# Presentation: 411376

## WELCOME

## GOALS

- Introduce the Technical Assistance Manual (TAM) as the framework
- Outlines passengers’ rights and carriers’ responsibilities under Part 382
- Provides practical examples and quick references

## SPECIFIC OBJECTIVES

- Provide useful approach to assist air travelers with disabilities
- Sources of **INFORMATION**
- Heightened** SENSITIVITY** and **AWARENESS**
- Enhanced **COMMUNICATION **skills
- Effective **CONFLICT RESOLUTION** techniques

## Specific Objectives  (cont’d)

- Reinforce understanding of carriers’ legal
- responsibilities to protect civil rights
- Civil rights = basic rights against discrimination
- Carriers’ legal obligations v. policies
- Civil rights violation - DOT enforcement
- Failure to follow carrier policy – different consequences

## How did TAM come about?

Congressional requirement 

Two audiences:

Air carrier employees and contractors

Air travelers with disabilities

DOT met with air carriers and disability community

- Congressional requirement
- Two audiences:
- Air carrier employees and contractors
- Air travelers with disabilities
- DOT met with air carriers and disability community

**ORIENTATION**

## Why is TAM useful for you on the job?

Delineates competing considerations

Distinguishes Part 382 from carrier policies

Provides quick reference lists and “tips”   

- Delineates competing considerations
- Distinguishes Part 382 from carrier policies
- Provides quick reference lists and “tips”

**Orientation (cont’d)**

## What information does TAM contain?

Chapter 1:	Background, Keyword Definitions

Chapter 2:	Basics about the Law

Chapter 3:	Assisting Travelers in Planning a 			Trip

Chapter 4:	Assisting Travelers At the Airport

- Chapter 1:	Background, Keyword Definitions
- Chapter 2:	Basics about the Law
- Chapter 3:	Assisting Travelers in Planning a 			Trip
- Chapter 4:	Assisting Travelers At the Airport

**Orientation (cont’d)**

## What information does TAM contain?

Chapter 5:	Boarding, Deplaning, and During 			the Flight

Chapter 6:   	Assisting Travelers with Their 				Complaints

Chapter 7:    	Interacting with People with Disabilities

Chapter 8:	Alphabetical Index and Part 382 Index

- Chapter 5:	Boarding, Deplaning, and During 			the Flight
- Chapter 6:   	Assisting Travelers with Their 				Complaints
- Chapter 7:    	Interacting with People with Disabilities
- Chapter 8:	Alphabetical Index and Part 382 Index

**Orientation (cont’d)**

## Appendices I-VI: 
Tips for Air Travelers with Disabilities

Management-Related Issues 

FAQs

DOT Enforcement Orders Related to ACAA

Copy of Part 382

DOT Guidance:  Service Animals in Air Transportation

- Tips for Air Travelers with Disabilities
- Management-Related Issues
- FAQs
- DOT Enforcement Orders Related to ACAA
- Copy of Part 382
- DOT Guidance:  Service Animals in Air Transportation

**Orientation (cont’d)**

## Locating Information In TAM - Exercises

## Locating Information In TAM 

- Exercise 1
- Where in TAM would you find information?
- 382.55(a)(2); 382.37(c)
- Appendix VI – DOT Guidance on Service Animals:    pp. 8-9, 11
- Alphabetical Index and Part 382 Index; Appendices; Chapter 2, Chapter 3, Section D, Chapter 5, Section B, Chapter 7

## Exercise 2

Are you permitted to hand-carry this passenger?  

   No.

- Are you permitted to hand-carry this passenger?
-    No.

**Locating Information in TAM (cont’d)**

## Exercise 2 (cont’d)

Where in TAM would you find information?

382.39(a)(2)  

Alphabetical Index and Part 382 Index; Appendices; Chapter 5, Section C

- Where in TAM would you find information?
- 382.39(a)(2)
- Alphabetical Index and Part 382 Index; Appendices; Chapter 5, Section C

**Locating Information in TAM (cont’d)**

## Exercise 3

Is this passenger a qualified individual with a 
disability because he weighs over 300 pounds?                                                               

It depends.  

Is he entitled to the bulkhead seat?

It depends.    

- Is this passenger a qualified individual with a
- disability because he weighs over 300 pounds?
- It depends.
- Is he entitled to the bulkhead seat?
- It depends.

**Locating Information in TAM (cont’d)**

## Exercise 3 (cont’d)

Where in TAM would you find information?

382.5; 382.38

Appendix III - Frequently Asked Questions

Alphabetical Index and Part 382 Index; Appendices; Chapter 2

- Where in TAM would you find information?
- 382.5; 382.38
- Appendix III - Frequently Asked Questions
- Alphabetical Index and Part 382 Index; Appendices; Chapter 2

**Locating Information in TAM (cont’d)**

## Exercise 4

Where in TAM would you find information?

382.41(g); 382.41(h)

Appendix I – Tips for Air Travelers with Disabilities

Alphabetical Index and Part 382 Index; Appendices; Chapter 3, Section H

- Where in TAM would you find information?
- 382.41(g); 382.41(h)
- Appendix I – Tips for Air Travelers with Disabilities
- Alphabetical Index and Part 382 Index; Appendices; Chapter 3, Section H

**Locating Information in TAM (cont’d)**

## Exercise 5

Must you accommodate this group?

   Yes.

- Must you accommodate this group?
-    Yes.

**Locating Information in TAM (cont’d)**

## Exercise 5 (cont’d)

Where in TAM would you find information?

382.33(b)(7); 382.33(c);382.31(c); 382.41(g)

Alphabetical Index and Part 382 Index; Appendices; Chapter 3, Section A

- Where in TAM would you find information?
- 382.33(b)(7); 382.33(c);382.31(c); 382.41(g)
- Alphabetical Index and Part 382 Index; Appendices; Chapter 3, Section A

**Locating Information in TAM (cont’d)**

## SENSITIVITY AND AWARENESS

- Why are sensitivity and awareness important?
- Passengers with disabilities are valued customers, and they are a growing population
- Builds loyalty
- Employees and contractors have direct contact with traveling public

## Why are sensitivity and awareness important?

Customer service is a major responsibility

Customer service differs from legal requirements

Helps distinguish customer service from legal obligations

- Customer service is a major responsibility
- Customer service differs from legal requirements
- Helps distinguish customer service from legal obligations

**Sensitivity and Awareness (cont’d)**

## Introducing Sensitivity and Awareness – Small Group Exercises

## Legal obligation to protect civil rights

Not “above and beyond” call of duty

- Not “above and beyond” call of duty

**Pre-exercise Reminder**

**Sensitivity and Awareness (cont’d)**

## Exercises – Concluding Remarks

Experiences shape attitudes

Attitudes depend on experiences interacting with people with disabilities  

Build on experiences; modify behavior through awareness and sensitivity

- Experiences shape attitudes
- Attitudes depend on experiences interacting with people with disabilities
- Build on experiences; modify behavior through awareness and sensitivity

**Sensitivity and Awareness (cont’d)**

## TAM as a Resource for Sensitivity and Awareness Information

Respectful, preferred language:

Use “person first” language

Don’t ask for self-identification

Demonstrate respect for privacy

Avoid asking cause of disability

Don’t make assumptions about conditions and resulting disabilities

- Respectful, preferred language:
- Use “person first” language
- Don’t ask for self-identification
- Demonstrate respect for privacy
- Avoid asking cause of disability
- Don’t make assumptions about conditions and resulting disabilities

**Sensitivity and Awareness (cont’d)**

## Appropriate behavior when interacting with people with disabilities

General guidance for language and behavior that conveys respect

Chapter 7 contains useful techniques

Some job functions require greater sensitivity and awareness than others

- General guidance for language and behavior that conveys respect
- Chapter 7 contains useful techniques
- Some job functions require greater sensitivity and awareness than others

**Sensitivity and Awareness (cont’d)**

## Appropriate communication and behavior 
when interacting with individuals who

are blind or visually-impaired

are deaf, hard of hearing, or deaf-blind

have mobility disabilities

have difficulty speaking

have disabilities that are not apparent

- when interacting with individuals who
- are blind or visually-impaired
- are deaf, hard of hearing, or deaf-blind
- have mobility disabilities
- have difficulty speaking
- have disabilities that are not apparent

**Sensitivity and Awareness (cont’d)**

## Communication

- Introduction
- Communication styles vary
- Genuine, authentic communication conveys respect
- Helping others in the moment – honest communication
- Use discretion when applying following language, tips
- Each passenger is unique

## Challenges of work environment impact communication

Time pressure of flight schedules

Important considerations with serious consequences: safety, terrorism

Linear path of air traveler

Fewer employees, increased job responsibilities

Others

- Time pressure of flight schedules
- Important considerations with serious consequences: safety, terrorism
- Linear path of air traveler
- Fewer employees, increased job responsibilities
- Others

**Communication  (cont’d)**

## Some ways to enhance communication

Ask expert: air traveler, companion

Make eye contact, be aware of nonverbal signs

Listen first, then formulate response

Be patient

Clarify information

Others

- Ask expert: air traveler, companion
- Make eye contact, be aware of nonverbal signs
- Listen first, then formulate response
- Be patient
- Clarify information
- Others

**Communication  (cont’d)**

## Attitude makes an impression

Assumptions often lead to misunderstandings

Taking things personally may color perceptions

Generate options rather than being adverse 

Maintain professionalism

- Assumptions often lead to misunderstandings
- Taking things personally may color perceptions
- Generate options rather than being adverse
- Maintain professionalism

**Communication  (cont’d)**

## Personal health needs

Self-care outside workplace

Overall health:  Mental, physical, emotional

Impact job performance

- Self-care outside workplace
- Overall health:  Mental, physical, emotional
- Impact job performance

**Communication  (cont’d)**

## Start with passenger and ask “How may I assist you?”

TAM contains useful questions

Ask, then listen, and clarify if needed

- TAM contains useful questions
- Ask, then listen, and clarify if needed

**Communication  (cont’d)**

## Share important information

Think about information you need

Safety always a factor

Draw from experience

Refer passenger to TAM

Others

- Think about information you need
- Safety always a factor
- Draw from experience
- Refer passenger to TAM
- Others

**Communication  (cont’d)**

## Practicing Communication – Small Group Exercises

## Passenger is best source of information

Offer information and options to passenger

Draw from experience, use available resources

Useful exchange of information

- Offer information and options to passenger
- Draw from experience, use available resources
- Useful exchange of information

**Pre-exercise Reminder**

**Communication  (cont’d)**

## Small Group Debrief

- Exercise 1
- Important considerations to keep in mind
- “Prompt return” required under 382.41(f); 382.43(a)
- Passenger entitled to use personal wheelchair
- Passenger’s autonomy in personal wheelchair greater
- Wheelchair retrieval and reassembly time

**Communication  (cont’d)**

## Exercise 1 (cont’d)

Passenger’s written instructions under 382.41(h)  

Passenger’s connecting flight and gate information

Priority stowage for wheelchair under 382.41(f)(2)

Wheelchair ready upon deplaning

- Passenger’s written instructions under 382.41(h)
- Passenger’s connecting flight and gate information
- Priority stowage for wheelchair under 382.41(f)(2)
- Wheelchair ready upon deplaning

**Communication  (cont’d)**

## Exercise 1  (cont’d)

Suggestions for analyzing the situation and exchanging useful information

Ask passenger

Listen without formulating response 

Clarify information  

Follow written instructions re: wheelchair reassembly

Inform other carrier personnel

- Suggestions for analyzing the situation and exchanging useful information
- Ask passenger
- Listen without formulating response
- Clarify information
- Follow written instructions re: wheelchair reassembly
- Inform other carrier personnel

**Communication  (cont’d)**

## Exercise 1 (cont’d)

Check PNR

Consult colleagues about time constraints

Check TAM, Part 382 (382.41(f); 382.43(a)), DOT guidance documents, and carrier policies

If requested, provide copy of Part 382 required by 382.45(d)

- Check PNR
- Consult colleagues about time constraints
- Check TAM, Part 382 (382.41(f); 382.43(a)), DOT guidance documents, and carrier policies
- If requested, provide copy of Part 382 required by 382.45(d)

**Communication  (cont’d)**

## Exercise 2

Important considerations to keep in mind

Aircraft dimensions affect wheelchair stowage options 

Advance seating assignment system or pre-boarding option

Features of aircraft relevant to wheelchair user 

Need for aisle chair for boarding and deplaning   

- Important considerations to keep in mind
- Aircraft dimensions affect wheelchair stowage options
- Advance seating assignment system or pre-boarding option
- Features of aircraft relevant to wheelchair user
- Need for aisle chair for boarding and deplaning

**Communication  (cont’d)**

## Exercise 2 (cont’d)

Clarify need for other boarding and deplaning assistance     

Suggest early arrival at gate 

Passenger’s written instructions about disassembly and reassembly of wheelchair under 382.41(h)

Carrier’s web site may contain relevant information	

- Clarify need for other boarding and deplaning assistance
- Suggest early arrival at gate
- Passenger’s written instructions about disassembly and reassembly of wheelchair under 382.41(h)
- Carrier’s web site may contain relevant information

**Communication  (cont’d)**

## Exercise 2 (cont’d)

Suggestions for analyzing the situation and exchanging useful information

Ask passenger

Listen without formulating response 

Clarify information  

Follow written instructions re: wheelchair reassembly

Inform other carrier personnel

- Suggestions for analyzing the situation and exchanging useful information
- Ask passenger
- Listen without formulating response
- Clarify information
- Follow written instructions re: wheelchair reassembly
- Inform other carrier personnel

**Communication  (cont’d)**

## Exercise 2  (cont’d)

Check TAM, Part 382 (382.45; 382.21, 382.33(b)(5); 382.38; 382.40 or 382.40a; 382.41), DOT guidance documents, and carrier policies

Refer passenger to carrier’s web site and Appendix I, via DOT web site

If requested, provide copy of Part 382 required by 382.45(d)

- Check TAM, Part 382 (382.45; 382.21, 382.33(b)(5); 382.38; 382.40 or 382.40a; 382.41), DOT guidance documents, and carrier policies
- Refer passenger to carrier’s web site and Appendix I, via DOT web site
- If requested, provide copy of Part 382 required by 382.45(d)

**Communication  (cont’d)**

## Exercise 3

Important considerations to keep in mind

Each passenger is unique

Ask how best you can assist   

Identify accessible method(s) of communication

- Important considerations to keep in mind
- Each passenger is unique
- Ask how best you can assist
- Identify accessible method(s) of communication

**Communication  (cont’d)**

## Exercise 3 (cont’d)

Inform other carrier personnel

Check PNR    

Respect privacy of deaf passenger

Be discreet when addressing or referring to her 

- Inform other carrier personnel
- Check PNR
- Respect privacy of deaf passenger
- Be discreet when addressing or referring to her

**Communication  (cont’d)**

## Exercise 3 (cont’d)

Suggestions for analyzing the situation and exchanging useful information

Ask passenger

Listen without formulating response 

Clarify information with traveling companion

Consult other carrier personnel

Ask about additional services and accommodations

- Suggestions for analyzing the situation and exchanging useful information
- Ask passenger
- Listen without formulating response
- Clarify information with traveling companion
- Consult other carrier personnel
- Ask about additional services and accommodations

**Communication  (cont’d)**

## Exercise 3 (cont’d)

Ask about need for additional services and accommodations  

Check PNR

- Ask about need for additional services and accommodations
- Check PNR

**Communication  (cont’d)**

## Exercise 3  (cont’d)

Check TAM, 382.23(a); 382.45(b)(1) and (2); 382.45(c); 382.39(b)(5); 382.38; 382.47, DOT guidance documents, and carrier policies.

If requested, provide copy of Part 382 required by 382.45(d)

- Check TAM, 382.23(a); 382.45(b)(1) and (2); 382.45(c); 382.39(b)(5); 382.38; 382.47, DOT guidance documents, and carrier policies.
- If requested, provide copy of Part 382 required by 382.45(d)

**Communication  (cont’d)**

## Conflict Resolution

- Carriers must make a complaint resolution official (CRO) available to address disability-related problems
- By telephone (or via TTY) or in person
- At all times carrier operates at airport under 382.65(a)(1) and (2)

## When does a CRO get involved?

If air traveler with a disability:

Complains of alleged or potential violation of law

Requests CRO, manager, supervisor, etc.

If employee or contractor decides to contact CRO for information or advice

- If air traveler with a disability:
- Complains of alleged or potential violation of law
- Requests CRO, manager, supervisor, etc.
- If employee or contractor decides to contact CRO for information or advice

**Complaint Resolution  (cont’d)**

## Disability-related complaints made to CRO during 
course of trip

If no violation has occurred, CRO must take action to comply with law  

Only pilot can countermand CRO’s decision for reasons of safety

CRO must provide written statement summarizing facts and carrier response to violation

- course of trip
- If no violation has occurred, CRO must take action to comply with law
- Only pilot can countermand CRO’s decision for reasons of safety
- CRO must provide written statement summarizing facts and carrier response to violation

**Complaint Resolution  (cont’d)**

## 
CRO must provide written statement summarizing facts and carrier explanation

Carriers must provide passenger all written statements at airport or within 10 calendar days of complaint

- CRO must provide written statement summarizing facts and carrier explanation
- Carriers must provide passenger all written statements at airport or within 10 calendar days of complaint

**Complaint Resolution  (cont’d)**

## Written disability-related complaints made after 
trip

Must provide written response within 30 days

Response must contain summary of facts and carrier’s determination about violation

Response must contain information about passenger’s right to pursue DOT enforcement action

- trip
- Must provide written response within 30 days
- Response must contain summary of facts and carrier’s determination about violation
- Response must contain information about passenger’s right to pursue DOT enforcement action

**Complaint Resolution  (cont’d)**

## Domestic and foreign carriers operating in U.S.
must 

record,

categorize, and 

report 

- must
- record,
- categorize, and
- report

**Complaint Resolution  (cont’d)**

- Written disability-related complaints to DOT          annually under 382.70

## To provide guidance for resolving complaints, TAM 
contains 

ACCESS= process 

Tips 

Also important: awareness, sensitivity and 
communication

- contains
- ACCESS= process
- Tips
- Also important: awareness, sensitivity and
- communication

**Complaint Resolution  (cont’d)**

## More on communication

Passenger has a right to speak to CRO

Avoid defensive or argumentative reaction

Make notes for use in carrier’s written response  

Others

- Passenger has a right to speak to CRO
- Avoid defensive or argumentative reaction
- Make notes for use in carrier’s written response
- Others

**Complaint Resolution  (cont’d)**

## Conflict Resolution Techniques may be useful

Avoid immediately taking sides

Use fresh eyes to assess situation, listen, and observe (if possible)

Review past only to gain basic understanding 

- Avoid immediately taking sides
- Use fresh eyes to assess situation, listen, and observe (if possible)
- Review past only to gain basic understanding

**Complaint Resolution  (cont’d)**

## 
Concentrate on solutions that comply with Part 382, DOT guidance documents, and carrier policies

Remind parties of shared goal of safe, pleasant, and smooth journey

Acknowledge carrier’s responsibility to protect civil rights

Allow venting and be prepared to manage anger

- Concentrate on solutions that comply with Part 382, DOT guidance documents, and carrier policies
- Remind parties of shared goal of safe, pleasant, and smooth journey
- Acknowledge carrier’s responsibility to protect civil rights
- Allow venting and be prepared to manage anger

**Complaint Resolution  (cont’d)**

## 
Acknowledge frustrations and patience of passenger under the circumstances

Listen patiently and carefully, conveying responsive attitude engenders trust and confidence

Write down relevant information and check accuracy

Explain basis for determination

Incorporate carrier’s policy, paper work, and procedures

- Acknowledge frustrations and patience of passenger under the circumstances
- Listen patiently and carefully, conveying responsive attitude engenders trust and confidence
- Write down relevant information and check accuracy
- Explain basis for determination
- Incorporate carrier’s policy, paper work, and procedures

**Complaint Resolution  (cont’d)**

## Demonstrating How CRO Handles Disability-related Complaint – Role Play

## CRO ROLE PLAY DEBRIEF

- Did not put either person on defensive
- Introduced herself and understood passenger’s right to speak with CRO
- Listened actively and took notes
- Initially gained understanding of situation, not present to observe

## 
Was aware of time-sensitive situation 

Asked about non-apparent disability 

Asked flight attendant if she had asked passenger about carry-on

Asked passenger about carry-on and medication

- Was aware of time-sensitive situation
- Asked about non-apparent disability
- Asked flight attendant if she had asked passenger about carry-on
- Asked passenger about carry-on and medication

**CRO Role Play Debrief  (cont’d)**

## 

Explained shared goal of safe and pleasant flight

Stated passenger’s legal right to keep medication close under 382.41(c) 

- Explained shared goal of safe and pleasant flight
- Stated passenger’s legal right to keep medication close under 382.41(c)

**CRO Role Play Debrief  (cont’d)**

## 
Might consult medical personnel re: possibility of medical emergency during flight under 382.7(c); 382.53(b)(1)(iii)

Acknowledged previous escalation of situation

Restated goal of accommodating passenger’s needs while complying with safety regulations and Part 382

Allowed venting and acknowledged difficult situation

- Might consult medical personnel re: possibility of medical emergency during flight under 382.7(c); 382.53(b)(1)(iii)
- Acknowledged previous escalation of situation
- Restated goal of accommodating passenger’s needs while complying with safety regulations and Part 382
- Allowed venting and acknowledged difficult situation

**CRO Role Play Debrief  (cont’d)**

## 
Handle write up in accordance with law under 382.63(b)(2) and carrier policy  

Provide written statement summarizing facts and any steps carrier proposes to take under 382.65(a)(5)(ii) and (iii)  

Provide written statement at airport or within 10 calendar days of complaint under 382.65(a)(5)(iv)

- Handle write up in accordance with law under 382.63(b)(2) and carrier policy
- Provide written statement summarizing facts and any steps carrier proposes to take under 382.65(a)(5)(ii) and (iii)
- Provide written statement at airport or within 10 calendar days of complaint under 382.65(a)(5)(iv)

**CRO Role Play Debrief  (cont’d)**

## BOARDING, DEPLANING, AND MAKING FLIGHT CONNECTIONS

- 	Boarding and Deplaning Assistance - Overview of Law
- If requested, carrier must provide boarding or deplaning assistance under 382.39(a)
- Services personnel
- Ground wheelchairs
- Boarding wheelchairs

## 
On-board wheelchairs (where required by law)

Ramps or mechanical lifts under 382.39(a)(1)

Wheelchair not always appropriate, required, or desired  

Train to proficiency in use of equipment and procedures 

- On-board wheelchairs (where required by law)
- Ramps or mechanical lifts under 382.39(a)(1)
- Wheelchair not always appropriate, required, or desired
- Train to proficiency in use of equipment and procedures

**Boarding, Deplaning and Making Flight Connections  (cont’d)**

## 
Safety and dignity of passengers receiving assistance under  382.40(d) and 382.40a(d)     

Size of the aircraft affects type of assistance under 382.40 and 382.40a

No physically hand-carrying under 382.39(a)(2)

- Safety and dignity of passengers receiving assistance under  382.40(d) and 382.40a(d)
- Size of the aircraft affects type of assistance under 382.40 and 382.40a
- No physically hand-carrying under 382.39(a)(2)

**Boarding, Deplaning and Making Flight Connections  (cont’d)**

## 
Q.	How quickly must boarding and deplaning assistance be provided?  

Provide “timely” boarding and deplaning assistance        under 382.39(a)

382.41(f) requires “timely return of passengers’ wheelchairs and other assistive devices” 

382.40(d) and 382.40a(d) require training to proficiency regarding use of equipment and safety and dignity of passengers 

**Q.****	****How quickly must boarding and deplaning assistance be provided?**
- Provide “timely” boarding and deplaning assistance        under 382.39(a)
- 382.41(f) requires “timely return of passengers’ wheelchairs and other assistive devices”
- 382.40(d) and 382.40a(d) require training to proficiency regarding use of equipment and safety and dignity of passengers** **

**Boarding, Deplaning and Making Flight Connections  (cont’d)**

## Q.  What does “timely” mean? 

“As soon as practicable” 

Case-by-case basis

- “As soon as practicable”
- Case-by-case basis

**Boarding, Deplaning and Making Flight Connections  (cont’d)**

## 
Q.	Are passengers who need boarding or deplaning assistance required to provide advance notice?

	No.  

Under 382.40(c)(3) and 382.40a(c)(3), if boarding assistance is provided by mechanical lift, carriers may require check in an hour before flight

Even if passenger does not check in an hour before flight, carrier must provide boarding assistance as long as no flight delay results    

**Q.****	****Are passengers who need boarding or deplaning assistance required to provide advance notice?**
- 	No.
- Under 382.40(c)(3) and 382.40a(c)(3), if boarding assistance is provided by mechanical lift, carriers may require check in an hour before flight
- Even if passenger does not check in an hour before flight, carrier must provide boarding assistance as long as no flight delay results

**Boarding, Deplaning and Making Flight Connections  (cont’d)**

## 

Q.	Where does providing assistance with enplaning and deplaning begin and end? 

	If requested, can begin at curbside at entrance to airport terminal.  Deplaning assistance would end at curbside the exit of airport terminal or elsewhere in terminal if requested.

Appendix III:  Frequently Asked Questions, p. 3

**Q.****	****Where does providing assistance with enplaning and deplaning begin and end?**** **
- 	If requested, can begin at curbside at entrance to airport terminal.  Deplaning assistance would end at curbside the exit of airport terminal or elsewhere in terminal if requested.
- Appendix III:  Frequently Asked Questions, p. 3

**Boarding, Deplaning and Making Flight Connections  (cont’d)**

## 
Q.	Does your carrier have any policies (including FAA safety considerations) that impact 	boarding and deplaning assistance?

	It depends on carrier’s policy.

**Q.****	****Does your carrier have any policies (including FAA safety considerations) that impact ****	****boarding and deplaning assistance?**
- 	It depends on carrier’s policy.

**Boarding, Deplaning and Making Flight Connections  (cont’d)**

## Connecting Assistance – Overview of Law

If requested, carrier must provide assistance with transportation between gates under 382.39(a)  

Regardless of interline agreement

Services of personnel

Wheelchairs

- If requested, carrier must provide assistance with transportation between gates under 382.39(a)
- Regardless of interline agreement
- Services of personnel
- Wheelchairs

**Boarding, Deplaning and Making Flight Connections  (cont’d)**

## 
Ramps or mechanical lifts under 382.39(a)(1)  

Can’t leave passenger unattended in ground wheelchair if not independently mobile  more than 30 minutes under 382.39(a)(3)

No advance notice required

- Ramps or mechanical lifts under 382.39(a)(1)
- Can’t leave passenger unattended in ground wheelchair if not independently mobile  more than 30 minutes under 382.39(a)(3)
- No advance notice required

**Boarding, Deplaning and Making Flight Connections  (cont’d)**

## 
Q.	When is connecting assistance complete?

	When delivering carrier escorts passenger to connecting carrier’s gate or other location where receiving carrier has accepted responsibility under 382.39(a).

**Q.****	****When is connecting assistance complete?**
- 	When delivering carrier escorts passenger to connecting carrier’s gate or other location where receiving carrier has accepted responsibility under 382.39(a).

**Boarding, Deplaning and Making Flight Connections  (cont’d)**

## Demonstrating Law on Deplaning Assistance – Role Play

## DEPLANING ASSISTANCE ROLE PLAY DEBRIEF

- Did not put people on defensive
- Introduced herself and understood passenger’s right to speak with CRO
- Listened actively and took notes
- Initially gained understanding of situation, not present to observe

## 
Was aware of time-sensitive situation 

Common interest of getting personal wheelchair to door of the plane

Asked for details about status of wheelchair’s return

Generated options for hurrying process along

- Was aware of time-sensitive situation
- Common interest of getting personal wheelchair to door of the plane
- Asked for details about status of wheelchair’s return
- Generated options for hurrying process along

**Deplaning Assistance Role Play Debrief  ****	****	****	****	****	****    (cont’d)**

## 
Apologized for delay and indicated management would receive notice

Acknowledged that passenger was entitled to timely deplaning assistance (382.39(a)) and use of his own wheelchair (382.41(f))

- Apologized for delay and indicated management would receive notice
- Acknowledged that passenger was entitled to timely deplaning assistance (382.39(a)) and use of his own wheelchair (382.41(f))

**Deplaning Assistance Role Play Debrief  ****	****	****	****	****	****    (cont’d)**

## 
Acknowledged previous escalation of situation 

Restated goal of accommodating passenger’s needs while complying with safety regulations and Part 382

Allowed venting and acknowledged difficult situation

- Acknowledged previous escalation of situation
- Restated goal of accommodating passenger’s needs while complying with safety regulations and Part 382
- Allowed venting and acknowledged difficult situation

**Deplaning Assistance Role Play Debrief  ****	****	****	****	****	****    (cont’d)**

## Handle write up in accordance with law under 382.63(b)(2) and carrier policy  

Provide written statement summarizing facts and any steps carrier proposes to take under 382.65(a)(5)(ii) and (iii)  

Provide written statement at airport or within 10 calendar days of complaint under 382.65(a)(5)(iv)

- Provide written statement summarizing facts and any steps carrier proposes to take under 382.65(a)(5)(ii) and (iii)
- Provide written statement at airport or within 10 calendar days of complaint under 382.65(a)(5)(iv)

**Deplaning Assistance Role Play Debrief  ****	****	****	****	****	****    (cont’d)**

## Sources of Information

Passenger 

Contractor has information about equipment retrieval 

Pilot and flight attendant draw from experience 

- Passenger
- Contractor has information about equipment retrieval
- Pilot and flight attendant draw from experience

**Deplaning Assistance Role Play Debrief  ****	****	****	****	****	****    (cont’d)**

## 
Other carrier personnel 

382.39(a), 382.41(f)(2) 

TAM 

Carrier policies  

- Other carrier personnel
- 382.39(a), 382.41(f)(2)
- TAM
- Carrier policies

**Deplaning Assistance Role Play Debrief  ****	****	****	****	****	****    (cont’d)**

## Sensitivity and Awareness 

Speak directly to passenger and stoop to communicate at eye level  

Look at passenger when speaking to him 

Ask if aisle chair is an option for short period of time  

Ask about other deplaning options

- Speak directly to passenger and stoop to communicate at eye level
- Look at passenger when speaking to him
- Ask if aisle chair is an option for short period of time
- Ask about other deplaning options

**Deplaning Assistance Role Play Debrief  ****	****	****	****	****	****    (cont’d)**

## Communication 

Use “person first” language when addressing and referring to passenger

Acknowledge patience and frustration

Apologize for problem

Listen actively before formulating response

- Use “person first” language when addressing and referring to passenger
- Acknowledge patience and frustration
- Apologize for problem
- Listen actively before formulating response

**Deplaning Assistance Role Play Debrief  ****	****	****	****	****	****    (cont’d)**

## 
Acknowledge pressures of work environment and time sensitivity   

Make eye contact  

Clarify information for yourself and others

- Acknowledge pressures of work environment and time sensitivity
- Make eye contact
- Clarify information for yourself and others

**Deplaning Assistance Role Play Debrief  ****	****	****	****	****	****    (cont’d)**

## Conflict Resolution  

Be prepared to deal with anger and frustration and some fear  

Write things down and confirm accuracy

Remind parties about shared interest in safe transfer and providing deplaning assistance

- Be prepared to deal with anger and frustration and some fear
- Write things down and confirm accuracy
- Remind parties about shared interest in safe transfer and providing deplaning assistance

**Deplaning Assistance Role Play Debrief  ****	****	****	****	****	****    (cont’d)**

## 

Reiterate carrier’s legal responsibilities

Generate options consistent with Part 382 and carrier policies  

- Reiterate carrier’s legal responsibilities
- Generate options consistent with Part 382 and carrier policies

**Deplaning Assistance Role Play Debrief  ****	****	****	****	****	****    (cont’d)**

## SERVICE ANIMALS

**Q.  What is the definition of a service animal?**
- Any animal individually trained to perform or capable of performing functions to assist a qualified person with a disability, or
- Any animal necessary for emotional well-being

## SERVICE ANIMALS (cont’d)

**Q.****	****May service animals remain with the passenger in the cabin?**
- 	Yes, consistent with FAA safety requirements.

**Service Animals  (cont’d)**

## Q.	How do you know if it’s a service animal   or pet?

	Training or innate ability to assist person with a disability  

Ask passenger

Accept credible verbal assurances

If not emotional support animal, accept identification cards, other written documentation, physical indicators

- 	Training or innate ability to assist person with a disability
- Ask passenger
- Accept credible verbal assurances
- If not emotional support animal, accept identification cards, other written documentation, physical indicators

**Service Animals  (cont’d)**

## 
Q.	What could you ask a passenger if you are unsure if the animal is a service animal?

How does this animal assist with your disability?

What has this animal been trained to do?

Would you describe how the animal performs tasks or carries out functions for you? 

**Q.****	****What could you ask a passenger if you are unsure if the animal is a service animal?**
- How does this animal assist with your disability?
- What has this animal been trained to do?
- Would you describe how the animal performs tasks or carries out functions for you?

**Service Animals  (cont’d)**

## 
Q.	What about a passenger accompanied by an emotional support animal?

	Carriers may require documentation to verify that an animal is an emotional support animal

Such documentation is not required by law

**Q.****	****What about a passenger accompanied by an emotional support animal?**
- 	Carriers may require documentation to verify that an animal is an emotional support animal
- Such documentation is not required by law

**Service Animals  (cont’d)**

## 
If documentation is required by carrier, it should be dated within a year of date of travel and state:

passenger has mental health-related disability;

passenger needs animal for mental-health condition; and

provider of letter is licensed mental-health professional (or medical doctor) and passenger is under individual’s professional care

- If documentation is required by carrier, it should be dated within a year of date of travel and state:
- passenger has mental health-related disability;
- passenger needs animal for mental-health condition; and
- provider of letter is licensed mental-health professional (or medical doctor) and passenger is under individual’s professional care

**Service Animals  (cont’d)**

## 
Q.	What if a service animal is behaving inappropriately in a public setting?

Even with verification, carriers may refuse transportation if service animal’s behavior in public:

Poses direct threat to health or safety of others, or

Would cause significant disruption on board (“fundamental alteration” under 382.7(c), e.g., urinating, biting, etc.)

**Q.****	****What if a service animal is behaving inappropriately in a public setting?**
- Even with verification, carriers may refuse transportation if service animal’s behavior in public:
- Poses direct threat to health or safety of others, or
- Would cause significant disruption on board (“fundamental alteration” under 382.7(c), *e.g.*, urinating, biting, etc.)

**Service Animals  (cont’d)**

## 
If carrier refuses transportation of service animal:

Offer alternative accommodations in accordance with Part 382 and carrier’s policy regarding carriage of animals    

- If carrier refuses transportation of service animal:
- Offer alternative accommodations in accordance with Part 382 and carrier’s policy regarding carriage of animals

**Service Animals  (cont’d)**

## 
Q.	Can certain service animals, e.g., snakes and spiders, pose unavoidable safety and/or public health concerns?

	Yes, release of such an animal could pose a direct threat to health or safety of others.

**Q.****	****Can certain service animals, *****e.g.*****, snakes and spiders, pose unavoidable safety and/or public health concerns?**
- 	Yes, release of such an animal could pose a direct threat to health or safety of others.

**Service Animals  (cont’d)**

## 
Q. Can a pig or a miniature horse be trained      
     as a service animal or function as an    
     emotional support animal?

	   It depends, carriers handle those on case-by-case        
       basis considering size, weight, foreign country restrictions, whether animal would pose a direct threat to health or safety of others or cause a fundamental alteration or disruption in cabin service.

**Q. Can a pig or a miniature horse be trained      **
**     ****as a service animal or function as an    **
**     ****emotional support animal?**
- 	   It depends, carriers handle those on case-by-case
-        basis considering size, weight, foreign country restrictions, whether animal would pose a direct threat to health or safety of others or cause a fundamental alteration or disruption in cabin service.

**Service Animals  (cont’d)**

## Q.	Is a passenger with a disability accompanied by a service animal entitled to a seating accommodation?

Yes.

- Yes.

**Service Animals  (cont’d)**

## 
Carriers must allow service animal to sit close to its user under 382.55(a)(2)

As long as FAA safety regulations followed

Under seat in front of passenger, or

Held by user as adult would hold an infant assuming animal is roughly the same or smaller size than a 2 year old  

- Carriers must allow service animal to sit close to its user under 382.55(a)(2)
- As long as FAA safety regulations followed
- Under seat in front of passenger, or
- Held by user as adult would hold an infant assuming animal is roughly the same or smaller size than a 2 year old

**Service Animals  (cont’d)**

## Sources of information

Appendix VI:  DOT Guidance Concerning Service Animals in Air Transportation

FAA Flight Standards Information Bulletin for Air Transportation (FSAT) #04-01A, “Location and Placement of Service Animals Engaged in Public Air Transportation” http://www.faa.gov/avr/afs/fsat/fsatl.htm

- Appendix VI:  DOT Guidance Concerning Service Animals in Air Transportation
- FAA Flight Standards Information Bulletin for Air Transportation (FSAT) #04-01A, “Location and Placement of Service Animals Engaged in Public Air Transportation” _http://www.faa.gov/avr/afs/fsat/fsatl.htm_

**Service Animals  (cont’d)**

## Depending on carrier’s policy, passengers accompanied by service animals may 

pre-board

request an advance seat assignment

Passenger generally knows most suitable seat for service animal     

- pre-board
- request an advance seat assignment
- Passenger generally knows most suitable seat for service animal

**Service Animals  (cont’d)**

## If requested, carriers must provide

a bulkhead seat if one exists, or

a seat other than a bulkhead seat, depending on the passenger’s request under 382.38(a)(3)  

- a bulkhead seat if one exists, or
- a seat other than a bulkhead seat, depending on the passenger’s request under 382.38(a)(3)

**Service Animals  (cont’d)**

## 
If carrier has advance seat assignment system, passenger must self-identify

If carrier has no advance seat assignment system, passenger may pre-board to select most suitable seat under 382.38(d)  

- If carrier has advance seat assignment system, passenger must self-identify
- If carrier has no advance seat assignment system, passenger may pre-board to select most suitable seat under 382.38(d)

**Service Animals  (cont’d)**

## No undue burden or fundamental alteration of 
services under 382.7(c) when seating passengers 
accompanied by service animals

- services under 382.7(c) when seating passengers
- accompanied by service animals

**Service Animals  (cont’d)**

## DOT does not require:

Asking other passengers to give up space in front to accommodate someone else’s service animal;

Denying transportation to accommodate passenger with service animal;

Furnishing more than one seat per ticket; or

Providing seat in class of service other than one purchased by passenger

- Asking other passengers to give up space in front to accommodate someone else’s service animal;
- Denying transportation to accommodate passenger with service animal;
- Furnishing more than one seat per ticket; or
- Providing seat in class of service other than one purchased by passenger

**Service Animals  (cont’d)**

## Demonstrating Law on Service Animals – Short Exercise

## SERVICE ANIMALS SHORT EXERCISE DEBRIEF

- Passenger entitled to have monkey in close proximity
- Given monkey’s size, sitting on lap okay
- Option to move seatmate
- If no other seats available, allay seatmate’s concerns
- Not required by law

## Sources of Information

Passenger

Other carrier personnel  

382.7(c), 382.55(a)(1) and (2) 

- Passenger
- Other carrier personnel
- 382.7(c), 382.55(a)(1) and (2)

**Service Animals Short Exercise Debrief  (cont’d)**

## 
DOT Guidance on Service Animals 

FAA document 

TAM

Carrier policies

- DOT Guidance on Service Animals
- FAA document
- TAM
- Carrier policies

**Service Animals Short Exercise Debrief  (cont’d)**

## Sensitivity and Awareness 

Be aware of service animal training to provide numerous services or functions

Don’t distract service animal  

Stoop to communicate with passenger at eye level 

Look at person when speaking to her  

Respect privacy of passenger accompanied by service animal

- Be aware of service animal training to provide numerous services or functions
- Don’t distract service animal
- Stoop to communicate with passenger at eye level
- Look at person when speaking to her
- Respect privacy of passenger accompanied by service animal

**Service Animals Short Exercise Debrief  (cont’d)**

## Communication 

Use “person first” language when addressing and referring to passenger

Acknowledge discomfort, but explain legal requirements

Listen actively before formulating response

- Use “person first” language when addressing and referring to passenger
- Acknowledge discomfort, but explain legal requirements
- Listen actively before formulating response

**Service Animals Short Exercise Debrief  (cont’d)**

## 
Use respectful tone

Maintain professional manner

Make eye contact  

Clarify information

- Use respectful tone
- Maintain professional manner
- Make eye contact
- Clarify information

**Service Animals Short Exercise Debrief  (cont’d)**

## Conflict Resolution  

Be prepared to deal with anger and frustration and some fear  

Write things down and confirm accuracy

Remind parties about shared interest in safe transfer and accommodating passenger traveling with service animal

Reiterate carrier’s legal responsibilities

Generate options consistent with Part 382 and carrier policies  

- Be prepared to deal with anger and frustration and some fear
- Write things down and confirm accuracy
- Remind parties about shared interest in safe transfer and accommodating passenger traveling with service animal
- Reiterate carrier’s legal responsibilities
- Generate options consistent with Part 382 and carrier policies

**Service Animals Short Exercise Debrief  (cont’d)**

## ASSISTIVE DEVICES

- Definition of Assistive Device
- Any piece of equipment to assist passenger with a disability carry out major life activity

## Carrying out major life activity includes:

caring for oneself
performing manual tasks
performing functions of daily life such as
	walking, seeing, hearing, speaking, breathing, learning and working

Assistive devices include medical devices,
medications, and bags/cases to carry them

- caring for oneself
- performing manual tasks
- performing functions of daily life such as
- 	walking, seeing, hearing, speaking, breathing, learning and working
- Assistive devices include medical devices,
- medications, and bags/cases to carry them

**Assistive Devices  (cont’d)**

## Legal requirements for stowage and treatment 
under 382.41  

Ventilator/respirators

Non-spillable batteries (needed for assistive device)

Canes

Wheelchairs

Other assistive devices 

- under 382.41
- Ventilator/respirators
- Non-spillable batteries (needed for assistive device)
- Canes
- Wheelchairs
- Other assistive devices

**Assistive Devices  (cont’d)**

## 
Passengers can bring assistive devices on board if 
	consistent with FAA safety regulations

Passengers can stow canes/other assistive devices close to seats under 382.41(c)

- Passengers can bring assistive devices on board if
- 	consistent with FAA safety regulations
- Passengers can stow canes/other assistive devices close to seats under 382.41(c)

**Assistive Devices  (cont’d)**

## 
Assistive devices not counted toward limit on carry-on items under 382.41(d)

Wheelchairs and other assistive devices stowed in baggage compartment with priority over other cargo and baggage under 382.41(f)(3)

No charge imposed if weight limit on checked baggage exceeded under 382.57

- Assistive devices not counted toward limit on carry-on items under 382.41(d)
- Wheelchairs and other assistive devices stowed in baggage compartment with priority over other cargo and baggage under 382.41(f)(3)
- No charge imposed if weight limit on checked baggage exceeded under 382.57

**Assistive Devices  (cont’d)**

## Folding, collapsible, or breakdown battery-powered wheelchairs or components thereof may be stowed:

In overhead compartments or under seats consistent with FAA regulations under 382.41(e)(1)

- In overhead compartments or under seats consistent with FAA regulations under 382.41(e)(1)

**Assistive Devices  (cont’d)**

## 
If the aircraft contains closet or storage area big enough to accommodate passenger’s wheelchair, carrier must designate it as priority stowage space for at least one passenger’s wheelchair

If passenger pre-boards, may stow wheelchair in designated storage space with priority over other carry-on items

- If the aircraft contains closet or storage area big enough to accommodate passenger’s wheelchair, carrier must designate it as priority stowage space for at least one passenger’s wheelchair
- If passenger pre-boards, may stow wheelchair in designated storage space with priority over other carry-on items

**Assistive Devices  (cont’d)**

## 
If passenger does not pre-board, may stow wheelchair in designated storage space on first-come, first-served basis under 382.41(e)(2)  

If no on-board stowage area big enough for wheelchair, carrier must stow it in cargo compartment with priority over other luggage under 382.41(e)(3)   

- If passenger does not pre-board, may stow wheelchair in designated storage space on first-come, first-served basis under 382.41(e)(2)
- If no on-board stowage area big enough for wheelchair, carrier must stow it in cargo compartment with priority over other luggage under 382.41(e)(3)

**Assistive Devices  (cont’d)**

## 
When wheelchair cannot be stowed in cabin, carriers must ensure timely checking and return of passenger’s wheelchair/assistive device close to door of aircraft so passenger can use own equipment under 382.41(f)      

- When wheelchair cannot be stowed in cabin, carriers must ensure timely checking and return of passenger’s wheelchair/assistive device close to door of aircraft so passenger can use own equipment under 382.41(f)

**Assistive Devices  (cont’d)**

## 
If requested, return wheelchair/assistive device at baggage claim area under 382.41(f)(1)

When wheelchair cannot be stowed in cabin, must stow passenger’s wheelchair/assistive device in baggage compartment with priority under 382.41(f)(3)

- If requested, return wheelchair/assistive device at baggage claim area under 382.41(f)(1)
- When wheelchair cannot be stowed in cabin, must stow passenger’s wheelchair/assistive device in baggage compartment with priority under 382.41(f)(3)

**Assistive Devices  (cont’d)**

## 
Must be among first items retrieved from baggage compartment under 382.41(f)(2)

If giving priority to wheelchairs/assistive devices “bumps” passengers’ non-assistive device-related baggage

Use best efforts to ensure non-assistive device-related baggage reaches destination within four hours 

- Must be among first items retrieved from baggage compartment under 382.41(f)(2)
- If giving priority to wheelchairs/assistive devices “bumps” passengers’ non-assistive device-related baggage
- Use best efforts to ensure non-assistive device-related baggage reaches destination within four hours

**Assistive Devices  (cont’d)**

## Battery-Powered Wheelchairs

Carriers must accept battery-powered wheelchairs as checked baggage unless baggage compartment size and aircraft airworthiness considerations prohibit it under 382.41(g) 

- Carriers must accept battery-powered wheelchairs as checked baggage unless baggage compartment size and aircraft airworthiness considerations prohibit it under 382.41(g)

**Assistive Devices  (cont’d)**

## 
Carriers may require one-hour advance check-in to have battery-powered wheelchair transported (including in cabin where required) under 382.41(g)(1)

Even without advance check-in carriers must make reasonable effort to transport wheelchair as long as no flight delay 

- Carriers may require one-hour advance check-in to have battery-powered wheelchair transported (including in cabin where required) under 382.41(g)(1)
- Even without advance check-in carriers must make reasonable effort to transport wheelchair as long as no flight delay

**Assistive Devices  (cont’d)**

## 
No removal and separate packaging of battery required if

battery on wheelchair has been labeled by manufacturer as non-spillable or 

wheelchair with a spillable battery can be loaded, stored, secured, and unloaded in upright position

- No removal and separate packaging of battery required if
- battery on wheelchair has been labeled by manufacturer as non-spillable or
- wheelchair with a spillable battery can be loaded, stored, secured, and unloaded in upright position

**Assistive Devices  (cont’d)**

## 
Carriers may remove and package separately a damaged/leaking battery under 382.41(g)(2)

When necessary to detach battery, carriers must provide packaging and package battery consistent with hazardous materials regulations under 382.41(g)(3) 

- Carriers may remove and package separately a damaged/leaking battery under 382.41(g)(2)
- When necessary to detach battery, carriers must provide packaging and package battery consistent with hazardous materials regulations under 382.41(g)(3)

**Assistive Devices  (cont’d)**

## 
Carriers must not charge for such packaging under 382.57  

Carriers must not drain batteries under 382.41(g)(4) 

If requested, carriers must stow wheelchair in cabin consistent with above requirements

- Carriers must not charge for such packaging under 382.57
- Carriers must not drain batteries under 382.41(g)(4)
- If requested, carriers must stow wheelchair in cabin consistent with above requirements

**Assistive Devices  (cont’d)**

## 
If wheelchair can be stowed in cabin without removing battery, then carriers must not remove battery

If wheelchair cannot be stowed in cabin without removing battery, then carriers must remove and stow battery in baggage compartment

In this case, carriers must permit wheelchair, with battery removed, to be stowed in the cabin under 382.41(g)(5)    

- If wheelchair can be stowed in cabin without removing battery, then carriers must not remove battery
- If wheelchair _**cannot**_ be stowed in cabin without removing battery, then carriers must remove and stow battery in baggage compartment
- In this case, carriers must permit wheelchair, with battery removed, to be stowed in the cabin under 382.41(g)(5)

**Assistive Devices  (cont’d)**

## 
Carriers must permit written instructions concerning disassembly/reassembly of passengers’ wheelchairs under 382.41(h)

When wheelchairs/assistive devices disassembled for stowage, carriers must reassemble them and ensure prompt return

Carriers must return wheelchair/assistive device to passenger in same condition in which they received it under 382.43(a)  

- Carriers must permit written instructions concerning disassembly/reassembly of passengers’ wheelchairs under 382.41(h)
- When wheelchairs/assistive devices disassembled for stowage, carriers must reassemble them and ensure prompt return
- Carriers must return wheelchair/assistive device to passenger in same condition in which they received it under 382.43(a)

**Assistive Devices  (cont’d)**

## 
On domestic flights, normal baggage liability limits do not apply to loss, damage, or delay concerning wheelchairs/assistive devices

Criterion for calculating compensation must be original price under 382.43(b)  

- On domestic flights, normal baggage liability limits do not apply to loss, damage, or delay concerning wheelchairs/assistive devices
- Criterion for calculating compensation must be original price under 382.43(b)

**Assistive Devices  (cont’d)**

## Demonstrating Law on Assistive Devices – Role Play

## ASSISTIVE DEVICES ROLE PLAY DEBRIEF

- No assistive device definition in Part 382but DOT interpretation available
- Handle on case-by-case basis
- Generally, carriers must transport and cannot charge under 382.57
- Under 382.7(c) no undue burden or fundamental alteration of program
- Transporting bed = undue burden / fundamental alteration

## Is passenger qualified individual with a disability as defined in 382.5? 

If so, does bed assist with major life activity?  

If reservation agent determines bed is not assistive device, explain policy regarding contents of the cargo compartment (dimensions, weight limitations, fees, etc.).  

Consult CRO and other carrier personnel to determine feasibility  

- If so, does bed assist with major life activity?
- If reservation agent determines bed is not assistive device, explain policy regarding contents of the cargo compartment (dimensions, weight limitations, fees, etc.).
- Consult CRO and other carrier personnel to determine feasibility

**Assistive Devices Role Play Debrief  ****	****	****	****         (cont’d)**

## Sources of Information

Passenger 

Other carrier personnel draw from experience

CRO

Medical personnel

- Passenger
- Other carrier personnel draw from experience
- CRO
- Medical personnel

**Assistive Devices Role Play Debrief  ****	****	****	****         (cont’d)**

## 
382.5, 382.57 

TAM

FAA regulations

Carrier policies  

- 382.5, 382.57
- TAM
- FAA regulations
- Carrier policies

**Assistive Devices Role Play Debrief  ****	****	****	****         (cont’d)**

## Sensitivity and Awareness 

Respect privacy

Explore whether if qualified individual with a disability under ACAA   

- Respect privacy
- Explore whether if qualified individual with a disability under ACAA

**Assistive Devices Role Play Debrief  ****	****	****	****         (cont’d)**

## Communication 

Use “person first” language when addressing and referring to passenger

Listen actively before formulating response

Maintain professional manner  

Use respectful tone

- Use “person first” language when addressing and referring to passenger
- Listen actively before formulating response
- Maintain professional manner
- Use respectful tone

**Assistive Devices Role Play Debrief  ****	****	****	****         (cont’d)**

## 
Explain carrier’s legal responsibility to protect civil rights

Raise concern about whether passenger covered under ACAA  

If not, state respectfully but authoritatively that carrier will not transport bed free of charge

Explain may not be feasible to transport bed depending on carrier’s fleets, policies

- Explain carrier’s legal responsibility to protect civil rights
- Raise concern about whether passenger covered under ACAA
- If not, state respectfully but authoritatively that carrier will not transport bed free of charge
- Explain may not be feasible to transport bed depending on carrier’s fleets, policies

**Assistive Devices Role Play Debrief  ****	****	****	****         (cont’d)**

## Conflict Resolution  

Be prepared to deal with anger and frustration  

Write things down and confirm accuracy

Remind passenger about shared interest in safe travel and accommodation of all passengers

Reiterate carrier’s legal responsibilities

- Be prepared to deal with anger and frustration
- Write things down and confirm accuracy
- Remind passenger about shared interest in safe travel and accommodation of all passengers
- Reiterate carrier’s legal responsibilities

**Assistive Devices Role Play Debrief  ****	****	****	****         (cont’d)**

## 

Explain carrier policies regarding transportation of larger/heavier items    

Generate options consistent with Part 382 and carrier policies  

- Explain carrier policies regarding transportation of larger/heavier items
- Generate options consistent with Part 382 and carrier policies

**Assistive Devices Role Play Debrief  ****	****	****	****         (cont’d)**

## SEATING ASSIGNMENTS AND ACCOMMODATIONS

- Seating Assignments and Accommodations -Overview of Law
- Only Safety Affects Seat Assignments
- No refusal of transportation because of appearance or involuntary behavior that may offend, annoy, or inconvenience under 382.31(b)

## 
No exclusion from exit row or other location

No seat assignment requirement based on passenger’s disability except to comply with FAA safety requirements under 382.37(a) 

Carriers must offer other seat location in same class of service as alternative to refusing transportation under 382.37(b)

- No exclusion from exit row or other location
- No seat assignment requirement based on passenger’s disability except to comply with FAA safety requirements under 382.37(a)
- Carriers must offer other seat location in same class of service as alternative to refusing transportation under 382.37(b)

**Seating Assignments and Accommodations (cont’d)**

## Demonstrating Law on Seating Assignments – Short Exercise

## SEATING ASSIGNMENT SHORT EXERCISE DEBRIEF

- As long as safety not an issue, carrier cannot restrict a passenger from particular seat
- If passenger touches others, safety considerations could require own row, if available, as alternative to refusing transportation
- If physical or verbal manifestations of Tourette’s syndrome jeopardize others, could create safety concerns

## 
Refusing transportation could be appropriate 

If annoyance, not safety concern, no seating assignment restriction  

- Refusing transportation could be appropriate
- If annoyance, not safety concern, no seating assignment restriction

**Seating Assignments and Accommodations (cont’d)**

## Sources of Information

Passenger

Other carrier personnel  

382.31(b), 382.37(a) 

- Passenger
- Other carrier personnel
- 382.31(b), 382.37(a)

**Seating Assignments and Accommodations (cont’d)**

## 
FAA document 

TAM

Carrier policies

- FAA document
- TAM
- Carrier policies

**Seating Assignments and Accommodations (cont’d)**

## Sensitivity and Awareness 

Look at person when speaking to him/her  

Respect privacy

Consider non-apparent disability or intermittent disability

- Look at person when speaking to him/her
- Respect privacy
- Consider non-apparent disability or intermittent disability

**Seating Assignments and Accommodations (cont’d)**

## Communication 

Use “person first” language when addressing and referring to passenger

Acknowledge discomfort, but explain legal requirements

Listen actively before formulating response

- Use “person first” language when addressing and referring to passenger
- Acknowledge discomfort, but explain legal requirements
- Listen actively before formulating response

**Seating Assignments and Accommodations (cont’d)**

## 
Use respectful tone

Maintain professional manner

Make eye contact  

Clarify information

- Use respectful tone
- Maintain professional manner
- Make eye contact
- Clarify information

**Seating Assignments and Accommodations (cont’d)**

## Conflict Resolution  

Be prepared to deal with discomfort

Write things down and confirm accuracy

Remind parties about shared interest in safe transfer and accommodation of all passengers and crew

- Be prepared to deal with discomfort
- Write things down and confirm accuracy
- Remind parties about shared interest in safe transfer and accommodation of all passengers and crew

**Seating Assignments and Accommodations (cont’d)**

## 

Reiterate carrier’s responsibilities under law and DOT guidance

Generate options consistent with Part 382 and carrier policies

Exercise best judgment under circumstances   

- Reiterate carrier’s responsibilities under law and DOT guidance
- Generate options consistent with Part 382 and carrier policies
- Exercise best judgment under circumstances

**Seating Assignments and Accommodations (cont’d)**

## If passenger self-identifies and requests seating accommodation, carriers are required to provide four seating accommodations, as follows:

First, for passenger using aisle chair to access aircraft, provide seat with moveable armrest if one exists under 382.3(a)(1)

Second, for passenger who travels with care attendant, provide seat for attendant next to passenger under 382.38(a)(2)(iii)

**First**, for passenger using aisle chair to access aircraft, provide seat with moveable armrest if one exists under 382.3(a)(1)
**Second**, for passenger who travels with care attendant, provide seat for attendant next to passenger under 382.38(a)(2)(iii)

**Seating Assignments and Accommodations (cont’d)**

## 

Third, for passenger accompanied by service animal, provide bulkhead or a seat other than a bulkhead seat depending on passenger’s request in same class of service under 382.38(a)(3)

Fourth, for passenger who has fused/immobilized leg, provide bulkhead or other seat with more legroom than other seats on side of aisle that best accommodates passenger in same class of service under 382.38(a)(4)

**Third**, for passenger accompanied by service animal, provide bulkhead or a seat other than a bulkhead seat depending on passenger’s request in same class of service under 382.38(a)(3)
**Fourth**, for passenger who has fused/immobilized leg, provide bulkhead or other seat with more legroom than other seats on side of aisle that best accommodates passenger in same class of service under 382.38(a)(4)

**Seating Assignments and Accommodations (cont’d)**

## Advance Seat Assignments

Seat “Blocking” Method

Carriers “block” adequate number of seats and must not assign “blocked” seats other than to those entitled until 24 hours before flight

- Seat “Blocking” Method
- Carriers “block” adequate number of seats and must not assign “blocked” seats other than to those entitled until 24 hours before flight

**Seating Assignments and Accommodations (cont’d)**

## 
Even if qualified passenger with disability does not make request 24 hours before flight, carrier must provide requested seating accommodation to extent practicable

But not required to reassign seat assigned to another passenger under 382.38(b)(1)(i), (ii), and (iii)

- Even if qualified passenger with disability does not make request 24 hours before flight, carrier must provide requested seating accommodation to extent practicable
- But not required to reassign seat assigned to another passenger under 382.38(b)(1)(i), (ii), and (iii)

**Seating Assignments and Accommodations (cont’d)**

## Demonstrating Law on Seat “Blocking” Method – Short Exercise

## SEAT “BLOCKING” METHOD SHORT EXERCISE DEBRIEF

- Since passenger made timely request, assign one of “blocked” bulkhead seats under 382.38(b)(1)(ii)
- If passenger had requested bulkhead within 24 hours of flight, would provide bulkhead to extent practicable but not required to reassign seat already assigned under 382.38(b)(1)(iii)

## Advance Seat Assignments

“Priority” Seating Method

Carriers designate “priority” seats for those entitled to seating accommodation

- “Priority” Seating Method
- Carriers designate “priority” seats for those entitled to seating accommodation

**Seating Assignments and Accommodations (cont’d)**

## 
Carriers must provide notice about possible reassignment

Carrier may provide notice through computer reservation system or other appropriate means under 382.38(b)(2)(i)

- Carriers must provide notice about possible reassignment
- Carrier may provide notice through computer reservation system or other appropriate means under 382.38(b)(2)(i)

**Seating Assignments and Accommodations (cont’d)**

## 
Carrier must provide “priority” seat if requested and if passenger entitled to seating accommodation checks in one hour before flight

If all “priority” seats have been assigned to other passengers, carrier must reassign seats to accommodate passenger entitled to seating accommodation under 382.38(b)(2)(ii)  

- Carrier must provide “priority” seat if requested and if passenger entitled to seating accommodation checks in one hour before flight
- If all “priority” seats have been assigned to other passengers, carrier must reassign seats to accommodate passenger entitled to seating accommodation under 382.38(b)(2)(ii)

**Seating Assignments and Accommodations (cont’d)**

## 
If no check-in one hour before flight, carrier must provide requested seating accommodation to extent practicable but not required to reassign seat under 382.38(b)(2)(iii)

- If no check-in one hour before flight, carrier must provide requested seating accommodation to extent practicable but not required to reassign seat under 382.38(b)(2)(iii)

**Seating Assignments and Accommodations (cont’d)**

## Demonstrating Law on “Priority” Seating Method – Short Exercise

## “PRIORITY” SEATING METHOD  SHORT EXERCISE DEBRIEF

- Passenger using aisle chair should have received notice about “priority” seat and possibility of reassignment under 382.38(b)(2)(i)
- Passenger using aisle chair entitled to “priority” seat in row with movable armrest if requested and checked in at least an hour before flight under 382.38(a)(1)

## 
Passenger using aisle chair would be reassigned to seat in row with movable armrest

Passenger with immobilized leg would be assigned fourth “priority” bulkhead seat  

- Passenger using aisle chair would be reassigned to seat in row with movable armrest
- Passenger with immobilized leg would be assigned fourth “priority” bulkhead seat

**“****Priority” Seating Method Short    **
**  ****Exercise Debrief           (cont’d)**

## Other Seating Accommodations for Passengers with Disabilities

Passengers may identify themselves as passengers with disabilities and request seating accommodation under 382.38(c)  

Carriers using “block” method not required to offer “blocked” seat when passenger with disability other than the types of passengers with disabilities entitled to a seating accommodation makes reservation more than 24 hours before flight under 382.38(c)(2)(i)

- Passengers may identify themselves as passengers with disabilities and request seating accommodation under 382.38(c)
- Carriers using “block” method **not** required to offer “blocked” seat when passenger with disability other than the types of passengers with disabilities entitled to a seating accommodation makes reservation more than 24 hours before flight under 382.38(c)(2)(i)

**Seating Assignments and Accommodations (cont’d)**

## 
Carrier must assign any seat not already assigned to another passenger that accommodates passenger’s needs even if seat not available for assignment to general passenger population under 382.38(c)(1)(ii)

- Carrier must assign any seat not already assigned to another passenger that accommodates passenger’s needs even if seat not available for assignment to general passenger population under 382.38(c)(1)(ii)

**Seating Assignments and Accommodations (cont’d)**

## When passengers with disabilities make reservations with carriers using “priority” method, carrier must assign any seat not already assigned to accommodate passenger’s needs, even if a seat is not available for assignment to general passenger population under 382.38(c)(2)(i)

If a passenger with a disability is assigned to a “priority” seat, subject to reassignment under 382.38(c)(2)(ii)

- If a passenger with a disability is assigned to a “priority” seat, subject to reassignment under 382.38(c)(2)(ii)

**Seating Assignments and Accommodations (cont’d)**

## Short exercise: Advance seating assignment other than one of the four types listed under the law - Seat “blocking” method

Must assign remaining bulkhead to passenger with arthritis in spine under 382.38(c)(1)(ii) 

- Must assign remaining bulkhead to passenger with arthritis in spine under 382.38(c)(1)(ii)

**“****Block” Seating Method Short   **
** ****Exercise Debrief (cont’d)**

## Short exercise: Advance seating assignment other than one of the four types listed under the law – “Priority” seating method

Assign passenger with arthritis in spine one of two “priority” seats but notify him that his “priority” seat could be reassigned if another passenger entitled to “priority” seat requests one and checks in one hour before flight under 382.38(c)(2)(ii)

- Assign passenger with arthritis in spine one of two “priority” seats but notify him that his “priority” seat could be reassigned if another passenger entitled to “priority” seat requests one and checks in one hour before flight under 382.38(c)(2)(ii)

**“****Priority” Seating Method Short    **
**  ****Exercise Debrief           (cont’d)**

## No Advance Seat Assignments

If no advance seat assignments system, passengers who self-identify may choose to pre-board (before other passengers entitled to pre-board) and select seats that best meet needs under 382.38(d) 

Carrier must receive written approval from DOT to comply with seat accommodations requirement in another way under 382.38(e)  

- If no advance seat assignments system, passengers who self-identify may choose to pre-board (before other passengers entitled to pre-board) and select seats that best meet needs under 382.38(d)
- Carrier must receive written approval from DOT to comply with seat accommodations requirement in another way under 382.38(e)

**Seating Assignments and Accommodations (cont’d)**

## Other Legal Requirements

Provide seating accommodation when requested even if seat not available to general passenger population under 382.38(f)

If carrier assigns seat to passenger with disability entitled to such seat and another passenger with a disability subsequently requests same seat, no reassignment unless first passenger consents under 382.38(g)

- Provide seating accommodation when requested even if seat not available to general passenger population under 382.38(f)
- If carrier assigns seat to passenger with disability entitled to such seat and another passenger with a disability subsequently requests same seat, no reassignment unless first passenger consents under 382.38(g)

**Seating Assignments and Accommodations (cont’d)**

## 
Must not deny transportation to provide seat accommodation under 382.38(h)  

Not required to provide more than one seat per ticket or seat in different class to accommodate passenger requesting seating accommodation under  382.38(i)

Carriers encouraged to seat disabled passengers needing extra room to accommodate disability next to empty seat if requested and available  

Must comply with all FAA safety requirements under 382.38(j)

- Must not deny transportation to provide seat accommodation under 382.38(h)
- Not required to provide more than one seat per ticket or seat in different class to accommodate passenger requesting seating accommodation under  382.38(i)
- Carriers encouraged to seat disabled passengers needing extra room to accommodate disability next to empty seat if requested and available
- Must comply with all FAA safety requirements under 382.38(j)

**Seating Assignments and Accommodations (cont’d)**

## Demonstrating Law on Seating Assignments – Short Exercise

## ANOTHER SEATING ASSIGNMENT SHORT EXERCISE DEBRIEF

- Because passenger has an immobilized leg and requested seat assignment, carrier must provide bulkhead seat or other seat on side of aisle that best accommodates him under 382.38(a)(4)
- Not required to provide seat in first class because passenger holds economy class ticket under 382.38(i)

## Sources of Information

Passenger

Other carrier personnel  

382.38, 382.45(a)(1) 

- Passenger
- Other carrier personnel
- 382.38, 382.45(a)(1)

**Another Seating Assignment Short Exercise Debrief                 (cont’d)**

## 
FAA document 

TAM

Carrier policies

- FAA document
- TAM
- Carrier policies

**Another Seating Assignment Short Exercise Debrief                 (cont’d)**

## Sensitivity and Awareness 

Look at person when speaking to him/her  

Respect privacy

Be aware that self-identification for seat assignment

- Look at person when speaking to him/her
- Respect privacy
- Be aware that self-identification for seat assignment

**Another Seating Assignment Short Exercise Debrief                 (cont’d)**

## Communication 

Use “person first” language when addressing and referring to passenger

Acknowledge discomfort, but explain legal requirements

Listen actively before formulating response

- Use “person first” language when addressing and referring to passenger
- Acknowledge discomfort, but explain legal requirements
- Listen actively before formulating response

**Another Seating Assignment Short Exercise Debrief                 (cont’d)**

## 
Foster useful information exchange

Provide information about carrier’s policies re seat assignments and aircraft accessibility, including any seats carrier does not make available to qualified individuals with a disability under 382.45(a)(1)

- Foster useful information exchange
- Provide information about carrier’s policies re seat assignments and aircraft accessibility, including any seats carrier does not make available to qualified individuals with a disability under 382.45(a)(1)

**Another Seating Assignment Short Exercise Debrief                 (cont’d)**

## 
Use respectful tone

Maintain professional manner

Make eye contact  

Clarify information

- Use respectful tone
- Maintain professional manner
- Make eye contact
- Clarify information

**Another Seating Assignment Short Exercise Debrief                 (cont’d)**

## Conflict Resolution  

Be prepared to deal with dissatisfaction

Write things down and confirm accuracy

Remind parties about shared interest in safe transfer and accommodation of all passengers and crew

- Be prepared to deal with dissatisfaction
- Write things down and confirm accuracy
- Remind parties about shared interest in safe transfer and accommodation of all passengers and crew

**Another Seating Assignment Short Exercise Debrief                 (cont’d)**

## 

Reiterate carrier’s responsibilities under the law

Exercise best judgment under circumstances 

Provide basis for decision  

- Reiterate carrier’s responsibilities under the law
- Exercise best judgment under circumstances
- Provide basis for decision

**Another Seating Assignment Short Exercise Debrief                 (cont’d)**

## COMMUNICABLE DISEASES/MEDICAL CERTIFICATES/ATTENDANTS 

**Communicable Diseases – Overview of Law**
- Except as described below, carriers must not
- refuse transportation to;
- require medical certificate from; or
- impose condition, restriction, or requirement not imposed on other passengers ON
- 	passenger with communicable disease or infection under 382.51(a)

## 

If passenger with communicable disease or infection poses direct threat to health or safety of others, carrier may take any action listed above  

Direct threat means significant risk to health or safety of others that cannot be eliminated by modification of policies, practices, or procedures, or by provision of auxiliary aids or services

- If passenger with communicable disease or infection poses direct threat to health or safety of others, carrier may take any action listed above
- Direct threat means significant risk to health or safety of others that cannot be eliminated by modification of policies, practices, or procedures, or by provision of auxiliary aids or services

**Communicable Diseases/Medical Certificates/Attendants  (cont’d)**

##   Make individualized assessment based on a    
   reasonable judgment

relying on current medical knowledge or best available objective evidence

  If medical certificate would alleviate concerns or 

  reasonable modification of policies, practices, or   
   procedures would lessen risk to other passengers, 

then consider when making individualized assessment  

-    reasonable judgment
- relying on current medical knowledge or best available objective evidence
-   If medical certificate would alleviate concerns or
-   reasonable modification of policies, practices, or
-    procedures would lessen risk to other passengers,
- then consider when making individualized assessment

**Communicable Diseases/Medical Certificates/Attendants  (cont’d)**

##   If passenger poses direct threat to health and safety of others choose least restrictive option under 382.51(b)(4)

 refuse transportation

 require medical certificate stating that
	- condition not transmittable during flight or
	- measures to prevent transmission under 382.53(c); or

 Impose special condition or restriction (e.g., 	wearing mask)

-  refuse transportation
-  require medical certificate stating that
- 	- condition not transmittable during flight or
- 	- measures to prevent transmission under 382.53(c); or
-  Impose special condition or restriction (e.g., 	wearing mask)

**Communicable Diseases/Medical Certificates/Attendants  (cont’d)**

## Medical Certificate – Overview of Law

  Medical certificate = written statement from 
   passenger’s physician

Carriers must not require a passenger with a disability to provide a medical certificate as a condition for being provided transportation 382.53(a)

States passenger capable of completing flight safely without requiring extraordinary medical assistance during flight under 382.53(b)(2)

-   Medical certificate = written statement from
-    passenger’s physician
- Carriers must not require a passenger with a disability to provide a medical certificate as a condition for being provided transportation 382.53(a)
- States passenger capable of completing flight safely without requiring extraordinary medical assistance during flight under 382.53(b)(2)

**Communicable Diseases/Medical Certificates/Attendants  (cont’d)**

##   Carriers may require medical certificate only if 
    passenger with a disability 

is traveling on stretcher or in incubator;

needs medical oxygen during flight; or

has medical condition that creates reasonable doubt that he/she can complete  flight safely without requiring extraordinary medical assistance during flight under 382.53(b)(1)     

-     passenger with a disability
- is traveling on stretcher or in incubator;
- needs medical oxygen during flight; or
- has medical condition that creates reasonable doubt that he/she can complete  flight safely without requiring extraordinary medical assistance during flight under 382.53(b)(1)

**Communicable Diseases/Medical Certificates/Attendants  (cont’d)**

## 
If carrier determines passenger with communicable disease or infection poses direct threat to health or safety of others, may require medical certificate under 382.53(c)(1)

Medical certificate must be dated within 10 days of flight under 382.53(c)(2)

- If carrier determines passenger with communicable disease or infection poses direct threat to health or safety of others, may require medical certificate under 382.53(c)(1)
- Medical certificate must be dated within 10 days of flight under 382.53(c)(2)

**Communicable Diseases/Medical Certificates/Attendants  (cont’d)**

## Demonstrating Law on Medical Certificates and Communicable Diseases – Short Exercise 

## MEDICAL CERTIFICATE AND COMMUNICABLE DISEASE SHORT EXERCISE DEBRIEF

- Generally, must not refuse travel to, require medical certificate from, or impose special conditions on passenger with communicable disease or infection
- But if direct threat to health or safety of others, determine best course of action
- Choose least restrictive option

## 
Obtain basic information about girl’s condition

Contact CRO and medical personnel

Mother says child has chicken pox but no longer contagious, may still choose least restrictive option of requiring medical certificate

- Obtain basic information about girl’s condition
- Contact CRO and medical personnel
- Mother says child has chicken pox but no longer contagious, may still choose least restrictive option of requiring medical certificate

**Medical Certificate And Communicable Disease Short Exercise Debrief  (cont’d)**

## Contents of medical certificate under 382.53(c)(2):

from child’s physician, 

states child’s chicken pox not contagious, 

includes any conditions or precautions to prevent transmission, and

dated within ten days of flight

- from child’s physician,
- states child’s chicken pox not contagious,
- includes any conditions or precautions to prevent transmission, and
- dated within ten days of flight

**Medical Certificate And Communicable Disease Short Exercise Debrief  (cont’d)**

## 
Child not permitted to fly if

Medical certificate incomplete, or

Passenger attempts to travel before date specified in medical certificate, or 

conditions outlined to prevent transmission not implemented 

- Child not permitted to fly if
- Medical certificate incomplete, or
- Passenger attempts to travel before date specified in medical certificate, or
- conditions outlined to prevent transmission not implemented

**Medical Certificate And Communicable Disease Short Exercise Debrief  (cont’d)**

## Attendants – Overview of Law

Generally not appropriate to require personal care attendant to accompany passenger with disability under 382.35(a)

- Generally not appropriate to require personal care attendant to accompany passenger with disability under 382.35(a)

**Medical Certificate And Communicable Disease Short Exercise Debrief  (cont’d)**

##   Safety May Necessitate Attendant

 May require passenger with disability to travel with attendant if passenger is: 

traveling on stretcher or in incubator (where service offered) 

mentally disabled and unable to comprehend or respond appropriately to safety instructions

-  May require passenger with disability to travel with attendant if passenger is:
- traveling on stretcher or in incubator (where service offered)
- mentally disabled and unable to comprehend or respond appropriately to safety instructions

**Communicable Diseases/Medical Certificates/Attendants  (cont’d)**

## 
severely impaired with respect to mobility and would be unable to assist in own evacuation 

deaf and severely impaired with respect to vision such that passenger could not adequately communicate to permit transmission of safety briefing under 382.35(b)(1) – (4) 

- severely impaired with respect to mobility and would be unable to assist in own evacuation
- deaf and severely impaired with respect to vision such that passenger could not adequately communicate to permit transmission of safety briefing under 382.35(b)(1) – (4)

**Communicable Diseases/Medical Certificates/Attendants  (cont’d)**

## If Carrier Requires Attendant for Safety and Passenger Disagrees

Carrier must not charge for transportation of attendant under 382.35(c)

If no seat available for attendant and passenger with disability with confirmed reservation unable to travel, passenger eligible for denied boarding compensation under 382.35(d)

Attendant deemed to have checked in at same time as passenger with disability under 382.35(e)    

- Carrier must not charge for transportation of attendant under 382.35(c)
- If no seat available for attendant and passenger with disability with confirmed reservation unable to travel, passenger eligible for denied boarding compensation under 382.35(d)
- Attendant deemed to have checked in at same time as passenger with disability under 382.35(e)

**Communicable Diseases/Medical Certificates/Attendants  (cont’d)**

## 
If attendant recruited to accompany passenger even though carriers not obligated to do so, carrier may ask

off-duty airline employee traveling on same flight

volunteer from among other customers traveling on same flight and offer free ticket or 

passenger with disability to choose attendant and offer free ticket 

- If attendant recruited to accompany passenger even though carriers not obligated to do so, carrier may ask
- off-duty airline employee traveling on same flight
- volunteer from among other customers traveling on same flight and offer free ticket or
- passenger with disability to choose attendant and offer free ticket

**Communicable Diseases/Medical Certificates/Attendants  (cont’d)**

## If attendant accompanying passenger on stretcher or in incubator, attendant must be capable of attending to passenger’s in-flight medical needs under 382.35(b)(1)  

Otherwise, purpose of attendant is to assist passenger with disability in emergency evacuation  

Other than situation above (stretcher or incubator) attendant not obligated to provide personal services 

- Otherwise, purpose of attendant is to assist passenger with disability in emergency evacuation
- Other than situation above (stretcher or incubator) attendant not obligated to provide personal services

**Communicable Diseases/Medical Certificates/Attendants  (cont’d)**

## Demonstrating Law on Attendants – Short Exercise

## ATTENDANTS SHORT EXERCISE DEBRIEF

- Determine extent of mobility impairment by asking whether he could assist with his own evacuation
- Determine whether he has functional ability to make progress toward exit
- If passenger says he can shout “Help!” explain issue is whether he can physically assist in evacuation

## If not, carrier may require him to travel with attendant    

If passenger required to travel with safety attendant and disagrees with carrier’s assessment he may choose attendant or carrier can assist by recruiting off-duty employee or another passenger

No charge for transportation of attendant

- If passenger required to travel with safety attendant and disagrees with carrier’s assessment he may choose attendant or carrier can assist by recruiting off-duty employee or another passenger
- No charge for transportation of attendant

**Attendants Short Exercise Debrief                  (cont’d)**

## Sources of Information

Passenger

Other carrier personnel: CRO, medical personnel  

382.51, 382.53, 382.35

- Passenger
- Other carrier personnel: CRO, medical personnel
- 382.51, 382.53, 382.35

**Attendants Short Exercise Debrief                  (cont’d)**

## 
FAA regulations

TAM

Carrier policies

- FAA regulations
- TAM
- Carrier policies

**Attendants Short Exercise Debrief                  (cont’d)**

## Sensitivity and Awareness 

Look at person when speaking to him/her  

Respect privacy and be discreet

- Look at person when speaking to him/her
- Respect privacy and be discreet

**Attendants Short Exercise Debrief                  (cont’d)**

## Communication 

Use “person first” language when addressing and referring to passenger

Acknowledge discomfort, but explain legal requirements

Listen actively before formulating response

- Use “person first” language when addressing and referring to passenger
- Acknowledge discomfort, but explain legal requirements
- Listen actively before formulating response

**Attendants Short Exercise Debrief                  (cont’d)**

## 
Use respectful tone

Maintain professional manner

Make eye contact  

Clarify information

- Use respectful tone
- Maintain professional manner
- Make eye contact
- Clarify information

**Attendants Short Exercise Debrief                  (cont’d)**

## Conflict Resolution  

Be prepared to deal with discomfort and frustration

Write things down and confirm accuracy

Remind parties about shared interest in safe transfer and accommodation of all passengers and crew

- Be prepared to deal with discomfort and frustration
- Write things down and confirm accuracy
- Remind parties about shared interest in safe transfer and accommodation of all passengers and crew

**Attendants Short Exercise Debrief                  (cont’d)**

## 

Reiterate carrier’s responsibilities under law

Exercise best judgment under circumstances

Provide basis for determination   

- Reiterate carrier’s responsibilities under law
- Exercise best judgment under circumstances
- Provide basis for determination

**Attendants Short Exercise Debrief                  (cont’d)**

## CONCLUSION

- Accomplished goals by
- Gaining understanding of Part 382 through hands-on application of law and
- Using four pieces of information, sensitivity and awareness, communication, and conflict resolution

## 
Questions

Comprehension Check and Evaluation

Certificates of Completion

- Questions
- Comprehension Check and Evaluation
- Certificates of Completion

**CONCLUSION**