available on connectED:
    [connected.ed.gov/index.cfm?articleobjectid=2C86F8CB-8EF6-447F-95F992E09A9BE07A](../connected.ed.gov/index.cfm%3Farticleobjectid=2C86F8CB-8EF6-447F-95F992E09A9BE07A)

[^3]: The Department initially was unable to provide us with a copy of
    this memorandum. We obtained a copy from OPM, but it was not signed,
    dated or printed on departmental stationary.

[^4]: Although an employer may ask employees with known disabilities
    whether they require assistance, self-identification should be
    invited periodically from all employees and not be based on
    assumptions about whether or not an individual has a disability or
    medical condition requiring such assistance. The EEOC has issued a
    Fact Sheet on Obtaining and Using Employee Medical Information as
    Part of Emergency Evacuation Procedures.
    <http://www.eeoc.gov/facts/evacuation.html>

[^5]: [oigmis3.ed.gov/Misc/ReportIIJun03.html](../oigmis3.ed.gov/Misc/ReportIIJun03.html)

[^6]: Update Bulletin #45 continues to be available on connectED:
    [connected.ed.gov/index.cfm?articleobjectid=2C86F8CB-8EF6-447F-95F992E09A9BE07A](../connected.ed.gov/index.cfm%3Farticleobjectid=2C86F8CB-8EF6-447F-95F992E09A9BE07A)

[^7]: OM:2-104 was issued on July 14, 2003, while OIG's inspection was
    underway. It superceded D:ADM:3-102, dated 07/23/1992.

[^8]: United States Fire Administration, *Emergency Procedures for
    Employees with Disabilities in Office Occupancies,* FA-154 (6/95);
    D.C. Fire and EMS Department, *Evacuation Plan Guide,* (Undated,
    provided to OIG by the D.C. Fire Department on July 19, 2003).

[^9]: The location in the emergency plan where this critical information
    should be says simply, "(Pages 22 -- 26 to be inserted: Plans for
    each of the federally occupied floors -- 6, 8, 9, 10 & 11)"

[^10]: Access Board: Emergency Evacuation Plan,
    <http://www.access-board.gov/evacplan.htm>. See also, The Access
    Board\'s Emergency Evacuation Plan: Background Information,
    <http://www.access-board.gov/evacplan.htm>