A Framework of

Emergency Preparedness Guidelines

For Federal Agencies

Interagency Coordinating Council on Emergency

Preparedness and Individuals with Disabilities

Subcommittee on Emergency Preparedness

in the Workplace

July 2005

Accounting for the

Needs of People

with Disabilities

FOR

PREPARINGTHE

WORKPLACE

EVERYONE:
Copies of this report are available from the United States Department of

Labor's Office of Disability Employment Policy (www.dol.gov/odep). The

United States Department of Labor is located at 200 Constitution Avenue,

N.W., Room S-1303, Washington, DC 20210; (202) 693-7880 (Main Voice);

(202) 693-7881 (Main TTY); (202) 693-7881 (Main Fax). Alternative

formats of this report are available by contacting the Office of

Disability Employment Policy.

Any modification(s) to the Report, or to material contained in this

Report, must be clearly specified. In addition, a description of the

modifications must be provided. Notice of the modification(s) must be

displayed prominently and must contain, if applicable, a notice that the

modification(s) may compromise the validity and readability of the

information and/or conclusions in this Report.
Accounting for the Needs of People with Disabilities i

he Interagency Coordinating Council on Emergency Preparedness and Individuals

with Disabilities (The Council) was established under Executive Order (EO) 13347,

signed by President George W. Bush on July 22, 2004. The Executive Order,

Individuals with Disabilities in Emergency Preparedness, calls for the Federal

EXECUTIVE ORDER 13347 AND THE COUNCIL

T

Government to appropriately support safety and security for individuals with disabilities in all

types of emergency situations through a coordinated effort among federal agencies that includes

the following:

■ Considering the unique needs of agency employees with disabilities and individuals

with disabilities whom the agency serves;

■ Encouraging, through the provision of technical assistance, as appropriate, consideration of the unique needs of employees and individuals with disabilities served by

state, local, and tribal governments and private organizations and individuals in

emergency preparedness planning; and

■ Facilitating cooperation among federal, state, local, and tribal governments as well as

private organizations and individuals.
ii Preparing the Workplace for Everyone

During 2004-05, the Subcommittee primarily focused on the Federal Government, documenting

effective emergency preparedness strategies and identifying key issues associated with fully

including individuals with disabilities. The lessons learned by federal agencies will ultimately

enable the Council to approach other employment sectors with effective practices and model

policies that can be readily modified for use by state and local governments, nonprofit organizations,

and the business community.

he Council established eight subcommittees to address the many facets of this issue.

In particular, the Emergency Preparedness in the Workplace Subcommittee has been

tasked with addressing emergency preparedness related to individuals with disabilities

within the governmental and private sector workplaces. The Subcommittee focuses on

THE WORKPLACE SUBCOMMITTEE

strategies for ensuring that the development, implementation, and maintenance of workplace

emergency preparedness plans fully include the unique perspectives and needs of individuals

with disabilities. The following agencies have participated in the Subcommittee’s work to date:

T

Department of Labor, Office of Disability Employment Policy (Chair)

Access Board Department of State

Department of Homeland Security Department of Transportation

Department of Agriculture Department of the Treasury

Department of Commerce Environmental Protection Agency

Department of Defense Equal Employment Opportunity Commission

Department of Education Federal Communications Commission

Department of Energy General Services Administration

Department of Health and Human Services Office of Personnel Management

Department of the Interior Social Security Administration

Department of Justice
Accounting for the Needs of People with Disabilities iii

reparing the Workplace for Everyone is meant to serve as a launching point for federal

agencies as they re-evaluate and strengthen their Occupant Emergency Plans (OEPs),

which are required for all federal agencies by the U.S. General Services Administration

(GSA).1 This framework of guidelines reflects the effective practices of nearly 20 federal

IMPORTANT NOTE TO READERS

agencies gathered from direct input, existing reports and articles, and actual emergency plans.

According to the National Council on Disability (NCD), in its 2005 report, Saving Lives: Including

People with Disabilities in Emergency Planning:

In disaster management activities it is important to think about disability broadly. Traditional

narrow definitions of disability are not appropriate. The term disability does not apply just to

people whose disabilities are noticeable, such as wheelchair users and people who are

blind or deaf. The term also applies to people with heart disease, emotional or psychiatric

conditions, arthritis, significant allergies, asthma, multiple chemical sensitivities, respiratory

conditions, and some visual, hearing, and cognitive disabilities. 2

The U.S. Federal Emergency Management Agency (FEMA) has historically recognized mitigation,

preparedness, response, and recovery as the phases of emergency management. However,

many of the issues addressed in this framework of guidelines may emerge in multiple phases.

Consequently, in order to enhance both the usability and readability of Preparing the Workplace

for Everyone, topics are explored in light of four phases of emergency preparedness plans:

development, implementation, practice, and maintenance.

For each topic, an explanation is provided, followed by a list of considerations. The critical questions

posed are intended to assist agencies in conducting a quick, informal self-assessment of existing

emergency preparedness plans and to aid in plan development and improvement. While careful

consideration has been given to including guiding principles, critical questions, and agency

examples, this should not be viewed as a comprehensive compilation. Furthermore, the

considerations presented are not intended to supersede or replace any existing policy or legislation,

but simply provide a framework for ensuring the needs of people with disabilities are taken into

account in workplace emergency preparedness. Please consult the appropriate entities for

additional details on a particular subject.

As is the nature of emergency preparedness, this framework is an evolving document. It is

anticipated that updates will periodically be issued to reflect significant enhancements in the

field. The Subcommittee welcomes examples of agency effective practices and/or feedback

regarding the ways the framework has aided in formulating or strengthening an agency plan.

Please contact the Subcommittee at (202) 693-7880.

P
iv Preparing the Workplace for Everyone

Executive Order 13347 and The Council ............................................................................... i

The Workplace Subcommittee .............................................................................................. ii

Important Note to Readers ................................................................................................... iii

Table of Contents .................................................................................................................. iv

Necessity of Plans .................................................................................................................1

Societal Changes................................................................................................................2

Legal Considerations ..........................................................................................................4

Homeland Security Presidential Directive 5 (HSPD-5)..................................................4

The U.S. Access Board’s ADA-ABA Accessibility Guidelines ........................................5

The Rehabilitation Act of 1973, as amended (Rehabilitation Act) .................................7

The Americans with Disabilities Act (ADA) ....................................................................8

State and Local Guidance .............................................................................................9

Agency Commitment ........................................................................................................11

Development.........................................................................................................................15

Involving Key Personnel ....................................................................................................16

Regional and Field Offices................................................................................................20

Shelter-in-Place (SIP) Plans .............................................................................................23

Evaluating Employee and Customer Needs .....................................................................26

The Buddy System and Cross-Training .......................................................................27

Implementation.....................................................................................................................33

Communicating About and Distributing the Plan ..............................................................34

Employer Responsibilities and Employee Right to Self-Determination.............................36

Working with First-Responders:

First-Responder Responsibilities and Employee Right to Self-Determination ..................40

Re-thinking the Elevator Policy .........................................................................................44

Emergency Notification Strategies....................................................................................48

TABLE OF CONTENTS
Accounting for the Needs of People with Disabilities v

Practice and Maintenance ...................................................................................................53

IN FOCUS TOPICS

The Role of Federal Executive Boards (FEBs) ...................................................................5

A Brief History: The Original ADA and ABA Guidelines ......................................................6

Engaging the Disability Community ..................................................................................18

Building Security Committees (BSCs) ..............................................................................21

Determining Equipment Needs.........................................................................................28

Service Animals and Emergency Preparedness ..............................................................29

Deciding Whether to Request Assistance.........................................................................38

First Responder Considerations in Emergency Situations ...............................................42

A Closer Look at Elevator Safety in Emergencies ............................................................46

The Importance of Redundancy: Situations and Notification Systems .............................50

Types of Drills ...................................................................................................................56

Appendices ...........................................................................................................................59

Appendix A: Critical Questions List..................................................................................60

Appendix B: Resources ...................................................................................................64

Appendix C: Executive Order 13347 ................................................................................69

Endnotes ...............................................................................................................................72
vi Preparing the Workplace for Everyone
Accounting for the Needs of People with Disabilities 1

NECESSITY

OF PLANS
2 Preparing the Workplace for Everyone

Societal Changes

mericans enjoy relative security in

their everyday lives. Yet, the threat

of emergency situations remains.

From the string of Florida

hurricanes and California wildfires to the East

Coast blackouts and the September 11th

terrorist attacks, Americans have been acutely

reminded in recent years of the devastation

caused by natural disasters, technological

accidents, and acts of terrorism. Like most of

the nation, the Federal Government has

focused greater attention on not only

responding to emergencies, but also preparing

for them. This is due, in part, to events such

as the bombing of the Oklahoma City federal

regional building on April 19, 1995; the terrorist

attacks on the Pentagon and the World Trade

Center on September 11, 2001; and the

shutting down of National Capitol

Region (NCR) federal offices due to Hurricane

Isabel on September 18-19, 2003.

Like most parts of society, the Federal

Government has re-evaluated its approach to

emergency preparedness and response.

Significant improvements have been made. It

is increasingly recognized that while

preparedness at home is important, having a

plan for the workplace is equally as critical. In

addition to keeping employees safe, there is a

need to ensure the safety of visitors. Still,

research during the last decade has shown

that people with disabilities are one segment

of the workforce that is often overlooked during

such planning efforts.

Explanations for this disparity vary but may

NECESSITY OF PLANS

include fear, lack of knowledge, a decision to

disregard the seriousness of a potential threat,

or even the belief that there will be no personal

effect. Employers may be hesitant about

recruiting or retaining people with disabilities

due to concerns related to securing their safety

during an emergency. A recent case filed by

the U.S. Equal Employment Opportunity

Commission (EEOC) in the U.S. District Court

for the Eastern District of Louisiana illustrates

this concern:

A former employee was awarded nearly $1.3

million after being terminated. The employer,

an international science and chemical

company, asserted that she was a “direct

threat” because of being incapable of safely

evacuating due to her inability to walk. However,

a Human Resources Manager later admitted

under oath that the employee was not a direct

threat and was capable of safely evacuating

by walking.

Keep in mind that job seekers, employees, and

visitors with disabilities may also have concerns

about their safety in an emergency. They may

be reluctant to seek employment in or visit

certain locations due to a fear of being trapped

or not being accommodated in a dangerous

situation. Consequently, emergency

preparedness plans that do not include or

adequately consider the needs of people with

disabilities may hinder equal access to

employment, goods, and services.

Plans that do consider the needs of employees

and customers with disabilities must also be

effectively reviewed, updated, and practiced on

a continual basis. Consider this real-life

A
Accounting for the Needs of People with Disabilities 3

example of a U.S. Department of Labor (DOL)

Occupational Safety and Health Administration

(OSHA) Compliance Assistance Officer:

In August 2001, OSHA staff at the Manhattan

Area Office completed an uneventful

evacuation drill from their offices on the top floor

of Building 6 of the World Trade Center complex.

Managers felt confident that everyone could

escape the building safely in an emergency—

including an employee who had recently

returned to work and was temporarily using a

wheelchair. The evacuation plan had

specifically been revised to accommodate his

needs.

Within weeks, the practice proved more

valuable than anyone could have imagined.

On the morning of September 11, 2001, OSHA

employees had begun a routine day when an

explosion shook the building. The Assistant

Area Director immediately ordered everyone

to evacuate. As the first plane hit the North

Tower of the World Trade Center, debris began

falling on Building 6. Staff rushed into the

hallway. Three employees helped their coworker in the wheelchair down the corridor and

into a freight elevator they had used during the

practice drill. They descended to the basement,

into a garage, down some steps, and into

another garage, where they escaped from the

building.

The group moved outside just as the second

plane hit the South Tower. As the group moved

away from the site, the North Tower collapsed,

destroying OSHA’s Manhattan Area Office as

it fell.

While there are no guarantees when it comes

to maintaining personal safety or the safety of

others in the event of an emergency, this OSHA

employee is living proof that taking into account

both those with and without disabilities in

planning, training, and practice efforts is

achievable. And, more importantly, such

planning and practice does make a difference.

“Sticking to the plan, and using the elevators is

probably what saved us,” explained the OSHA

employee’s co-worker.3

As federal agency plans continue to evolve, it

is vital to consider the needs of all employees

and visitors, including those with disabilities.

The perspectives of people with disabilities

should be taken into account throughout the

mitigation, preparedness, response, and

recovery phases of emergency management.

While much has been accomplished, there

remains much to do, throughout the Federal

Government, in the Washington, DC area, and

at federal facilities nationwide. Employees—

including those with disabilities—should not

make assumptions with regard to emergency

preparedness. It is the responsibility of each

individual to actively prepare, to the extent

possible, whether on an individual, office, or

agency level. It is also important to keep in

mind that some individuals with cognitive or

developmental disabilities may need additional

assistance in preparing for and responding in

emergencies. Consequently, thoughtful

planning, collaboration, and steadfast

commitment by agencies, managers, planners,

first responders, employees, and service

providers are key to ensuring a safer workplace

for all.
4 Preparing the Workplace for Everyone

R

Legal Considerations

ecognizing that everyone, including

individuals with disabilities, should

enjoy the same level of safety and

security in their communities and

work environments, President George W. Bush

issued Executive Order 13347, Individuals with

Disabilities in Emergency Preparedness, on

July 22, 2004. The Executive Order directs the

Federal Government to work together with

state, local, and tribal governments, as well as

private organizations to appropriately address

the safety and security needs of people with

disabilities. In addition to the Executive Order,

there are a number of regulations, codes, and

guidelines federal agencies must take into

account.

For example, federal agencies located in

buildings managed by the U.S. General

Services Administration (GSA) must have an

Occupant Emergency Plan (OEP), that

complies with U.S. Department of Labor’s

(DOL) Occupational Safety and Health

Administration regulations.4

The OEP should set forth procedures for

safeguarding lives and property in the shortterm. Variables such as building location,

proximity to prominent landmarks or buildings,

design features, and the missions of agencies

occupying the building impact security and

safety measures. Consequently, security,

shelter-in-place, and evacuation procedures

should be tailored to the facility. For GSAcontrolled property, this is mainly accomplished

through recurring threat assessments

completed by the Federal Protective Service/

U.S. Department of Homeland Security (DHS).

Federal agencies in buildings not managed by

GSA may contact the Federal Bureau of

Investigation or local police for emergency

preparedness and/or threat assessments.5

Homeland Security Presidential

Directive 5

Issued in 2003, the Homeland Security

Presidential Directive 5 (HSPD-5) established

a single, comprehensive National Incident

Management System (NIMS). The objective

was to ensure that all levels of government had

the capability to work efficiently and effectively

together. As such, with regard to domestic

incidents, crisis management and consequence management are treated as a single,

integrated function, rather than as two separate

functions.

The Directive requires all federal agencies to

develop an Incident Command System (ICS)

to facilitate a national, coordinated response

to domestic emergencies. The general

framework set forth in this Directive was

patterned after the U.S. Department of

Agriculture’s (USDA) Forest Service ICS

program. A closer look at the USDA ICS

program reveals the establishment of a

particularly noteworthy precedent: the position

of Special Needs Advisor to the Incident

Commander. While NIMS does not specifically

mention such a position within the ICS, it does

allow for this appointment at the discretion of

the Incident Commander.
Accounting for the Needs of People with Disabilities 5

The U.S. Access Board’s ADA-ABA

Accessibility Guidelines

On July 23, 2004, the U.S. Access Board issued

updated accessibility guidelines for new or

altered facilities covered by Americans with

Disabilities Act (ADA) and the Architectural

Barriers Act (ABA), so a consistent level of

access is specified under both laws. Through

this update, the Board sought to simplify

compliance by making its guidelines more

consistent with model building codes and

industry standards. The Board coordinated

extensively with model code groups and

standard-setting bodies in order to reconcile

differences. In particular, the Board sought to

IN FOCUS:

The Role of Federal Executive Boards

One of the key ways information is shared between the Federal Government and field offices is

through the 28 Federal Executive Boards (FEBs), which are comprised of federal agency senior

staff and employees. The FEBs, which exist in cities with major federal activity, act as points of

coordination for the development and operation of federal programs having common characteristics;

serve as a means of strengthening field understanding and support of management initiatives

and concerns; and provide federal representation and involvement in communities.

While not considered first responders, these boards have aided agencies in their commitment to

the safety of federal workers through the dissemination of information. Along with city officials,

FEBs provide recommendations to the Director of the U.S. Office of Personnel Management

(OPM) and/or the local agency head, who also has the authority to close an agency. Nevertheless,

the primary responsibility for emergency preparedness for all employees and for communicating

these plans to the regions resides with agencies.

In cities where FEBs do not exist, there are Federal Executive Associations or Councils. They do

not function within the same formal set of parameters (i.e., officially established by Presidential

Memorandum and policy direction and guidance from the OPM) as do FEBs.

align the guidelines with the International

Building Code (IBC) and access standards

issued through the American National

Standards Institute (ANSI).

While the Board’s guidelines are not

mandatory, they do serve as the baseline for

enforceable standards maintained by other

federal agencies. In this respect, they are

similar to a model building code in that they

are not required to be followed except as

adopted by an enforcing authority. Under the

ADA, the U.S. Department of Justice (DOJ)

and, in the case of transit facilities, the U.S.

Department of Transportation (DOT) are
6 Preparing the Workplace for Everyone

IN FOCUS:

A Brief History: The Original ADA and ABA Guidelines

Under the Americans with Disabilities Act (ADA) the U.S. Access Board is responsible for

accessibility guidelines covering newly built and altered facilities. In 1991, the Board published

the ADA Accessibility Guidelines (ADAAG), which served until July 2004 as the basis for standards

used to enforce the law. Similar to its responsibility under the ADA, the Board maintains guidelines

under the Architectural Barriers Act (ABA) that serve as the basis for enforceable standards.

ADAAG included specifications for accessible means of egress, emergency alarms, and signage.

Unlike the ABA guidelines, the ADA guidelines cover places of public accommodation, commercial

facilities, and state and local government facilities. The new guidelines, which were published in

July 2004, revised the original ADAAG.

ABA requires that buildings and facilities designed, constructed, or altered with federal funds, or

leased by a federal agency comply with federal standards for physical accessibility. This

requirement includes U.S. Postal Service facilities. ABA requirements apply only to architectural

standards in new and altered buildings as well as newly leased facilities; they do not address the

activities conducted in those buildings and facilities. The Board has updated its guidelines for

ABA facilities jointly with the new ADA guidelines so that a consistent level of access is specified

under both laws.

Prior to July 2004, the ABA design requirements were incorporated into the Uniform Federal

Accessibility Standards (UFAS). The Rehabilitation Act regulations also use UFAS as the standard

for new construction and alterations. UFAS Section 4.3.10: EGRESS provides that: “Accessible

routes serving any accessible space or element shall also serve as a means of egress for

emergencies or connect to an accessible place of refuge. Such accessible routes and places of

refuge shall comply with the requirements of the administrative authority having jurisdiction.”

UFAS defines administrative authority as “[a] governmental agency that adopts or enforces

regulations and standards for the design, construction, or alteration of buildings and facilities.”

Such a broad definition has made it difficult to articulate a specific standard that an ABA facility

would have to meet nowadays.

Consequently, these guidelines have been brought more in line with International Building Code

(IBC) and access standards issued through the American National Standards Institute (ANSI).

Used by a growing number of states and local jurisdictions, the IBC contains scoping provisions

for accessibility. The ANSI A117.1 standard, a voluntary consensus standard, provides technical

criteria referenced by the IBC. A number of revisions were made to the guidelines for consistency

with these and other model codes and standards. In addition, the Board worked to resolve

remaining differences by advocating changes to the IBC and the ANSI A117.1 standard based

on the new guidelines.
Accounting for the Needs of People with Disabilities 7

responsible for enforceable standards based

on the Board’s guidelines. Several other

agencies, including the U.S. General Services

Administration (GSA), the U.S. Department of

Defense (DOD), the U.S. Department of

Housing and Urban Development (HUD), and

the U.S. Postal Service (USPS) hold similar

responsibilities for standards used to enforce

the ABA.

The four agencies responsible for implementing

the ABA (HUD, DOD, GSA, and USPS) are now

revising their ABA implementing regulations to

adopt the new ABA Accessibility Guidelines

published by the Board. The USPS has already

adopted the new requirements. The DOD’s rule

is a work in progress. GSA–which covers most

federal buildings–expects to publish a final rule

in July 2005 that will require federal agencies

and other entities subject to the ABA to comply

with the new ABA Standards. Those guidelines

will require covered entities to comply with the

requirements for accessible means of egress

established by the IBC in either its 2000 edition

(as supplemented in 2001) or its 2003 edition.

The IBC provisions explicitly require “areas of

refuge” in newly constructed buildings that do

not have supervised sprinkler systems. These

technical requirements for areas of refuge are

essentially the same as the ADA requirements

for areas of rescue assistance.

The Rehabilitation Act of 1973, as

amended (Rehabilitation Act)

The Rehabilitation Act of 1973, as amended,

prohibits discrimination on the basis of disability

in federal programs or those receiving federal

funding, and in the employment practices of

federal agencies and their contractors. The

Rehabilitation Act regulations also use the

Uniform Federal Accessibility Standards

(UFAS) for new construction and alterations,

which makes it difficult to articulate specific

standards for a facility covered by the ABA.

However, there has been a push to have ABA

buildings comply with the IBC provisions, which

explicitly require areas of refuge in newly

constructed buildings with no supervised

sprinkler systems. The IBC model code

establishes technical requirements for areas

of refuge that are essentially the same as the

ADA requirements for areas of rescue

assistance.

■ Section 501 requires affirmative action and

nondiscrimination in employment by federal

agencies of the executive branch. The

standards for determining employment

discrimination under the Rehabilitation Act

are the same as those used in Title I of the

ADA. To obtain more information or to file a

complaint, contact the Equal Employment

Opportunity Office at www.eeoc.gov.

■ Section 503 requires affirmative action and

prohibits employment discrimination by

Federal Government contractors and

subcontractors with contracts of more than

$10,000. For more information, visit the U.S.

Department of Labor’s Office of Federal
8 Preparing the Workplace for Everyone

Contract Compliance Programs (OFCCP)

Web site at www.dol.gov/esa/ofccp.

■ Section 504 states that “no qualified

individual with a disability in the United

States shall be excluded from, denied the

benefits of, or be subjected to discrimination

under” any program or activity that either

receives federal financial assistance or is

conducted by any Executive agency or the

USPS. For information on Section 504, visit

the U.S. Department of Justice’s (DOJ) Civil

Rights Division Web site at www.ada.gov.

■ Section 508 requires that electronic and

information technology developed,

maintained, procured, or used by the

Federal Government be accessible to

people with disabilities, including

employees and members of the public. An

accessible information technology system

is one that can be operated in a variety of

ways and does not rely on a single sense

or ability of the user. Some individuals with

disabilities may still need software or

peripheral devices in order to use these

systems. More information can be found

at www.section508.gov or www.accessboard.gov.

The Americans with Disabilities Act (ADA)

The ADA prohibits discrimination on the basis

of disability in employment; state and local

government; public accommodations;

commercial facilities; transportation; and

telecommunications. The ADA also prohibits

retaliating against, interfering with, coercing,

intimidating, or harassing any individual who

opposes actions made unlawful by the ADA or

who seeks enjoyment of (or assists others in

the enjoyment of) any rights under the ADA.

The ADA’s requirements apply to Congress,

as well as to private entities and to state and

local governments.

In most instances, an individual must have a

disability or an association with someone with

a disability in order to be protected by the ADA.

The ADA defines an individual with a disability

as “a person who has a physical or mental

impairment that substantially limits one or more

major life activities; a person who has a history

or record of such an impairment; or a person

who is perceived by others as having such an

impairment.”

While the ADA does not refer to the

development of emergency plans specifically,

if plans are in place, they should include those

with disabilities. Furthermore, plans may need

to be established to fulfill a request for a

reasonable accommodation. It should be noted

that ADA regulations do require areas of rescue

assistance in newly constructed buildings that

do not have supervised sprinkler systems. This

requirement is contained in the ADA Standards

for Accessible Design. Areas of rescue

assistance are not required in alterations. 6

■ Title I: Employment Employers with 15 or

more employees must provide qualified

individuals with disabilities equal

employment opportunities. Discrimination

in recruitment, hiring, promotions, training,

pay, social activities, and other privileges

of employment is prohibited. Questions
Accounting for the Needs of People with Disabilities 9

about an applicant’s or employee’s disability

and/or medical examinations of an applicant

or employee are also limited. Employers

must make reasonable accommodations for

otherwise qualified individuals with

disabilities, unless this would result in undue

hardship.

■ Title II: State and Local Government

Activities All activities of state and local

governments, regardless of the entity’s size

or receipt of federal funding, are covered.

Additionally, state and local governments are

required to allow people with disabilities an

equal opportunity to benefit from all

programs, services, and activities (e.g. public

education, employment, transportation,

recreation, health care, social services,

courts, voting, and town meetings). This

includes relocating programs or otherwise

providing access in inaccessible older

buildings, and communicating effectively

with people who have hearing, vision, or

speech disabilities.

■ Title III: Public Accommodations This title

covers businesses and nonprofit service

providers that are public accommodations,

privately operated entities offering certain

types of courses and examinations, privately

operated transportation, and commercial

facilities. Public accommodations are

defined as private entities that own, lease,

lease to, or operate facilities. This includes

restaurants, retail stores, hotels, private

schools, convention centers, doctors’ offices,

homeless shelters, transportation depots,

day care centers, and recreation facilities

(e.g., sports stadiums and fitness clubs).

Transportation provided by private entities

is also covered.

Public accommodations must comply with

basic nondiscrimination requirements that

prohibit exclusion, segregation, and unequal

treatment, as well as specific architectural

standards for new and altered buildings;

reasonable modifications to policies, practices,

and procedures; effective communication with

people with hearing, vision, or speech

disabilities; and other access requirements.

Barriers in existing buildings must be removed

when possible without much difficulty or

expense.

State and Local Guidance

State and local anti-discrimination laws provide

protections similar to the Rehabilitation Act and

the Americans with Disabilities Act (ADA). In

addition, state and local laws, regulations, and

ordinances may impact general access to

facilities as well as emergency planning efforts.

Provisions of these laws that are inconsistent

with federal laws and provide less protection

are likely pre-empted; however, state and local

laws that provide greater protection or greater

access to facilities are not pre-empted. Such

guidance applies to private facilities in which

the Federal Government leases space. For

more information on specific state codes,

please visit the U.S. Access Board Web site at

www.access-board.gov/links/statecodes.htm.
10 Preparing the Workplace for Everyone

Critical Questions

■ Are agency emergency preparedness

personnel aware of applicable federal,

state and/or local laws? If not, what steps

are being taken to change this?

■ How do each of these laws affect the

development, implementation and

maintenance of agency emergency

preparedness plans?

■ In instances in which an agency leases

space in facilities owned by private entities

or by state or local governments, how will

responsibilities for various aspects of the

emergency preparedness process be

allocated between the parties of the

lease?

Follow-Up Items
Accounting for the Needs of People with Disabilities 11

Agency Commitment

n effective emergency preparedness

plan requires support and

commitment from senior-level

management within an agency. A

preparedness plan will only be as good as the

financial and personnel resources supporting

it. The methods of securing and demonstrating

managerial commitment to including people

with disabilities in emergency planning vary

from agency to agency. At some agencies, this

has been accomplished through direct

communications from executive-level officials,

such as the Secretary or agency head.

Because the protocols and forms of

communications differ from agency to agency,

personnel tasked with creating emergency

preparedness plans must think creatively about

obtaining and communicating the vital

managerial buy-in.

Here are a few ways agencies have

demonstrated their commitment:

■ Created a position within the agency’s

Incident Command System (ICS) program

to address the needs of special populations,

including those with disabilities. This is

provided for under the general framework

of the Homeland Security Presidential

Directive 5 (HSPD-5).

Example:

At the U.S. Department of Agriculture (USDA)

headquarters, the position of Special Needs

Advisor to the Incident Commander was

established under the heading of Technical

Specialist: Special Needs. This has given the

A

disability community a voice in the ICS, and an

inside advisory position where the

departmental plan for emergency

preparedness, occupant emergency,

communications, training, and review and

evaluation has been designed, written and

implemented.

■ Established an emergency response team

(ERT).

Example:

Established by U.S. Department of Labor (DOL)

Secretary Elaine L. Chao and chaired by the

Deputy Secretary and Assistant Secretary for

Administration and Management (OASAM),

the main goal of the ERT team is to develop

and implement strategies to safeguard

occupants of all DOL facilities. The team met

frequently following September 11th and still

meets on a quarterly basis. Recommendations

are implemented with input from a number of

agencies within DOL to ensure that all

necessary issues are appropriately addressed.

Initially, forums were conducted to discuss

emergency evacuation strategies for people

with disabilities. These forums served several

functions. First, they gave individuals from the

Department’s disability community the chance

to provide valuable input and recommendations

for enhancing procedures. Meetings also

provided an opportunity to update personnel

on ERT evacuation planning for people with

disabilities, respond to concerns, conduct

trainings and demonstrations, and listen to

rationales for recommendations.
12 Preparing the Workplace for Everyone

■ Ensured everyone has a defined

responsibility in emergency preparedness.

Example:

At the U.S. Social Security Administration

(SSA), managers throughout the agency are

automatically members of their building

Occupant Emergency Program Organization.

They work closely with the facility designated

official, whose primary responsibilities include

developing the site Occupant Emergency

Program, ensuring appropriate emergency

procedures are followed, and preparing

occupants for emergencies. They fully

cooperate with the Building Occupant

Emergency Coordinator, the senior official of

the largest department at the headquarters

building, who assists the Designated Official.

Managers and supervisors assist in clearing

work areas; ensuring the evacuation of

employees and visitors with disabilities;

assisting emergency services as necessary;

and accounting for all employees in the

assembly area.

Example:

At the U.S. Department of Transportation

(DOT), the senior management has oversight

responsibility. Supervisors are responsible for

ensuring the safety of their employees.

Employees with disabilities also participate in

planning for their own safety, which may include

providing necessary information to personnel

responsible for assisting them in the event of

an emergency. Finally, facility, emergency, and

security personnel have the responsibility of

planning for emergency situations in general,

as well as considering the unique needs of

people with disabilities.

■ Conducted assessments of national and

regional facilities.

Example:

In this process, the U.S. Department of Labor’s

(DOL) Office of the Inspector General

concluded that a “cookie cutter” approach was

not appropriate. Instead, DOL officials

determined a more effective approach would

be to address each situation and develop

procedures that considered the needs of all

employees, including people with disabilities.
Accounting for the Needs of People with Disabilities 13

Critical Questions Follow-Up Items

■ Have senior-level staff demonstrated a

commitment to developing, implementing,

and maintaining a plan that includes

people with disabilities?

■ If not, what can and is being done to increase awareness of the importance of

this issue, particularly among senior staff?

■ If senior staff have recognized the importance of this issue, describe in some detail evidence of this agency commitment.

■ How might this support be strengthened

and re-affirmed? Which areas (e.g., communicating the plan, practicing) need particular work? What are some strategies

for addressing these areas?
14 Preparing the Workplace for Everyone
Accounting for the Needs of People with Disabilities 15

DEVELOPMENT DEVELOPMENT
16 Preparing the Workplace for Everyone

DEVELOPMENT

W

Involving Key Personnel

hile planning for every situation that

may occur in an emergency is

impossible, being as prepared as

possible is important. One way of

accomplishing this is to consider the

perspectives of various individuals and

entities—from senior staff and employees with

disabilities to first responders and agencies in

nearby space. Involving these key groups early

on will help everyone understand the existing

state of plans and the challenges that each

stakeholder group faces, whether it is related

to physical, sensory, or cognitive ability, or

personnel, budget, or resources.

U.S. Office of Personnel Management (OPM)

guidance reminds managers, “[E]mployees will

look to you for support in a time of emergency.

It is important that you understand the plan your

agency has in place....”7

Considerations

■ Are there individuals with disabilities

involved in the planning process? If so, do

their perspectives represent the broader

views of the disability community?

Note:

Not only is it important that many types of

disabilities are represented (i.e., vision, mobility,

cognitive, developmental, and hearing), but the

ideas presented should encompass the views

and needs of many individuals within a

particular disability category.

Example:

The U.S. Department of Agriculture (USDA)

utilizes the Incident Command System (ICS)

to enable the Special Needs Advisor to

evaluate all emergency preparedness activities.

This individual provides input on all emergency

plans for personnel and visitor movement

(evacuation and shelter-in-place), communication systems (purchases and

upgrades), as well as training programs and

schedules.

The Special Needs Advisor also studies the

potential impact of policies under consideration

by the USDA ICS. If a suggested program or

system negatively impacts one of the fourmajor disability categories (vision, mobility,

cognitive and hearing), then changes are made

to ensure all have access to the information or

program. Often, accommodations that are

made for individuals with disabilities have

benefited the entire building population.

■ The active support and understanding of

senior staff is essential to bringing about

effective and lasting change. Do seniorlevel staff understand and support the plan

or the need to make changes, so as to

include people with disabilities?

Note:

One possible method of getting management

on board is to present the risk(s) for the

organization (i.e., One person getting hurt will

impact more than 100 people.).
Accounting for the Needs of People with Disabilities 17

Example:

The U.S. Department of Transportation (DOT)

accomplished this critical step through a

Secretarial memorandum to the agency’s key

leaders. The memorandum demonstrated both

the significance of this issue to all the

Departmental employees and the Secretary’s

commitment to individuals with disabilities. For

example, the memorandum designated specific

roles and responsibilities in developing the

emergency preparedness plan. It also required

that people with disabilities be involved in the

plan development, and mandated that the DOT

Secretary be provided a summary of steps that

had been or would be taken (to fulfill the

responsibilities and roles delineated).

Accordingly, implementation and maintenance

of the plan met with little resistance.

■ First responders and service providers are

a valuable resource during this phase of the

process. They can provide input on the

feasibility of plans, as well as coordinate

response efforts with an agency.

Example:

The U.S. Department of Labor (DOL)

headquarters has its own command center,

which is also connected to the police

department. The agency has worked closely

with authorities to establish protocols regarding

who will respond in specific situations.

Sometimes the trained DOL staff (e.g., security

personnel) handle issues, while local entities

are called in other times.

Example:

According to Kathy Hargett of the President’s

Committee on People with Intellectual

Disabilities, in anticipation of possible computer

or electrical outages at the change of the

Millennium, the New York City Regional Office

for Mental Retardation and Developmental

Disabilities (NYCRO MR/DD), in partnership

with service providers, developed emergency

plans for those whom they serve. These plans

included identifying the location of 65,000

individuals; establishing alternative respite and

residential facilities to accommodate them; and

having a 7-day, portable supply of medications.

In addition, these partners participated in

training exercises prior to the end of 1999.

On September 11, 2001, these plans resulted

in the identification and safe evacuation of more

than 2,000 people with mental retardation/

developmental disabilities (MR/DD) in the area

around the World Trade Center. This included

people with profound MR/DD in addition to

those with higher functioning abilities.8

■ Working with facilities personnel and

agencies in nearby or adjacent spaces

ensures that the plan meets federal and

local requirements, and does not conflict

with established procedures.

Example:

The U.S. Department of Labor (DOL)

headquarters worked with nearby employers

and first responders to designate assembly

areas following an evacuation. The agency also

consulted security and facilities personnel to

free evacuation routes of barriers (e.g.,

construction, security barricades, etc.).
18 Preparing the Workplace for Everyone

IN FOCUS:

Not sure of ways to engage the disability community? Here are a few places to start:

■ Federal Agency Disability Advisory Councils–These informal groups of federal

employees often have regular meetings. Check with disability program managers in the

agency for more information.

■ National disability organizations and/or their local affiliates–There are several national

cross-disability organizations as well as a number of disability-specific organizations with

local affiliates. Check the Web or phone book for more information.

■ State Vocational Rehabilitation agencies–In addition to providing employment-related

services, Vocational Rehabilitation (VR) offices assist people with disabilities in living as

independently as possible by providing services and educating the public. They may be

listed under Vocational Rehabilitation, Rehabilitation Services Administration, or

Rehabilitation on the Web or in the phone book. A complete listing may be found at

www.jan.wvu.edu/SBSES/VOCREHAB.HTM.

■ Centers for Independent Living (CILs)–These community-based resource and advocacy

centers are managed by and for people with disabilities. Approximately 550 CILs throughout

the United States promote independent living and equal access for all persons with physical,

mental, cognitive, and sensory disabilities. Visit www.virtualcil.net/cils/ for a listing of centers.

■ State or local government committee, commission, or council on disabilities–These

are often part of the Governor’s office or cabinet.

■ Department of Veterans Affairs (VA) regional offices–The VA provides education and

training; compensation and benefits; medical care, as well as other services to the nation’s

veterans and their families. Visit www.va.gov/index.htm for more information.

■ Community-based nonprofit organizations and agencies–There are a variety of

community-based organizations and agencies that work with people with disabilities. Check

local listings for more information.

■ Local ADA coordinators–Contact the mayor’s office or the county government office for

more information.

■ Citizen Corps Councils–With over 1,600 Citizen Corps Councils nationwide, these councils

coordinate the grassroots emergency preparedness efforts of volunteer programs, elected

officials, business, emergency managers and citizens. The National Citizen Corps Council,

in partnership with the Department of Homeland Security’s Office of Civil Rights and Civil

Liberties, has convened a subcommittee of various national disability consumer advocacy

organizations to address the issues emergency preparedness and response as it related to

individuals with varying abilities. Visit www.citizencorps.gov for more information.

Engaging the Disability Community
Accounting for the Needs of People with Disabilities 19

Critical Questions Follow-Up Items

■ Are key staff familiar with the Occupant

Emergency Plan (OEP)?

■ Are individuals with disabilities involved

in all aspects of emergency

preparedness? If not, what steps have

been taken to engage the disability

community? Have the broad perspectives

of the disability community been

considered?

■ Do senior staff support the process of

updating your agency plan? If not, what

steps will be taken to change this?

■ Has the plan been reviewed by first

responders and facilities personnel?

■ Does any part of the plan conflict with

procedures established by nearby

agencies?
20 Preparing the Workplace for Everyone

A

Regional and Field Offices

pproximately 84 percent of all federal

employees work outside the National

Capital Region (NCR). Not only do

field representatives carry out many

of the federal programs, but they also serve as

the Federal Government’s principal means of

contact with citizens. Regional and field offices

face unique challenges when it comes to

emergency preparedness planning. Given

their unique function and locations, these

offices must consider the needs of employees

with disabilities, personnel previously

unidentified as having a disability, and the

public. It is also essential that federal safety

plans take into account the plans of agencies

and/or businesses in adjacent space. Below

are a few factors to consider when developing,

implementing, and maintaining plans, including

those for field offices.

Considerations

■ Federal agencies that share building space

with private companies or other federal

agencies must consider how another plan

(or lack thereof) will affect their own.

Note:

Federal agencies throughout the country have

unique characteristics. Some are located in

government-built and owned buildings, while

others are located in privately- owned buildings.

Some are sole occupants, while others share

space with other federal agencies or private

employers. Some occupy entire campuses,

while others may be isolated industrial-style

facilities, such as warehouses. Regardless, a

coordinated approach to evacuation or shelterin-place is essential to ensure the safety of all

building occupants.

■ Determine what effect the agency’s location

will have on egress routes and access to

resources.

Note:

Busy streets, construction, and security barriers

can all hinder an individual’s ability to evacuate.

Individuals in rural areas may have difficulty

getting home in the event of an emergency,

especially if they rely on para-transit services.

Working with local first responders, city officials,

and building personnel is essential.

■ Take into account the personnel and visitors

in the building on an average day.

Note:

Some federal agencies have very few nongovernment personnel in the building. Other

offices, especially those that provide services

to the public, have a constant flow of visitors

and non-government personnel.

■ Be aware of employees’ needs; however,

remember to also consider the needs of

others in the building. This may include

children in the daycare center, cafeteria

workers, contractors, sales representatives,

and personal visitors.
Accounting for the Needs of People with Disabilities 21

IN FOCUS:

Building Security Committees (BSCs)

Security needs vary by location, even among facilities at the same security level. In order to

adequately address security concerns at each facility under the control of U.S. General Services

Administration (GSA), Building Security Committees (BSCs) have been established. These

committees, which meet regularly as well as whenever the building tenants or an agency’s mission

changes, consist of representative(s) from each of the federal agencies occupying a particular

building. In addition to ensuring people follow building security practices and employees receive

training related to the Occupant Emergency Plan (OEP) and security awareness, the BSCs must

continually evaluate the building security standards.

Routine security assessments (using the U.S. Department of Justice’s Vulnerability Assessment

of Federal Facilities standards) are typically conducted by a Federal Protective Service (FPS)

Inspector or Physical Security Specialist (PSS) designated by the FPS/DHS. The findings from

the assessments are shared, discussed, and validated with the BSC. The Committee then conveys

its recommendations and cost estimates to GSA.

To determine if an agency has BSC representation, contact a FPS/DHS regional office. More

information can be found at www.ice.gov/graphics/fps/contact2.htm.
22 Preparing the Workplace for Everyone

Critical Questions Follow-Up Items

■ Is the building inside or outside the

National Capital Region (NCR)?

■ Does the agency partially occupy, but not

control, the building?

■ What is the approximate number of

occupants?

■ Does the agency have representation on

the Building Security Committee (BSC)?

■ Does the building population consist

mostly of Federal Government

personnel? Are the personnel from the

same agency or several federal

agencies?

■ Do private sector businesses or state or

local government agencies occupy a

portion of the building?

■ What is the flow of employees and visitors

and customers on a typical day and

week?
Accounting for the Needs of People with Disabilities 23

needed to assist individuals with disabilities

or special needs (see Evaluating Employee

and Customer Needs). In the event of an

actual emergency, responsible officials will

be implementing pre-determined and

approved protective actions.

■ Communicate the procedures for

sheltering-in-place to all building occupants

prior to an actual emergency, and mark all

designated areas with clear signage.

■ Ensure there are multiple and redundant

means of conveying timely information to

both employees and visitors with disabilities,

including deaf or hard of hearing individuals.

Keep in mind that interpreters,

transliterators, assistive listening devices,

Communication Access Realtime Translation (CART) as well as other aids or services

may not be available during the SIP.

■ Encourage staff to store any specific

personal supplies (e.g., medications,

supplies for service animals, etc.) they may

need at their desks.

Example:

U.S.Department of Labor (DOL) headquarters

has two separate procedures for sheltering-inplace, depending on the nature of the

emergency. Posture I Advisory requires that

employees and their visitors remain at their

workstations and wait for further instruction.

Posture II Advisory, used in situations deemed

highly critical, requires that staff and visitors

move to the nearest designated shelter-inplace. Employees are given laminated cards

that provide written reminders of the

Shelter-in-Place (SIP) Plans

heltering-in-Place means seeking

immediate shelter and remaining

there during an emergency rather

than evacuating. Because evacuating may put individuals at greater risk of

harm or injury, SIP may be the preferred

method of safely waiting out a hazardous event.

In most cases, the latter option only lasts a few

hours. Advance preparation can help ensure

that everyone remains as comfortable as

possible. In some cases, occupants may be

instructed to evacuate after a certain period of

time. Generally, a SIP plan involves taking the

following actions steps:

■ Shutting down the building’s ventilation

system as quickly as possible;

■ Turning off the elevators;

■ Closing all exits and entrances and securing

the loading dock and garage areas;

■ Notifying occupants and visitors–via an

audible and visual public address system,

phone, e-mail, pagers, etc.–of the event

and emergency procedures, as well as

providing updated information as needed;

and

■ Asking everyone to remain in the building,

until it is safe to leave.

Considerations

■ Determine the action steps to be taken

under given sets of emergency conditions.

Include emergency scenarios that may

occur without access to electrical power

supplies. Identify and incorporate the steps

S
24 Preparing the Workplace for Everyone

procedures and designated areas. The

information is also available on-line for those

needing alternate formats. During both types

of SIP, no one is allowed to leave or enter the

building. The doors are locked for everyone’s

protection. Each SIP area has telephone(s)

and secured cabinets, which are used to store

food and other emergency supplies. There is

enough food and supplies for both employees

and visitors for a period of time. Floor Wardens,

Zone Monitors, and security personnel have

key access to these cabinets.

Note:

Zoë Fearon of DOL’s Office of the Assistant

Secretary for Administration and Management

(OASAM) reminds employees and others that

the length of time for a shelter-in-place is

usually relatively short. “The need to shelterin-place [due to an airborne substance] only

lasts for 4-6 hours.” Although agencies should

prepare for their employees and visitors, Ms.

Fearon urges staff to store any specific

personal supplies (e.g., medications, supplies

for service animals, assistive listening devices,

extra batteries, etc.) at their desks. When the

need for a shelter-in-place has passed,

authorities explain the reason for it.

Example:

U.S. Department of Agriculture (USDA)

headquarters uses several communication

systems to keep employees and visitors

informed of situations that necessitate

sheltering-in place. These include the

Computer Emergency Notification System

(CENS), the public address system, wireless

email devices, and Local Area Network (LAN)

televisions located throughout the complex.

These same systems are used to communicate

with employees and visitors with disabilities

about obtaining assistance, if needed.

Storage lockers throughout the USDA facilities

hold emergency supplies such as water,

blankets, and medical supplies. The sheer

number of employees prevents USDA from

stocking enough supplies for everyone, so staff

maintain personal Grab and Go kits, which

contain at least a three-day supply of essential

items (e.g., hearing aid batteries, supplies for

service animals, and/or personal medical

supplies).

The USDA has two SIP movements. Because

almost all the offices in the headquarters

complex have windows, employees and visitors

are instructed to move to interior hallway

spaces, closing windows and locking doors as

they relocate. For lighter-than-air chemical, gas

and biological events, occupants move to the

lower three levels of the complex. For heavier

than air chemical, gas and biological events,

employees and visitors relocate to the upper

three floors.

Elevators are used to re-locate persons with

mobility impairments. Employees and visitors

with mobility impairments are encouraged to

self-identify to floor wardens, or to use the

“Warden Phones” to obtain permission to use

the elevators. By monitoring the weather (via

the Emergency Command Center) and staying

in close contact with other federal agencies,

the USDA is able to use the elevators until just

prior to the expected arrival time of the

hazardous plume.
Accounting for the Needs of People with Disabilities 25

Critical Questions Follow-Up Items

■ Have the steps for evaluating an

emergency situation and subsequent

action been clearly defined, agreed upon,

and communicated to all necessary staff?

■ Are there multiple methods in place to

relay timely and relevant information to all

staff and visitors?

■ Have all SIP areas been clearly marked?

■ Are plans in place that would allow for

communication with all staff and visitors

to the facility, including those who are deaf

or hard of hearing or may have

communication difficulties? If not, what

steps are being taken to ensure that there

are plans in place?

■ Are employees encouraged to keep extra

medication or personal supplies at their

desks?
26 Preparing the Workplace for Everyone

Evaluating Employee

and Customer Needs

rivacy is important. The ADA and the

Rehabilitation Act strictly limit how,

when, and what type of information

can be gathered about an

employee’s medical condition, even for

purposes of emergency preparedness.

Additionally, the Rehabilitation Act and U.S.

Office of Personnel Management (OPM)

policies require that medical information be kept

in a file separate from the employee’s personnel

file.

Considerations

■ The Rehabilitation Act of 1973 gives

agencies and federal contractors

permission to gather pertinent information

(i.e., the type of emergency assistance an

individual needs and how it relates to the

individual’s disability), and to disseminate

it to necessary personnel.9

Example:

At the U.S. Department of Energy (DOE), a Self

Identification/Needs Form has been used to

collect the information. The form, developed by

the agency’s Disability Action Council

(DAC), provides individuals with disabilities an

opportunity to voluntarily self-identify their

requirements and initiates an action by the

Emergency Personnel. The form—which asks

for an individual’s contact information, work

hours, supervisor’s name, and the type of

assistance needed—is also used in developing

personal support networks, promoting cross

training, and planning for evacuation. Several

co-workers are typically identified to assist an

individual, in the event that the primary person

is unavailable.

■ It is important to reassure employees of

confidentiality: that the information will be

shared only with those responsible for

safety and emergency preparedness.

■ Have a dialogue with employees.

Communicate the reasons for gathering any

medical information, and inform them that

responding is voluntary. In addition, let

employees know who will have access to

the information.

■ There are three key points at which the

information may be collected10:

■ Before Employment Begins: After a job

offer has been made, but before

employment commences, all entering

employees in the same job category

may be asked disability-related

questions, including whether they

would require assistance in the event

of an emergency and what type of

assistance would be necessary.

■ On the Job: All employees may be asked

to voluntarily self-identify if they have

impairments that would make assistance

necessary in the event of an emergency.

For those who respond affirmatively,

employers may ask what type of

assistance employees would need.

■ Employees with Obvious Disabilities:

Even if an employer decides not to ask

all employees to voluntarily self-identify

as needing assistance in an emergency,

employees with known disabilities may

be asked whether and what type of

assistance they may need in an

P
Accounting for the Needs of People with Disabilities 27

emergency. An employer should not

assume that employees with obvious

disabilities will always need assistance

during an evacuation. However,

remember that people with cognitive or

developmental disabilities may not have

the judgment and cognitive skills required

to articulate their needs. Generally,

people with disabilities are in the best

position to determine their own needs.

■ The Rehabilitation Act allows disclosure of

medical information to first aid and safety

personnel, as well as to those who are

responsible for implementing the

emergency preparedness plan.

■ Only medical information necessary to

implement the emergency preparedness

plan may be disclosed.

■ When making equipment decisions, it is

best to talk with people with disabilities and

other federal agencies, as well as work with

local emergency response personnel and

community organizations. Communicate

regularly with these entities in order to

educate new emergency response

personnel and to keep abreast of new

technology or procedures.

■ Those employees with service animals

should be encouraged to relay to

emergency management personnel their

preferences with regard to evacuation and

handling of the animal.

Note:

Although it may be difficult, encourage

employees to think about under what

circumstances they may have to make a

decision about leaving the service animal

behind, and share these preferences with the

appropriate personnel.

The Buddy System and Cross-Training

In a traditional buddy system, people pair up

as partners to assist each other. For most

people, the buddy system is a redundant and

additional measure that supplements other

means of notifying individuals about and

responding to an emergency. A buddy can help

ensure that an employee with a disability is

informed about and appropriately responds to

an emergency. It is important that buddies be

able to communicate with and assist the

employee with a disability.

Reliance on a single buddy can put the

employee who needs assistance at risk,

especially when the buddy is not present, able,

or willing to assist during an emergency.

Therefore, flexibility in an emergency

preparedness plan is vital.

Note:

According to Bruce McFarlane, Director of the

U.S.Department of Agriculture’s (USDA) Target

Center, plans should not be based on the buddy

or employee being in his or her own office at

the time of an emergency. He believes that

planning that is person-or location-dependent

generally has glaring weaknesses.

Consequently, he sees the buddy system as

not exclusively effective, since it is both person

and location dependent.
28 Preparing the Workplace for Everyone

IN FOCUS:

Determining Equipment Needs

One of the most critical aspects of implementing and maintaining an effective plan is determining

the type of equipment necessary to keep individuals safe, whether it be during a shelter-in-place

or an evacuation. There is no one model or piece of equipment that is appropriate for every

situation or individual. There are currently no standards governing the type of equipment that

must be provided for the safe evacuation of people with disabilities. However, below are a few

issues to keep in mind during the selection and procurement decision-making process:

■ Consider keeping extra equipment (e.g., wheelchairs, assistive listening devices, simple

communication boards) in central locations for employees or visitors.

■ Employees with disabilities are often a good resource for accommodation ideas.

Remember to consider temporary impairments and hidden disabilities.

■ Contact other agencies, local first responders and community organizations (e.g., fire and

police departments, Centers for Independent Living, etc.) for input and feedback.

■ Taking into account all occupants and visitors may necessitate obtaining equipment

different from that for specific individuals.

Additionally, architectural realities, budgetary constraints, and agency characteristics should be

evaluated, since these factors undoubtedly impact equipment decisions.

When discussing the use of equipment in emergencies, two related aspects of evacuating people

with mobility disabilities often arise: moving the individual (either by using a device or carrying the

individual) and evacuating his or her personal mobility devices. Whatever the situation, it is

essential to involve the individuals with a disability in the discussion. Keep in mind that some

people have preferences about being moved and about the handling of their mobility devices.

Additional considerations include the following:

■ As is the case with any equipment, make sure people are trained on use of the device, and

have regular practice sessions.

■ Carrying a person can be somewhat cumbersome and even dangerous. Talk with individuals

to determine the best way to move them, making sure to rehearse the procedure.

■ If there is absolutely no one available to assist the individual, consider instructing him or

her to go to a designated area and contact emergency personnel.

■ Think about implementing a plan that provides for the evacuation of mobility devices. This

makes for a smoother transition for the employees who use these devices. Otherwise,

employees will be essentially helpless upon fleeing from the emergency situation.
Accounting for the Needs of People with Disabilities 29

IN FOCUS:

Service Animals and Emergency Preparedness

Service animals assist people with disabilities with day-to-day activities. While most people may

be familiar with guide dogs trained to assist people with visual impairments, service animals may

be trained for a variety of tasks, depending on an individual’s disability. These tasks may include

alerting a person to sounds in the home and workplace, pulling a wheelchair or picking up items,

or assisting with balance.

The Americans with Disabilities Act (ADA) defines a service animal “as any guide dog, signal

dog, or other animal individually trained to provide assistance to an individual with a disability.”

Service animals do not have to be licensed or certified by state or local government. Under the

ADA, they are permitted in private facilities that serve the public, including shelters, hospitals,

and emergency vehicles; in state and local government facilities; and in the workplace.

A service animal can be excluded from a facility under the following rare circumstances:

■ The animal’s behavior poses a direct threat to the health or safety of others;

■ The animal’s presence would result in a fundamental alteration to the nature of a business

or a state or local government’s program or activity; or

■ The animal would pose an “undue hardship” for an employer.

Such instances include when a service animal displays vicious behavior toward visitors or coworkers, or when a service animal is out of control. Even in these situations, the public

accommodation, state or local government, or employer must give the individual with a disability

the opportunity to enjoy its goods, services, programs, activities, and/or equal employment

opportunities without the service animal (but perhaps with some other accommodation).

Keep in mind that the individual and his/her service animal are a team and should not be separated.

The success of this working team is based not only on hours of practice, but also a personal

bond. Typically, these animals are trained to remain with the individual and respond only to his or

her commands, unless instructed otherwise. With this in mind, consider the talking the following

actions in emergency preparedness:

■ Practice the evacuation drills with the individual and his/her service animal.

■ Discuss how to best assist if the service animal becomes hesitant or disoriented in the situation.

Make sure everyone, including the service animal, is comfortable with this routine.

■ Notify first responders of the employee with a disability and his/her service animal.

■ Encourage the employee to keep extra food and supplies on hand for the service animal.

Consider keeping supplies or food on hand for the service animals of visitors as well.
30 Preparing the Workplace for Everyone

Having an effective procedure in place may

mean augmenting the traditional buddy system

with additional supports for the employee; in

other words, have multiple individuals prepared

to assist in an emergency, thus creating

personal support networks. For example, the

U.S.Access Board chose not to use the buddy

system, given staff travel and training

schedules and the agency size (less than 30

staff). Instead, staff who volunteered to work

with people with disabilities during an

emergency situation were cross-trained.

Note:

Whether an agency utilizes the buddy system

or personal support networks, Peg Blechman,

a Compliance Specialist with the U.S. Access

Board, recommends that “participation be

voluntary, volunteers be cross-trained and have

volunteers assemble at central location(s).” If

the buddy or the employee is unavailable, a

backup system should be utilized. Blechman

emphasizes that redundancy is key!

With either approach, cross training is essential.

Individuals (and their co-workers) needing to

use emergency evacuation devices, such as

evacuation chairs, should be trained regarding

their proper operation. This will allow these

employees to better direct others on the use of

the equipment, in the event that “trained”

personnel are not available.

Example:

At the U.S. Social Security Administration

(SSA), evacuation chairs have been issued to

every employee who will require a chair for

emergency evacuation. Additionally,

evacuation chairs have been mounted in or

near every emergency stairwell above the

ground floor in SSA space to accommodate

visitors or individuals injured during an

emergency, providing a rapid means of

evacuation. Monitors are trained on the use of

the chair and employees with disabilities are

encouraged to participate in the training. Chair

training is part of the Occupant Emergency

Organization training conducted by SSA’s

Office of Protective Security Services, Office

of Facilities Management, with its training

partner, the University of Maryland’s Fire and

Rescue Institute at College Park, Maryland.

Training occurs through various means, at SSA

sites across the nation.

A few additional considerations:

■ Include training for those who work after

normal business hours.

■ Check with buddies or personal support

networks quarterly to make sure the

individuals are still willing and able to assist

in an emergency; also, be sure to notify

them of changes in work schedules.

■ Consider one-on-one training or evaluation

of evacuation devices for individuals who

may be uncomfortable practicing

evacuation procedures in a group setting.
Accounting for the Needs of People with Disabilities 31

Critical Questions Follow-Up Items

■ Has information about an employee’s

need for assistance in the event of an

emergency evacuation been collected in

a manner that is consistent with the

Rehabilitation Act?

■ Have steps been taken to clearly

communicate the reasons for gathering

the information and the importance

of maintaining the employee’s

confidentiality?

■ Has only the essential medical information

been shared with just those who need to

know (e.g., first aid personnel, safety staff,

and those responsible for implementing

the plan)?

■ Has the agency consulted with other

agencies, entities, and individuals with

disabilities in selecting equipment?

■ Are there employees with service

animals? What specific plans have been

put in place for individual and service

animal teams? Have plans been made

for visitors with service animals?

■ Have efforts been made to facilitate the

establishment of personal support

networks?

■ Have all employees needing and

providing assistance had adequate

training on equipment and emergency

procedures?
32 Preparing the Workplace for Everyone
Accounting for the Needs of People with Disabilities 33

IMPLEMENTATION

IMPLEMENTATION
34 Preparing the Workplace for Everyone

Communicating About

and Distributing the Plan

ommunicating effectively is vital in

any emergency preparedness plan.

It can impact the establishment of

emergency plans, maintenance of

an effective plan, and response to drills and/or

an actual emergency. In short, it directly affects

an individual’s ability to remain safe in an

emergency, and can mean the difference

between life and death, or well-being and injury.

One aspect of communication involves

ensuring that everyone understands the plan

and can easily locate the necessary

information. An agency may communicate

information about its emergency preparedness

plan in a number of ways (e.g., through an

internal Web site available to all employees,

through written procedures or memoranda, and

at staff meetings). Regardless of the methods

used, communications to employees with

disabilities must be as effective as those to nondisabled employees.

Considerations

■ Information distributed through the agency’s

Web site or intranet should be accessible

to blind/low-vision employees who use

screen readers, as well as those employees

who may use speech recognition

technology.

Note:

PDF files and PowerPoint presentations may

be inaccessible using screen readers. If an

agency uses such formats to communicate

emergency preparedness information, the

IMPLEMENTATION

documents should also be made available in a

word processing application or plain text. Text

descriptions should be provided for images,

graphics, and charts.

■ Hard copy documents should also be

provided electronically, whether on e-mail,

disk, or CD. Text descriptions should be

provided for graphics, images, and charts.

■ Use simple language and different

formatting techniques to highlight key points

and make the document more readerfriendly.

■ Locate the plans in a prominent place(s)

on the agency’s intranet and, if possible,

throughout the building.

■ Conduct meetings or training sessions for

staff in locations accessible to employees

who use wheelchairs.

■ Ensure effective communication with

employees who are deaf or hard of hearing

(i.e., by providing qualified sign language

interpreters, transliterators, Communication

Access Realtime Translation [CART],

assistive listening devices, or other aids/

services) at emergency preparedness

training sessions and meetings.

■ For buildings or agencies that issue

frequent-visitor identification badges (in

order to expedite security clearance each

time the non-agency personnel visits the

facility), distribute emergency evacuation

and shelter-in-place (SIP) information at the

time the identification badge is issued.

C
Accounting for the Needs of People with Disabilities 35

Critical Questions Follow-Up Items

■ Is emergency preparedness information

communicated with the same frequency

and level of detail to all employees? If

not, what steps will be taken to correct

this?

■ Is the information on emergency

preparedness on the agency Web site or

intranet easy to locate and available in a

text version? Are there text descriptions

for every image, graphic, and chart?

■ Are emergency preparedness training

sessions and meetings in accessible

locations? Are qualified sign language

interpreters, transliterators, CART,

assistive listening devices, or other aids/

services provided when necessary to

ensure effective communication with deaf

or hard of hearing employees?

■ If possible, are copies of the plan placed

in prominent locations throughout the

building?

■ Are emergency-evacuation and general

SIP information distributed to those who

have frequent-visitor identification

badges?
36 Preparing the Workplace for Everyone

Employer Responsibilities

and Employee Right to SelfDetermination

ach agency must provide a safe

workplace for all employees,

including those with disabilities. It

is incumbent upon managers who

oversee employees with disabilities to be aware

of specific emergency preparedness guidance

outlined in the agency’s Occupant Emergency

Plan (OEP). Furthermore, managers should be

proactive in discussing the topic with all

employees. At the same time, people with

disabilities must take responsibility for engaging

in emergency preparedness.

Neither the Rehabilitation Act of 1973 nor the

Americans with Disabilities Act (ADA)

specifically require emergency preparedness

plans. They do, however, require equal access

for people with disabilities to the benefits and

privileges of employment, the programs and

activities conducted or funded by the Federal

Government or state and local governments

as well as to the goods and services made

available by places of public accommodation.

If a plan is in place, it must include people with

disabilities. Employers who do not have

emergency evacuation plans may still have to

address emergency evacuation for employees

and visitors with disabilities under Sections 501

and 504 of the Rehabilitation Act and/or under

the ADA.

Employers undoubtedly bear much of the

responsibility for emergency preparedness, but

employees with disabilities must also actively

participate in the process. Dr. Richard Horne,

Supervisory Research Analyst in the Office of

Disability Employment Policy (ODEP) at the

U.S. Department of Labor (DOL), stresses that

if employees do not plan, then what they need

will not be in place when it is needed. A

dialogue between employees and employers

is essential in successful planning. While an

employer should make every effort to ensure

the safety of all employees, the reality is that

not everyone who may need assistance in an

emergency will know that they should or will

want to ask for help in advance of an

emergency. More importantly, employees

should not assume that plans have been made

to assist them.

Considerations

■ If a person believes he/she does not need

assistance, but impedes others during an

evacuation drill, talk to the individual directly

and privately to try and work out a solution.

Generally, the Rehabilitation Act prohibits

an employer from requiring that an

employee with a disability accept a

reasonable accommodation. At the same

time, an employer may take appropriate

action to ensure that an individual with a

disability does not pose a “direct threat” (i.e.,

a significant risk of substantial harm to the

individual or others) in the workplace.

■ Reconsider your agency’s definition of

disability, or at least the means of identifying

who will need assistance during an

emergency. Think broadly. Do not limit

assistance to only those who meet the

Rehabilitation Act’s definition of “disability.”

E
Accounting for the Needs of People with Disabilities 37

This will maximize the effectiveness of an

emergency preparedness program and

may encourage individuals who do not

consider themselves “disabled” to plan

ahead. Additionally, conducting practice

drills can be helpful in determining whether

or not assistance is needed during an

emergency.

Note:

June Isaacson Kailes, Associate Director at the

Center for Disability Issues and the Health

Professions at Western University of Health

Sciences, insists, “Many people who need

assistance will never, ever identify as having a

disability or having ... a special need.” She

attributes this primarily to the fact that

“...Unfortunately, many people still attach a

broad amount of stigma to disability and do

whatever they can to stay away from that effort.”

■ Regardless of whether individuals choose

to self-identify, they should be encouraged

to plan. Avoid the avoidance tendency!

Note:

As mentioned earlier, employees must take the

initiative to ensure that plans are in place for

them. Whether or not people choose to selfidentify, plans are essential to mitigating the

impact of any emergency. As June Isaacson

Kailes explains in Evacuation Preparedness:

Taking Responsibility For Your Safety: A Guide

For People With Disabilities and Other Activity

Limitations, “There is a universal human

tendency to avoid thinking about possible

emergencies. This avoidance has greater

consequences for people with disabilities than

for people without disabilities.”11

■ Involve people with disabilities in all stages

of the process. If you are constructing an

individual plan, talking with the employee

is key. The disability community motto,

“Nothing About Us Without Us,” should be

a guiding principle in emergency

preparedness planning.

Example:

During a 1993 fire drill at the U.S. Department

of Agriculture (USDA) headquarters, multiple

employees with disabilities were either left

behind or unable to evacuate. Following that

event, a panel consisting of six employees

convened to ensure this would not happen

again. In 1994, the panel prepared Occupant

Emergency Plan Review for Employees with

Disabilities. A key recommendation of the report

was the call for autonomy and independent

decision-making authority in emergency

planning.

■ Do not exclude individuals with disabilities

from employment or employment-related

activities because of fears about workplace

emergencies. Only when the agency can

demonstrate that a person with a disability

will pose a “direct threat” can it lawfully

exclude the individual from employment or

other employment-related activities.

Definition:

A direct threat means a significant risk of

substantial harm to the individual or others that

cannot be reduced or eliminated through

reasonable accommodation. Assessments

should take into account the needs of individual

employees. Avoid making generalizations

based on an individual’s disability. Concerns
38 Preparing the Workplace for Everyone

about evacuating an individual will rarely, if

ever, meet the direct threat standard.

■ Keep in mind that the Rehabilitation Act

generally prohibits agencies from limiting,

segregating, or classifying individuals with

disabilities in a manner that discriminates

against them.

Example:

If an agency places all employees with

disabilities, or those needing assistance in the

event of an emergency, in a single workspace,

this would likely violate provisions of the Act.

■ When requested as a reasonable

accommodation, an employer may relocate

a particular employee with a disability to a

different part of the facility (e.g., to the first

floor) in order to aid in the evacuation

process, as long as it is not an undue

hardship for the organization.

IN FOCUS:

Deciding Whether to Request Assistance

Employees consider the following situations when determining whether to request assistance:

■ Limitations that interfere with walking or using stairs;

■ Reduced stamina, fatigue, or tire easily;

■ Emotional, cognitive, thinking, or learning difficulties;

■ Vision or hearing loss;

■ Temporary limitations (surgery, accidents, pregnancy); or

■ Use of technology or medications.
Accounting for the Needs of People with Disabilities 39

Critical Questions

■ Are there employees who impede the

evacuation of others? Has the issue been

addressed privately and directly? Have

solutions or alternatives been suggested?

■ Have all of the following factors been

thoroughly considered when determining

whether a particular applicant or

employee with a disability would pose a

“direct threat”?

■ The nature and severity of the

potential harm

■ The likelihood that the potential harm

will occur

■ The duration of any risk posed by the

individual

■ The imminence of the potential harm

■ The availability of any reasonable

accommodation(s) that would reduce

or eliminate the risk

■ Has every effort been made to ensure that

people with disabilities have been

included in the emergency planning

process?

■ Has every effort been made to ensure that

people with disabilities have not been

segregated or discriminated against in

establishing emergency procedures?

■ Have employees made requests for

reasonable accommodations with regard

to emergency preparedness? If so, have

all these requests been fulfilled? If not,

can the agency show that providing the

accommodation(s) would impose an

undue hardship?

Follow-Up Items
40 Preparing the Workplace for Everyone

Working with

First-Responders: FirstResponder Responsibilities

and Employee Right to

Self-Determination

he priorities of first-responders and

people with disabilities sometimes

seem at odds. Accounts from

September 11, 2001, indicated that

several individuals with disabilities decided to

wait in the stairwells for rescuers. Rescuers

never reached them. Others with disabilities

chose to evacuate, with the help of co-workers

and rehearsed plans. This situation was not

unique, and it exemplifies a common dilemma:

To what extent should an agency or individual

rely on first responders to evacuate an

employee? By the same token, to what degree

should an individual be able to decide how to

get out of the building? Remember that

choosing whether to wait for first responders

in order to evacuate is a personal decision.

Nevertheless, all options should be clearly and

thoroughly explained, so the employee can

make an informed decision.

Considerations

■ Create opportunities for employees with

disabilities to make their preferences

known, and share the agency’s policy with

all staff.

Example:

Prior to September 11, 2001, at the DOL

headquarters, there was a lack of employee

knowledge regarding the Frances Perkins

Building Evacuation & Emergency Response

Handbook, and procedures related to

evacuation, what to do once outside, and reentry into the building. Furthermore, people

with disabilities were often told to “stay put” or

were confused about exactly where they should

go. Now, when appropriate, there is an

“everyone out” policy, which means that plans

provide a means for all employees to evacuate.

■ Inform the local fire department about any

particular issues that you have identified

with respect to the employees with

disabilities.

Example:

The U.S. Access Board has learned that the

police and fire department go to the front desk

first. This gives them an overview of what is

happening in the building. It is here the Board

maintains a list of all the people with disabilities

and their preferences for evacuation (i.e., staff

members who preferred to wait in the office’s

safe area for firefighters or law enforcement

officers rather than use an evacuation chair).

Briefings regarding the Board’s plans have

been held for local fire departments.

■ Involve first responders in the planning,

implementation, and maintenance phases.

This is important to ensure all procedures

facilitate getting everyone to safety as

quickly as possible.

Example:

The U.S. Department of Defense’s Defense

Intelligence Agency (DOD/DIA) periodically

conducts drills in which firefighters go to where

the employees are located in the building. The

firefighters talk to employees, either as a group

T
Accounting for the Needs of People with Disabilities 41

or individually, about next steps and give advice

in accordance with the employees’ specific

limitations. DOD/DIA’s plan also calls for the

provision of counseling, by trained personnel,

for individuals who may have a debilitating

emotional or psychiatric reaction to the stress

of an emergency.

■ The Rehabilitation Act “reasonable

accommodation” mandate is intended to

provide the same level of safety and utility

for people with disabilities as is provided to

everyone.

■ Consider purchasing evacuation chairs, and

evacuating any mobility devices (e.g.,

wheelchairs) that individuals may require

once they have been removed from the

emergency situation.

Note:

Many fire departments have ladders that

cannot reach the entire height of a multiple

story building. By having evacuation chairs

available, people with disabilities can, at the

very least, be moved to an area or floor where

emergency response personnel can assist

them further. Additionally, having a plan in

place for evacuating mobility devices makes

for a smoother transition for employees who

use them. Otherwise, employees will be

essentially helpless once they have left the

emergency situation.

Example:

The DOL headquarters has purchased extra

wheelchairs that remain in strategic locations

throughout the building (e.g., stairwells and the

main lobby). This facilitates the safe and quick

evacuation of wheelchair users and others

needing assistance.

■ Areas of refuge or areas of rescue

assistance are a requirement under the

Americans with Disabilities Act (ADA), the

Uniform Federal Accessibility Standards

(UFAS) and the International Building Code

(IBC). Such areas are only necessary in

new buildings. Structures with an approved

sprinkler system are an exception and do

not require an area of refuge. (See Legal

Considerations section for more

information.)

Note:

If an aerial evacuation (fire department

equipment with a ladder and/or a “cherry

picker”) is utilized, be sure the equipment can

reach to the room window. The rule of thumb is

that the equipment can reach up to the seventh

story, assuming the area below the window is

perfectly level and has a solid “footing.”

■ Explore the pros and cons of various

evacuation procedures, and involve

employees with disabilities and first

responders in the decision-making process.

Note:

Agencies must consider such issues as

elevator use, areas of refuge, the type of

equipment available, and which employees will

require assistance. Research, training, and

practice are essential in helping both agencies

and individuals evaluate the options and

determine the most effective practices. When

evaluating and prioritizing options, it is also

critical to consider the type of emergency.
42 Preparing the Workplace for Everyone

IN FOCUS:

First-Responder Considerations in Emergency Situations

While architects and occupants may have months to design, analyze, and plan a means of egress

in an emergency, rescuers may be faced with an evolving situation. The dynamics of the emergency

may leave the first-responder with only one course of action. It may be helpful when working with

first-responders to keep in mind some of the issues they must address, depending on the type of

emergency:

■ Evaluating the situation/scene;

■ Determining the stability of the structure;

■ Gaining access to the facility;

■ Making contact with and evaluating individuals (including medical needs);

■ Determining number of individuals;

■ Evaluating individual rescue factors;

■ Assessing resource requirements (staffing and equipment); and

■ Considering time limits.
Accounting for the Needs of People with Disabilities 43

Critical Questions Follow-Up Items

■ Have first-responders been notified of

particular issues related to employees

with disabilities? Does all staff have the

same level of safety?

■ Does the agency have a policy regarding

evacuation? Has it been clearly

communicated? Have any expressed

strong opposition? If so, how has the

issue been addressed?

■ Have first-responders been involved

throughout the process? If not, how will

this be addressed?
44 Preparing the Workplace for Everyone

Re-thinking the Elevator

Policy

ince the September 11th attacks,

there has been renewed interest in

elevator use for both occupant

egress and firefighter access. This

seems to be in direct conflict with what we, as

a society have been taught. Historically,

elevator use has been regarded as dangerous,

prohibited in virtually all emergency situations.

However, according to current standards, some

elevators are indeed operable under certain

circumstances. More importantly, fire experts

have begun advocating elevator use in highrise buildings as one method of taking

firefighters to the blaze and evacuating building

occupants.12

Considerations

■ Talk with first responders to get a clearer

understanding of both who can operate

approved elevators and under what

circumstances this can be done.

Note:

According to The American Society of

Mechanical Engineers (ASME), Phase I is also

referred to as Emergency Recall Operation. It

is defined as “the operation of an elevator

where it is automatically or manually recalled

to a specific landing and removed from normal

service because of activation of firefighters’

service” 13. Following an emergency (in which

an alarm is activated), elevators automatically

move to the main floor (or floor exiting to the

outside) and lock down in Phase I. Once fire

personnel arrive and ensure the elevators are

safe to use, authorized personnel can operate

them manually (Phase II). Most new elevators

have buttons (marked with a red fire hat) that

flash when they are unsafe for use.

■ Review the agency’s current policy on

elevator use in the event of an emergency.

Keep in mind that elevators may only be

operated in certain situations by authorized

personnel if they meet the specific criteria

and comply with appropriate local codes.

Note:

Such elevators share several characteristics

intended to ensure safety and reliability. They

must be installed in a smoke-proof hoistway

constructed to a two-hour fire resistance and

pressurized against smoke infiltration. In

addition, these elevators must be pressurized

and have enclosed lobbies with a two-hour

resistance (one-hour in buildings fully equipped

with sprinklers). Fire codes in some locations,

such as New York, preclude the use of elevators

in high rise buildings during fire emergencies.

Example:

The U.S. Department of State headquarters

has three freight elevators powered by

emergency diesel generators. They are

specifically designated for people with

disabilities, and will continue operating during

a fire, even in the event of a power failure. If

the fire is near an elevator, the elevator will not

operate. As such, employees are encouraged

to learn the location of all these elevators.

Facility personnel can activate an elevator’s

S
Accounting for the Needs of People with Disabilities 45

override and ensure the operation of elevators,

as can the District of Columbia Fire

Department.

Some of the over 40 State Department annexes

are in leased spaces where all elevators are

recalled to the main exit floor and can only be

operated by incoming firefighters. Other

buildings have elevators that continue operating

during emergencies as long as smoke is not

detected in the elevator lobbies or in the

elevator shaft.

■ Establish a policy regarding who will be

permitted to use the elevator in an

emergency, and how the determination will

be made.

Example:

At the U.S. Department of Transportation (DOT)

headquarters, any individual requesting to use

the elevator during an emergency evacuation

is allowed to do so. DOT believes this is the

safest approach because many individuals may

have hidden disabilities. In the event of an

actual emergency, this saves fire wardens

critical time, since they are not in the position

of determining whether an individual has an

actual need.

■ Determine one or more means of

evacuating individuals in the event that all

the building elevators are inoperable.

Example:

At the DOL headquarters, the use of elevators

depends on the nature of the emergency. Due

to the steel and stone makeup of the elevators,

there is a low incidence of burning. In the event

of an emergency, some elevators return to the

first floor. Others are manually operated by

Emergency Elevator Operators (EEOs) and

serve as a means of assisting persons with

disabilities out of the building.

Note:

If all of the elevators are deemed unsafe, Zoë

Fearon of DOL’s Office of the Assistant

Secretary for Administration and Management

(OASAM), says, “We would use our last line of

defense [the stairwell and an evacuation

device] to evacuate people with disabilities from

the building.”
46 Preparing the Workplace for Everyone

IN FOCUS:

A Closer Look at Elevator Safety in Emergencies

In the last several years, recognized building experts have increasingly joined forces to carefully

consider building elevators that are safer for use in the event of an emergency.

In October 2003, the National Institute of Standards and Technology (NIST) began working with

the elevator industry to develop and test more reliable emergency power systems and waterproof

components. Under consideration are software and sensing systems that adapt to changing

smoke and heat conditions, helping to maintain safe and reliable elevator operation during fire

emergencies. Such changes could allow the remote operation of the elevators during fires, thus

freeing firefighters to assist in other ways during an emergency.14

The topic was further examined in March 2004 during a workshop co-sponsored by the American

Society of Mechanical Engineers (ASME International), NIST, International Code Council (ICC),

National Fire Protection Association (NFPA), the U.S. Access Board, and the International

Association of Fire Fighters (IAFF). The Workshop on the Use of Elevators in Fires and Other

Emergencies provided a forum for brainstorming and formulating recommendations to the various

groups in an effort improve codes and standards.

The majority of recommendations led to the formation of two new task groups: The Use of Elevators

by Firefighters, and The Use of Elevators for Occupant Egress. Please visit www.asme.org for

more information. The project is a collaborative effort of ASME, NIST, ICC, NFPA, IAFF, the U.S.

Department of Homeland Security (DHS), and the Access Board.
Accounting for the Needs of People with Disabilities 47

Critical Questions Follow-Up Items

■ Does the agency have a policy on elevator

use during an emergency?

■ Have first responders been consulted in

the development of this policy? If so,

under what circumstances may elevators

be used, and who is permitted to operate

them?

■ Has a determination been made

regarding who gets priority use of the

elevators?

■ What are the alternative means of

evacuating an individual in the event that

designated elevators are inoperable?
48 Preparing the Workplace for Everyone

Emergency Notification

Strategies

n a broad level, the need for an

accessible, consistent, reliable and

redundant multi-platform emergency

notification system that effectively

serves people with disabilities is recognized

by both the Federal Communications

Commission (FCC) and the Department of

Homeland Security (DHS). People with

disabilities, like others, need access to timely

information in the event of an emergency. This

holds true not only in the community, but also

in the workplace. Consider the following

example of a deaf employee on September 11,

2001:

Employees were told to evacuate a building and

go home. For a deaf individual, a co-worker

hand-signed the word “war” and told him to get

out. He had no knowledge of what had

happened at the Twin Towers or the Pentagon.

When he was outside the building, he didn’t

see any of his co-workers, so he went back

into the office. One co-worker, who was still in

the building, again spelled out in sign alphabet

the word ‘war’ and told him to go home. He

eventually did but was unable to obtain detailed

information about what was going on while at

work.

This experience was not unique. Reports from

organizations “indicate[d] that widespread

difficulties were experienced across the

nation.”15 A national follow-up survey in Spring

2003 asked what plans or procedures had

been implemented. “This second survey found

that only a few isolated attempts had been

made across the U.S. and that there was little

or no sharing of information or coordination of

efforts.”16

Considerations

■ Implement a variety of systems, rather than

just one system to communicate

information.

Note:

Keep in mind that the specific type of

emergency will affect the method of notification.

When an emergency is combined with a loss

of power, the problem becomes even more

severe, as back-up sources of information may

not be usable by people with sensory

disabilities. Radios and telephones are not an

option for many people with hearing loss, and

text telephones (TTYs or TDDs) require power.

Web-based information and cell phone menus

are often inaccessible to people with vision

loss.

Example:

Originally, the U.S. Office of Personnel

Management (OPM) had provided pagers to

employees who were deaf and hard of hearing

so they could be notified during an emergency.

However, recently a Mylar coating was applied

to the windows of the building, which interfered

with the transmission of the alert to the

employees using the pagers. OPM then

provided wireless hand-held communication

devices to alert these employees in the event

of an evacuation or shelter-in-place.

OPM has also installed the E-POP system,

which when activated by security and

I
Accounting for the Needs of People with Disabilities 49

emergency actions displays a pop-up screen

on every computer, directing employees to

evacuate or shelter-in-place or provides other

pertinent emergency information.

■ Develop strategies for communicating with

people who are away from their desk or out

of the building.

Example:

The USDA uses a pager system to notify deaf

or hard of hearing employees during

emergencies. These pagers have two

numbers, one for the pager itself and the other

to let individuals know that there is an

emergency. All other pagers are dialed

remotely.

■ Ensure that the emergency-planning

manual has information specific to people

who are deaf or hard of hearing.

■ Make sure individuals with disabilities who

have speech or communication difficulties

can convey information quickly to those who

need to know. This can be accomplished

by whatever means works best for the

individual.

Agencies must ensure that a variety of

notification systems that are understood by all

employees are in place. Below are some

systems and situations in which they can be

utilized.

■ Fire alarms: Evacuation only

■ Hearing-Impaired Pager System (HIPS)

devices (for persons who are deaf or hard

of hearing): Fire alarms only.

■ Computer Electronic Notification Systems

(CENS): These systems can be used in all

situations, but the software system must

afford access to all. This requires them to

be compatible with screen readers and

speech recognition software (a good

system for shelter-in-place).

■ Warden Phones: These are phones located

at elevators that connect to a command

center. The command center informs

persons with mobility impairments whether

or not it is safe to use elevators. A button

inside the elevators can allow individuals

to contact the command center. Some

people believe TTYs should also be

installed in elevators to ensure similar

access for deaf or hard of hearing

employees.

■ Public Address Systems (PAS)

■ Wireless Communication Devices (e.g.,

pagers, PDAs, cell phones)

■ Short-Wave Radios: Floor Monitors and

drivers use these radios.

■ Emergency Hotline: Concerned individuals

or employers may call in (using a phone or

TTY) and obtain more information about the

situation.

■ Web Site Information
50 Preparing the Workplace for Everyone

IN FOCUS:

The Importance of Redundancy: Situations and Notification Systems

Bruce McFarlane, Director of the U.S. Department of Agriculture’s (USDA) TARGET Center, says

that all notification systems should have backup alternatives. For example, messages should be

repeated at least two to three times and kept very short when announced over the PA system.

Below are some of the possible notification systems for use in emergency preparedness and

response, as well as situations in which they may be most beneficial:

Preventive Measures:

■ Accessible signage for areas designated as sanctuaries

■ Emergency phone and TTY (teletypewriter) numbers on the agency Web site

■ Accessible signage by fire marshal phones (red phones)

■ Lobby posters or other visual devices indicating the building situation

■ Increased number of televisions in public areas–with the closed caption feature turned

on–along with correct cabling to allow television use

■ Occupant Emergency Plans (OEPs) in place in leased buildings

■ Evaluation of fire alarms to determine if more than one sound and visual options

is available

Immediate Communications:

■ Two-way radios

■ Personal messages from Emergency Command Centers

■ Personal messages from Operations Situation Rooms

■ Telephone tree/personal contacts

■ System manager messages

■ Fire alarms

■ Pagers/cell phone/handheld devices/e-mail

■ Fire marshal phones

■ Public Address Systems (PAS)

■ Internal television systems

Following an emergency:

■ System manager/memorandum message to employees

■ Periodic and regular Senior Action Team meetings

■ Weekly Management Council meetings

■ After Action Reports from Operations
Accounting for the Needs of People with Disabilities 51

Critical Questions

■ Have efforts been made to ensure that

all employees and visitors–including

those who are deaf or hard of hearing and/

or blind/low vision–have access to the

same information in a detailed and timely

manner?

■ Are there multiple methods in place to

notify individuals of emergency plans and

procedures?

■ Do these methods account for those who

may be away from their desks or the

office?

■ Do agency plans take the possible loss

of electric power into consideration?

■ Do the plans take visitors into account?

Follow-Up Items
52 Preparing the Workplace for Everyone
Accounting for the Needs of People with Disabilities 53

PRACTICE AND

MAINTENANCE
54 Preparing the Workplace for Everyone

he importance of practicing a plan

cannot be overemphasized. It

solidifies employees’ grasp of the

plan, assists employees in

recognizing they may need assistance in an

emergency, and unveils weaknesses in

emergency planning through a comprehensive

analysis of employee feedback. To this end, it

is imperative that all people participate and

provide feedback regarding the successes and

failures of a drill.

While conducting standard drills is important,

varying the drills and imbedding “stumbling

blocks” is vital to helping employees prepare

for the unexpected. Both announced and

unannounced drills should be conducted

several times a year. Drills should vary

(evacuation and shelter-in-place [SIP]) and

pose a variety of challenges, such as closed

off hallways/stairwells, blocked doors, or

unconscious individuals, along designated

evacuation routes.

Practice does make a difference. In 1993,

during the World Trade Center bombing, a

woman could not discern how to leave the

building until two co-workers came by and

reminded her about the evacuation chair under

her desk. Human factor studies support the

idea of practice: people tend to come and go

from the same place using the same route.

T Considerations

■ Establish regular opportunities to practice

agency plans for both evacuation and

shelter-in-place.

■ Ensure that all employees are familiar with

the established shelter-in-place procedures

and evacuation routes. For visitors and

customers, consider posting the plans and

exit routes in public areas, and provide

prepared “tip sheets” to visitors on days that

drills are planned.

■ Many occupants may ignore or avoid the

drills, since there are often no penalties for

not participating. Encourage everyone to

participate in practice drills.

Example:

The U.S. Environmental Protection Agency

(EPA) is finalizing computer-based training

modules on the agency’s Occupant Emergency

Plan, which will be available to all headquarters’

employees online. The training includes floor

plans and maps for all headquarters buildings.

■ Vary the type of drills and the time at which

they occur. For unannounced drills, it may

be helpful to appoint key people that know

when the drill will occur, especially

managers and supervisors of individuals

with disabilities. They can assist in

evaluating all that happens and in

developing appropriate action steps.

PRACTICE AND MAINTENANCE
Accounting for the Needs of People with Disabilities 55

■ Consider establishing a policy allowing

visitors and staff to quickly exit the building

during practice drills under extenuating

circumstances.

Note:

Visitors may not want to be detained during a

SIP drill. Those who intended to be in the

building for only a brief time (e.g., delivering a

document) and have other commitments may

protest about participating in such drills.

Consider establishing a safe exit route for such

exceptions.

■ Place roadblocks, such as blocked

entrances, “injured” individuals, or unusable

stairwells along exit routes and in the midst

of SIP drills. This will provide an opportunity

for individuals to learn new routes and help

them avoid complacency.

■ Conduct regular debriefings to determine

how improvements can be made to the

plans, and provide opportunities for

employees to provide feedback related to

what did and did not work.

Example:

The U.S. Department of Defense/Defense

Intelligence Agency (DOD/DIA) plan contains

an innovative system of assessing the

strengths and weaknesses of DIA’s emergency

preparedness plan. A red, yellow, and green

grading system is used. A grade of yellow

indicates that modifications in specific areas

are needed, while a grade of red requires all

personnel involved in an area to be retrained

regarding the DIA emergency preparedness

plan.

■ An agency plan should be viewed as a living

document. Establish a procedure for

reviewing feedback from drills and

incorporating approved changes into the

agency plan. The plan must be continually

revised and updated to reflect changes in

technology and procedures. Both research

and practice drills are essential to

continuously strengthening a plan.

Example:

At the U.S. Department of Transportation (DOT)

headquarters, lessons learned from drills,

practices, and other issues that present

themselves are reviewed by facilities, security,

and emergency support personnel. The

Department’s civil rights organizations are also

consulted on these matters. Additionally, the

civil rights organizations often raise specific

concerns with the above-identified personnel.

The DOT emergency preparedness plan is

continually updated. Employees are regularly

educated on the substance of the plan, and

the equipment is consistently updated.

Example:

One process born out of the DOD/DIA plan

is identifying training programs geared toward

DIA emergency personnel (e.g., floor wardens)

and requiring them in turn to train other DIA

employees.
56 Preparing the Workplace for Everyone

IN FOCUS:

Types of Drills

There are three types of drills: walkthrough drills, scheduled drills, and unannounced drills.

■ Walkthrough drills: These allow personnel to discuss possible difficulties and slowly

practice evacuation techniques. For example, people might practice using an evacuation

chair or carrying someone.

■ Scheduled Drills: Such drills provide an opportunity to practice evacuating people with

disabilities in a slow and controlled environment. The procedures are methodically practiced

by all.

■ Unannounced Drills: It is critical that unannounced drills occur only after scheduled

drills. This ensures that the problems are corrected, and people do not practice incorrectly.

In addition, it is important that surprise drills are not held when emotions are high (e.g.,

around the anniversary of September 11th or following a highly-publicized criminal case).

Edwina Juillet, Co-Founder of the National Taskforce on Fire/Life Safety for People with

Disabilities, recommends that emergency response staff (e.g., floor wardens) be notified

prior to such drills, so that they can practice their responsibilities.
Accounting for the Needs of People with Disabilities 57

Critical Questions Follow-Up Items

■ Does the agency have a clearly

established policy regarding the regular

and continual practice of emergency

preparedness plans? If not, is a policy in

the process of being established? If so,

does the policy include both evacuation

and SIP?

■ Has the agency met and exceeded these

requirements?

■ Have first responders been involved in

multiple practice drills and/or has their

feedback been solicited regularly on

practice drills? Have they been consulted

to ensure that equipment is as current as

possible?

■ Has an effort been made to ensure that

drills are both varied in type and time of

day?

■ Have various roadblocks been incorporated into all types of drills?

■ Are people with disabilities expected and

able to participate fully in all drills?

■ Does the agency have an established

policy for employees or visitors who may

need to leave the building during a

practice drill?
58 Preparing the Workplace for Everyone
Accounting for the Needs of People with Disabilities 59

APPENDICES
60 Preparing the Workplace for Everyone

Legal Considerations

■ Are agency emergency preparedness

personnel aware of applicable federal,

state and/or local laws? If not, what

steps are being taken to change this?

■ How do each of these laws affect the

development, implementation and

maintenance of agency emergency

preparedness plans?

■ In instances in which an agency leases

space in facilities owned by private

entities or by state or local governments,

how will responsibilities for various

aspects of the emergency preparedness

process be allocated between the

parties of the lease?

Agency Commitment

■ Have senior-level staff demonstrated a

commitment to developing,

implementing, and maintaining a plan

that includes people with disabilities?

■ If not, what can and is being done to

increase awareness of the importance

of this issue, particularly among senior

staff?

■ If senior staff have recognized the

importance of this isue, describe in

some detail evidence of this agency

commitment.

■ How might this support can be

strengthened and re-affirmed? Which

areas (e.g., communicating the plan,

practicing) need particular work? What

are some strategies for addressing

these areas?

APPENDIX A: CRITICAL QUESTIONS LIST

Involving Key Personnel

■ Are key staff familiar with the Occupant

Emergency Plan (OEP)?

■ Are individuals with disabilities involved

in all aspects of emergency

preparedness? If not, what steps have

been taken to engage the disability

community? Have the broad

perspectives of the disability community

been considered?

■ Do senior staff support the process of

updating your agency plan? If not, what

steps will be taken to change this?

■ Has the plan been reviewed by first

responders and facilities personnel?

■ Does any part of the plan conflict with

procedures established by nearby

agencies?

Regional and Field Offices

■ Is the building inside or outside the

National Capital Region (NCR)?

■ Does the agency partially occupy, but

not control, the building?

■ What is the approximate number of

occupants?

■ Does the agency have representation

on the Building Security Committee

(BSC)?

■ Does the building population consist

mostly of Federal Government

personnel? Are the personnel from the

same agency or several federal

agencies?
Accounting for the Needs of People with Disabilities 61

■ Do private sector businesses or state

or local government agencies occupy a

portion of the building?

■ What is the flow of employees and

visitors and customers on a typical day

and week?

Shelter-in-Place (SIP) Plans

■ Have the steps for evaluating an

emergency situation and subsequent

action been clearly defined, agreed

upon, and communicated to all

necessary staff?

■ Are there multiple methods in place to

relay timely and relevant information to

all staff and visitors?

■ Have all SIP areas been clearly

marked?

■ Are plans in place that would allow for

communication with all staff and visitors

to the facility, including those who are

deaf or hard of hearing or may have

communication difficulties? If not, what

steps are being taken to ensure that

there are plans in place?

■ Are employees encouraged to keep

extra medication or personal supplies

at their desks?

Evaluating Employee and Customer Needs

■ Has information about an employee’s

need for assistance in the event of an

emergency evacuation been collected

in a manner that is consistent with the

Rehabilitation Act?

■ Have steps been taken to clearly

communicate the reasons for gathering

the information and the importance of

maintaining the employee’s confidentiality?

■ Has only the essential medical

information been shared with just those

who need to know (e.g., first aid

personnel, safety staff, and those

responsible for implementing the plan)?

■ Has the agency consulted with other

agencies, entities, and individuals with

disabilities in selecting equipment?

■ Are there employees with service

animals? What specific plans have

been put in place for individual and

service animal teams? Have plans been

considered for visitors with service

animals?

■ Have efforts been made to facilitate the

establishment of personal support

networks?

■ Have all employees needing and

providing assistance had adequate

training on equipment and emergency

procedures?

Communicating About and Distributing

the Plan

■ Is emergency preparedness information

communicated with the same frequency

and level of detail to all employees? If

not, what steps will be taken to correct

this?

■ Is the information on emergency

preparedness on the agency Web site

or intranet easy to locate and available

in a text version? Are there text

descriptions for every image, graphic,

and chart?
62 Preparing the Workplace for Everyone

■ Are emergency preparedness training

sessions and meetings in accessible

locations? Are qualified sign language

interpreters, transliterators, CART,

assistive listening devices, or other aids/

services provided when necessary to

ensure effective communication with

deaf or hard of hearing employees?

■ If possible, are copies of the plan placed

in prominent locations throughout the

building?

■ Are emergency-evacuation and general

SIP information distributed to those who

have frequent-visitor identification

badges?

Employer Responsibilities and Employee

Right to Self-Determination

■ Are there employees who impeded the

evacuation of others during a drill or prior

to an actual emergency? Has the issue

been addressed privately and directly?

Have solutions or alternatives been

suggested?

■ Have all of the following factors been

thoroughly considered when

determining whether a particular

applicant or employee with a disability

would pose a “direct threat”?

■ The nature and severity of the potential

harm

■ The likelihood that the potential harm

will occur

■ The duration of any risk posed by the

individual

■ The imminence of the potential harm

■ The availability of any reasonable

accommodation(s) that would reduce or

eliminate the risk

■ Has every effort been made to ensure

that people with disabilities have been

included in the emergency planning

process?

■ Has every effort been made to ensure

that people with disabilities have not

been segregated or discriminated

against in establishing emergency

procedures?

■ Have any employees made requests

for reasonable accommodations with

regard to emergency preparedness? If

so, have all these requests been

fulfilled? If not, can the agency show

that providing the accommodation(s)

would impose an undue hardship?

Working with First-Responders: FirstResponder Responsibilities and Employee

Right to Self-Determination

■ Have first-responders been notified of

particular issues related to employees

with disabilities? Do all staff have the

same level of safety?

■ Does the agency have a policy

regarding evacuation? Has it been

clearly communicated? Have any

expressed strong opposition? If so, how

has the issue been addressed?

■ Have first-responders been involved

throughout the process? If not, how will

this be addressed?
Accounting for the Needs of People with Disabilities 63

Re-thinking the Elevator Policy

■ Does the agency have a policy on

elevator use during an emergency?

■ Have first-responders been consulted in

the development of this policy? If so,

under what circumstances may

elevators be used, and who is permitted

to operate them?

■ Has a determination been made

regarding who gets priority use of the

elevators?

■ What are the alternative means of

evacuating an individual in the event that

designated elevators are inoperable?

Emergency Notification Strategies

■ Have efforts been made to ensure that

all employees and visitors—including

those who are deaf or hard of hearing

and/or blind/low vision—have access to

the same information in a detailed and

timely manner?

■ Are there multiple methods in place to

notify individuals of emergency plans

and procedures?

■ Do these methods account for those

who may be away from their desks or

the office?

■ Do agency plans take the possible loss

of power into consideration?

■ Do the plans take visitors into account?

Practice and Maintenance

■ Does the agency have a clearly

established policy regarding the regular

and continual practice of emergency

preparedness plans? If not, is a policy

in the process of being established? If

so, does the policy include both

evacuation and SIP?

■ Has the agency met and exceeded

these requirements?

■ Have first responders been involved in

multiple practice drills and/or has their

feedback been solicited on practice

drills? Have they been consulted to

ensure that equipment is as current as

possible?

■ Has an effort been made to ensure that

drills are both varied in type and time of

day?

■ Have various roadblocks been

incorporated into all types of drills?

■ Are people with disabilities expected

and able to participate fully in all drills?

■ Does the agency have an established

policy for employees or visitors who may

need to leave the building during a

practice drill?
64 Preparing the Workplace for Everyone

Key Contacts

Interagency Coordinating Council on

Emergency Preparedness and Individuals

with Disabilities

www.dhs.gov/disabilitypreparedness

Disability Preparedness Resource Center

www.dhs.gov/disabilitypreparedness/

resourcecenter

Department of Labor (DOL)

200 Constitution Avenue, N.W.

Washington, DC 20210

Voice: (866) 4-USA-DOL (4-872-365)

TTY: (877) 889-5627

www.dol.gov

Office of Disability Employment Policy

(ODEP)

U.S. Department of Labor (DOL)

200 Constitution Avenue, N.W.

Washington, DC 20210

Voice: (866) ODEP-DOL (633-7365)

TTY: (877) 889-5627

www.dol.gov/odep

DisabilityInfo.gov

www.disabilityinfo.gov

Job Accommodation Network (JAN)

P.O. Box 6080

Morgantown, WV 26506-6080

Voice/TTY: (800) ADA-WORK

(800) 232-9675)

Fax: (304) 293-5407

E-mail: jan@jan.wvu.edu

www.jan.wvu.edu

Calls are answered from 8 a.m. to 8 p.m.

Eastern Time Monday through Thursday

and on Fridays from 8 a.m. to 7 p.m. Machines answer after-hours calls.

APPENDIX B: RESOURCES

Department of Homeland Security (DHS)

Washington, DC 20528

www.dhs.gov

Office for Civil Rights and Civil Liberties

Washington, DC 20528

Voice: (202) 401-1474

TTY: (202) 401-0470

Fax: (202) 401-4708

www.dhs.gov

Citizen Corps

800 K Street, N.W.

Suite 950

Washington, DC 20001-8000

 www.citizencorps.gov

Federal Protective Service (FPS)

Voice: (877) 4FPS-411 ((877) 437-7411)

www.ice.gov

Federal Emergency Management Agency

(FEMA)

500 C Street, S.W.

Washington, DC 20472

Phone: (202) 566-1600

www.fema.gov

Fire Administration (USFA)

16825 S. Seton Avenue

Emmitsburg, MD 21727

Voice: (301) 447-1000

Fax: (301) 447-1052

www.usfa.fema.gov

Homeland Security Presidential Directive

5 (HSPD-5)

www.whitehouse.gov
Accounting for the Needs of People with Disabilities 65

Additional Resources

The following reflects publically available

information. While every effort has been made

to ensure comprhensiveness, the level of

specificity may differ among listing.

Access Board

1331 F Street, N.W.

Suite 1000

Washington, DC 20004-1111

Voice: (202) 272-0080

(800) 872-2253

TTY: (202) 272-0082

(800) 993-2822

Fax: (202) 272-0081

E-mail: info@access-board.gov

www.access-board.gov

American Red Cross National

Headquarters

2025 E Street, N.W.

Washington, DC 20006

Phone: (202) 303-4498

www.redcross.org

American Society of Mechanical

Engineers (ASME)

Voice: (800) 843-2763/ (973) 882-1167

E-mail: infocentral@asme.org

www.asme.org

Center for Disability Issues and the Health

Professions

Western University of Health Sciences

309 E. Second Street

College Plaza

Pomona, CA 91766-1854

Phone: (909) 469-5380

E-mail: evac@westernu.edu

www.cdihp.org

Department of Agriculture (USDA)

1400 Independence Avenue, S.W.

Washington, DC 20250

www.usda.gov

USDA TARGET Center

Room 1006 South Building

1400 Independence Avenue, S.W.

Washington DC 20250-9876

Voice/TTY: (202) 720-2600 (V / TTY)

Fax: (202) 720-2681 (FAX)

target-center@usda.gov

Department of Commerce (DOC)

1401 Constitution Avenue, N.W.

Washington, DC 20230

www.doc.gov

Department of Defense (DOD)

www.dod.gov

Defense Intelligence Agency (DIA)

Voice: (202) 231-8601

www.dia.mil/

Department of Education (ED)

400 Maryland Avenue, S.W.

Washington, DC 20202

Voice: (800) USA-LEARN ((800) 872-5327)

TTY: (800) 437-0833

Fax: (202) 401-0689

Office of Special Education and

Rehabilitative Services (OSERS)

400 Maryland Avenue, S.W.

Washington, DC 20202-7100

Voice: (202) 245-7468

www.ed.gov/about/offices/list/osers
66 Preparing the Workplace for Everyone

Department of Energy (DOE)

1000 Independence Avenue, S.W.

Washington, DC 20585

Voice: (800) dial-DOE

www.energy.gov

Department of Health and Human

Services (HHS)

200 Independence Avenue, S.W.

Washington, DC 20201

Voice: (202) 619-0257/ (877) 696-6775

www.hhs.gov

Department of Interior (DOI)

1849 C St., N.W.

Washington, DC 20240

Voice: (202) 208-3100

www.doi.gov

Department of Justice (DOJ)

950 Pennsylvania Avenue, N.W.

Washington, DC 20530-0001

www.usdoj.gov

Disability Rights Section

U.S. Department of Justice

950 Pennsylvania Avenue, N.W.

Civil Rights Division

Disability Rights Section - NYAV

Washington, D.C. 20530

Fax: (202) 307-1198

www.usdoj.gov/disabilities.htm

For information and technical assistance

about the Americans with Disabilities Act

(ADA) contact the ADA Information Line.

ADA Specialists are available to provide

ADA information and answers to technical

questions on Monday, Tuesday, Wednesday, and Friday from 9:30 a.m. until 5:30

p.m. or on Thursday from 12:30 p.m. until

5:30 p.m. (Eastern Time).

Voice: (800) 514-0301

TTY: (800) 514-0383

Department of State (DOS)

2201 C Street N.W.

Washington, DC 20520

Voice: (202) 647-4000

TTY: (800) 877-8339

(Federal Relay Service)

www.state.gov

Department of Transportation (DOT)

400 7th Street, S.W.

Washington, DC 20590

E-mail: dot.comments@ost.dot.gov

www.dot.gov

Disability Resource Center

400 7th Street, S.W.

M-14.4.4, Room 2110

Washington, DC 20590

Voice: (202) 493-0625

TTY: (202) 366-5273

Fax: (202) 366-3571

Email: drc@dot.gov

www.drc.dot.gov

www.dotcr.ost.dot.gov/asp/

emergencyprep.asp

Department of Treasury (TREAS)

1500 Pennsylvania Avenue, N.W.

Washington, DC 20220

Phone: (202) 622-2000

Fax: (202) 622-6415

www.treas.gov
Accounting for the Needs of People with Disabilities 67

Disability Preparedness Center

1010 Wisconsin Avenue, N.W.

Suite 340

Washington, DC 20007

Voice/TTY: (202) 338-7158 x201

Fax: (202) 338-7216

E-mail: DPC@inclusioninc.com

www.disabilitypreparedness.com

Environmental Protection Agency (EPA)

Ariel Rios Building

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460

Voice: (202) 272-0167

www.epa.gov

Equal Employment Opportunity Commission (EEOC)

1801 L Street, N.W.

Washington, DC 20507

Voice: (202) 663-4900

TTY: (202) 663-4494

You can be automatically connected to your

nearest Field Office by calling:

Voice: (800) 669-4000

TTY: (800) 669-6820

Federal Communications Commission

(FCC)

445 12th Street, S.W.

Washington, DC 20554

Voice: (888) 225-5322

TTY: (888) 835-5322

fccinfo@fcc.gov

www.fcc.gov

Disability Rights Office

www.fcc.gov/cgb/dro/

General Services Administration (GSA)

www.gsa.gov

U.S. Code of Federal Regulations Title 41

Chapter 102-74, which specifies the need

for an Occupant Emergency Plan (OEP):

www.access.gpo.gov/nara/cfr/waisidx_04/

41cfr102-74_04.html

National Institute of Standards and

Technology (NIST)

100 Bureau Drive, Stop 1070

Gaithersburg, MD 20899-1070

Voice: (301) 975-NIST (6478)

TTY: (301) 975-8295

E-mail: inquiries@nist.gov

www.nist.gov

National Council on Disability (NCD)

1331 F Street, N.W.

Suite 850

Washington, DC 20004 

Voice: (202) 272-2004

TTY: (202) 272-2074

E-mail: info@ncd.gov

www.ncd.gov

National Council on Independent Living

(NCIL)

1916 Wilson Boulevard

Suite 209

Arlington, VA 22201

Voice: (703) 525-3406

TTY: (703) 525-4153

Fax: (703) 525-3409

Email: ncil@ncil.org

For a listing of Centers for Independent

Living (CILs) by state visit www.virtualcil.net/

cils/
68 Preparing the Workplace for Everyone

National Fire Protection Association

(NFPA)

1 Batterymarch Park

Quincy, MA 02169-7471

Phone: (617) 770-3000

Fax: (617) 770-0700

www.nfpa.org

National Organization on Disability (NOD)

910 Sixteenth Street, N.W., Suite 600

Washington, DC 20006

Voice: (202) 293-5960

Fax: (202) 293-7999

TTY: (202) 293-5968

Email: ability@nod.org

www.nod.org

National Taskforce on Fire/Life Safety for

People with Disabilities

637 Riverside Drive

Luray, VA 22835-2910

Voice/Fax (by appointment): (540) 743-4601

E-mail: edwina@shentel.net

Northern Virginia Resource Center for

Deaf and Hard of Hearing Persons (NVRC)

3951 Pender Drive, Suite 130

Fairfax, VA 22030

Voice: (703) 352-9055

TTY: (703) 352-9056

Fax: (703) 352-9058

E-mail: info@nvrc.org

Office of Personnel Management (OPM)

1900 E Street, N.W.

Washington, DC 20415-1000

Voice: (202) 606-1800

TTY: (202) 606-2532

www.opm.gov

President’s Committee for People with

Intellectual Disabilities

U.S. Department of Health and Human

Services

Administration for Children and Families

Aerospace Center, Suite 701

370 L’Enfant Promenade, S.W.

Washington, DC 20447

Voice: (202) 619-0634

www.acf.hhs.gov/programs/pcpid/

Social Security Administration (SSA)

6401 Security Boulevard

Baltimore, MD 21235-0001

Voice: (800) 772-1213

TTY: (800) 325-0778

www.socialsecurity.gov
Accounting for the Needs of People with Disabilities 69

July 22, 2004

Individuals With Disabilities In Emergency Preparedness

By the authority vested in me as President by the Constitution and the laws of the United States

of America, and to strengthen emergency preparedness with respect to individuals with disabilities,

it is hereby ordered as follows:

Section 1. Policy. To ensure that the Federal Government appropriately supports safety and

security for individuals with disabilities in situations involving disasters, including earthquakes,

tornadoes, fires, floods, hurricanes, and acts of terrorism, it shall be the policy of the United

States that executive departments and agencies of the Federal Government (agencies):

(a) consider, in their emergency preparedness planning, the unique needs of agency employees

with disabilities and individuals with disabilities whom the agency serves;

(b) encourage, including through the provision of technical assistance, as appropriate,

consideration of the unique needs of employees and individuals with disabilities served by State,

local, and tribal governments and private organizations and individuals in emergency preparedness

planning; and

(c) facilitate cooperation among Federal, State, local, and tribal governments and private

organizations and individuals in the implementation of emergency preparedness plans as they

relate to individuals with disabilities.

Sec. 2. Establishment of Council. (a) There is hereby established, within the Department of

Homeland Security for administrative purposes, the Interagency Coordinating Council

on Emergency Preparedness and Individuals with Disabilities (the “Council”). The Council shall

consist exclusively of the following members or their designees:

(i) the heads of executive departments, the Administrator of the Environmental Protection Agency,

the Administrator of General Services, the Director of the Office of Personnel Management, and

the Commissioner of Social Security; and

(ii) any other agency head as the Secretary of Homeland Security may, with the concurrence of

the agency head, designate. 

APPENDIX C: EXECUTIVE ORDER 13347
70 Preparing the Workplace for Everyone

(b) The Secretary of Homeland Security shall chair the Council, convene and preside at its

meetings, determine its agenda, direct its work, and, as appropriate to particular subject matters,

establish and direct subgroups of the Council, which shall consist exclusively of Council members.

(c) A member of the Council may designate, to perform the Council functions of the member, an

employee of the member’s department or agency who is either an officer of the United States

appointed by the President, or a full-time employee serving in a position with pay equal to or

greater than the minimum rate payable for GS-15 of the General Schedule.

Sec. 3. Functions of Council. (a) The Council shall:

(i) coordinate implementation by agencies of the policy set forth in section 1 of this order;

(ii) whenever the Council obtains in the performance of its functions information or advice from

any individual who is not a full-time or permanent part-time Federal employee, obtain such

information and advice only in a manner that seeks individual advice and does not involve collective

judgment or consensus advice or deliberation; and

(iii) at the request of any agency head (or the agency head’s designee under section 2(c) of this

order) who is a member of the Council, unless the Secretary of Homeland Security declines the

request, promptly review and provide advice, for the purpose of furthering the policy set forth in

section 1, on a proposed action by that agency.

(b) The Council shall submit to the President each year beginning 1 year after the date of this

order, through the Assistant to the President for Homeland Security, a report that describes:

(i) the achievements of the Council in implementing the policy set forth in section 1;

(ii) the best practices among Federal, State, local, and tribal governments and private organizations

and individuals for emergency preparedness planning with respect to individuals with disabilities;

and

(iii) recommendations of the Council for advancing the policy set forth in section 1.

Sec. 4. General. (a) To the extent permitted by law:
Accounting for the Needs of People with Disabilities 71

(i) agencies shall assist and provide information to the Council for the performance of its functions

under this order; and

(ii) the Department of Homeland Security shall provide funding and administrative support for the

Council.

(b) Nothing in this order shall be construed to impair or otherwise affect the functions of the

Director of the Office of Management and Budget relating to budget, administrative, or legislative

proposals.

(c) This order is intended only to improve the internal management of the executive branch and

is not intended to, and does not, create any right or benefit, substantive or

procedural, enforceable at law or in equity by a party against the United States, its departments,

agencies, instrumentalities, or entities, its officers or employees, or any other person.

GEORGE W. BUSH

THE WHITE HOUSE,

July 22, 2004.
72 Preparing the Workplace for Everyone

1 Preparing the Workplace for Everyone assumes that an OEP has been prepared by the

agency and is intended to supplement the OEP with information specific to individuals with

disabilities. For more information on OEPs and GSA’s Occupant Emergency Program for

federal buildings it manages, see www.ice.gov/graphics/fps/org_oep.htm.

2

 National Council on Disability. Saving Lives: Including People with Disabilities in Emergency

Planning. Washington: (NCD), 11.

3

 Miles, Donna. (2001). An OSHA Office Evacuates. Job Safety & Health Quarterly (Fall),

20–22; U.S. Department of Labor. Emergency Preparedness for People with Disabilities.

Washington: (DOL), 75–76.

4 See 41 C.F.R. § 102–74.230 and 29 C.F.R. § 1910.38–39. For additional clarification, see

Occupational Safety and Health Administration’s (OSHA) Compliance Directive CPL 2-1.037.

Available at www.osha.gov/OshDoc/Directive_pdf/CPL_2-1_037.pdf.

5

 A guide to assist agencies in the development of OEPs, and contact information for the FPS/

DHS, are available at www.ice.gov/graphics/fps/org_oep.htm.

6 See 28 C.F.R. pt. 36, App. A, and § 4.1.3 (9).

7

 U.S. Office of Personnel Management. Federal Manager’s/Decision Maker’s Emergency

Guide, 4. Available at http://www.opm.gov/emergency/PDF/ManagersGuide.pdf.

8

 Hargett, Kathy (PCPID). E-mail to the Office of Disability Employment Policy (ODEP). 21

May 2005.

9 The complete text of the Rehabilitation Act of 1973, as amended, is available at www.accessboard.gov/enforcement/Rehab-Act-text/intro.htm.

10 For more information, see the Equal Employment Opportunity Commission’s (EEOC) Fact

Sheet on Obtaining and Using Employee Medical Information as Part of Emergency Evacuation Procedures, available online at www.eeoc.gov/facts/evacuation.html.

11 Kailes, June Isaacson. Evacuation Preparedness: Taking Responsibility For Your Safety: A

Guide For People With Disabilities and Other Activity Limitations, 2002, 6. Published and

distributed by Center for Disability Issues and the Health Professions, Western University of

Health Sciences, 309 E. Second Street, Pomona, CA 91766-1854, Phone: (909) 469-5380,

TTY (909) 469-5520, Fax: (909) 469-5407, Email: evac@westernu.edu. Available at

www.cdihp.org/products.htm#evac-guide

ENDNOTES
Accounting for the Needs of People with Disabilities 73

12 National Institute of Standards and Technology (NIST). (24 October 2003). Developing

Elevators that Function During Fires. National Institute of Standards and Technology (NIST)

Tech Beat.

13The American Society of Mechanical Engineers. A17.1 Handbook on Safety Code for Elevators and Escalators.

14 Id.

15 Brick, K.N., & Heppner, C.A. (2003). Excerpts from Personal Experiences of Deaf and Hard

of Hearing Persons: September 11, 2001 and Its Aftermath, p. 2. Deaf and Hard of Hearing

Consumer Advocacy Network & Northern Virginia Resource for Deaf and Hard of Hearing

Persons;

See also Stout, C. et al. (2003). Emergency Preparedness and Communication Access: Lessons Learned Since 9/11 and Recommendations. Deaf and Hard of Hearing Consumer Advocacy Network & Northern Virginia Resource for Deaf and Hard of Hearing Persons.

16 Id.
74 Preparing the Workplace for Everyone