### BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON DC

_____________________________________ ) Formal Third-Party Complaint of ) ) FRANK DRUM ) ) Complainant, )

) v. ) DOCKET OST-2013-0093 ) SOUTHWEST AIRLINES CO. and ) PRIMEFLIGHT AIRLINE SERVICES, INC. ) ) Respondents )

_____________________________________ )

ANSWER AND MOTION TO DISMISS OF SOUTHWEST AIRLINES CO. Communications with respect to this document should be sent to:
Mark Shaw Robert W. Kneisley Vice President General Counsel Associate General Counsel and Corporate Secretary Leslie C. Abbott SOUTHWEST AIRLINES CO. Senior Attorney 2702 Love Field Drive SOUTHWEST AIRLINES CO. Dallas, TX 75235
-1611 1901 L Street, N.W., Suite 640 Washington, D

.C

. 20036 bob.kneisley@wnco.com leslie.abbott@wnco.com (202) 263
-6285

June 20, 2013

### BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON DC

_____________________________________ ) Formal Third-Party Complaint of ) ) FRANK DRUM ) ) Complainant, )

) v. ) DOCKET OST-2013-0093 ) SOUTHWEST AIRLINES CO. and ) PRIMEFLIGHT AIRLINE SERVICES, INC. ) ) Respondents )

_____________________________________ )
ANSWER AND MOTION TO DISMISS OF SOUTHWEST AIRLINES CO. Pursuant to Rule 405 and 408 of the Department‟s Rules of Practice, Southwest Airlines Co. (Southwest or the Company) hereby files this Answer and Motion to Dismiss in response to the formal third
-party complaint filed with the Department by the Service Employees International Union (SEIU) on behalf of Frank Drum dated May 7, 2013. 1 

### Mr. Drum is employed by PrimeFlight Airline Services (PrimeFlight) as a wheelchair attendant at Philadelphia International Airport (PHL) under a service contract between PrimeFlight and Southwest. 2 

### The Complaint alleges that Southwest violated the Air Carrier Access Act (ACAA) and the Department‟s implementing regulations in 14 C

. F

. R

. Part 382 by failing to provide: (1) required training on the provision of air travel to

1 The Department granted Southwest and PrimeFlight motions for an extension of time to answer the Complaint until June 20, 2013. See June 10 and June 18 Notices filed in this docket

. 2 PrimeFlight, as a co-respondent, concurs with and joins in this Answer.

### Southwest Airlines Co.

Page 2 passengers with a disability, (2) training on the proper and safe operation of equipment used to accommodate passengers with a disability, and (3) equipment in sound working condition to assist passengers with a disability. The Complaint requests that the Department institute a formal enforcement proceeding to determine if Southwest and PrimeFlight violated the ACAA and applicable regulations and if so, order Southwest to: (1) provide, or ensure that PrimeFlight provides, “adequate training to proficiency to Complainant and all other PrimeFlight employees who provide assistance to individuals with disabilities, concerning the applicable regulations and all required equipment and procedures”, (2) provide and maintain, or ensure that PrimeFlight provides and maintains, “all necessary and proper accessibility equipment in sound working condition at PHL as required under applicable regulations, and (3) impose “all appropriate penalties on Southwest and PrimeFlight for their failure to adhere to the ACAA and all applicable regulations.” The Complaint is completely unfounded and should be dismissed. Strict compliance with the Department‟s disability regulations is an important priority for Southwest, and the Company devotes significant resources to ensuring that it meets or exceeds all ACAA and DOT requirements

. To this end, Southwest regularly performs audits on PrimeFlight and all contractor training files to ensure training has been completed to meet all federally mandated requirements, as well as Southwest‟s policies and procedures. Southwest also reviews all customer complaints naming contractors, including any ACAA complaints. In this case, records retained by Southwest and PrimeFlight show conclusively that Mr. Drum was provided with training that met or surpassed the regulatory

### Southwest Airlines Co.

Page 3 requirements in each area, and that Southwest took appropriate steps through its vendor to provide the necessary equipment in sound working condition as required under 14 C

. F

. R. § 382.91

. Accordingly, the allegations are entirely without merit and the Complaint should be dismissed with prejudice

.
I. TRAINING RECORDS AND WHEELCHAIR MAINTENANCE LOGS PROVIDE CONCLUSIVE EVIDENCE THAT SOUTHWEST MET OR EXCEEDED ALL ACAA AND PART 382 REQUIREMENTS. Southwest retains PrimeFlight at PHL to provide wheelchair assistances to customers with disabilities who request assistance between the airport curbside and the aircraft gate and between the aircraft gate and baggage claim

. PrimeFlight employees are expected and trained to provide safe and courteous service in accordance with regulations set forth in 14 C

. F

. R

. § 382.141. Contrary to the allegations contained in the Complaint, Southwest and PrimeFlight have on-going mandatory training programs in place for all contract wheelchair attendants. Southwest and PrimeFlight training materials, training sheets signed by Mr. Drum and wheelchair equipment records show conclusively that the training curriculum, as well as the equipment maintenance program, fully comply with all ACAA and Part 382 requirements. The allegations contained in the Complaint are therefore meritless and should be dismissed without delay

.
II. RESPONSES TO THE COMPLAINT’S SPECIFIC ALLEGATIONS
. Southwest denies all assertions of wrongdoing in the Complaint

. Pursuant to 14 CFR § 302.408(b), Southwest‟s responses to each specific allegation are as follows:

### Southwest Airlines Co.

Page 4
1. ALLEGATION: “Southwest Airlines and PrimeFlight Failed to Provide Employee Training Required Under 14 C.F.R. §§ 382.141(a)(1)(i)&(ii). ” The Complaint states that PrimeFlight “did not provide [Mr. Drum] with any formal training when he began his job at PrimeFlight,” and that “Drum was simply instructed to „shadow‟ a co
worker”‟ but was “later given instruction on techniques for manually lifting a passenger to assist them in transferring from a wheelchair.”

RESPONSE: SOUTHWEST DENIES THIS ALLEGATION. Review of the training records, as well as Mr. Drum‟s signature acknowledging receipt of relevant training, show that Southwest and PrimeFlight met or exceeded the training requirements contained in Part 382.141 (a)(1)(i)&(ii)

. These regulations require that air carriers “ensure training to proficiency” for personnel who deal with the traveling public on the requirements of Part 382 and other regulations affecting the provision of air travel to passengers with disabilities and that air carriers ensure their procedures are consistent with Part 382 concerning the provision of air travel to passengers with a disability, including the proper and safe operation of any equipment used to accommodate passengers with a disability. PrimeFlight training records show Mr. Drum received Initial Training on May 12, 2005, two days after he was hired with PrimeFlight. See Exhibit A

. This training was comprehensive and included instruction on customer service (class #420), sensitivity relating to the ADA & ACAA (class #421), wheelchair operation (class #820), wheelchair
safety (class #521), a work place safety overview and a class on diversity, discrimination & sexual harassment policy

. See Exhibit B. The “Acknowledgment of Receipt” that Mr. Drum signed provides conclusive evidence that he received and

### Southwest Airlines Co.

Page 5 completed Initial Training. See Exhibit C. During the Initial Training course, new employees were encouraged to ask questions and discuss “what if” scenarios with the instructor. This training was followed
-up with a 12 question quiz on the materials for all participants. Mr. Drum received a 100% score on the quiz following the training. See Exhibit D

. In addition to the initial classroom training described above, Mr. Drum then completed PrimeFlight‟s “On The Job” training by shadowing an experienced wheelchair service provider at PHL for between four and eight hours. See Exhibit E . This training is particularly valuable for new employees because it allows them to apply their classroom learning on the ACAA and Part 382 requirements to real
-life scenarios and experience the subtlety and variation of customer issues first hand

. Shortly after Mr. Drum received Initial and On The Job Training from PrimeFlight, Southwest provided him with additional Wheelchair and Assistive Device Training which covered, among other things:

“Understanding the Customers‟ wheelchair or assistive device is an extension of the person; Understanding the importance of communication to the Customer and Coworkers when handling the wheelchair or assistive device; Completing a wheelchair inspection tag; and Handling the wheelchair or assistive device in a careful manner keeping the Customer in mind.” See Exhibit F for course description and training sheet signed by Mr. Drum. Furthermore, Southwest records that include Mr. Drum‟s signature show that he also completed the Company‟s Disability Awareness Recurrent Training Class on March

### Southwest Airlines Co.

Page 6
23, 2007, June 24, 2010 and April 17, 2012

. See Exhibit G

. The training materials attached in Exhibits H and I show that the class is comprehensive and covers ACAA and Part 382 requirements in detail. 3 

### Finally, Southwest‟s contract with PrimeFlight states explicitly that Wheelchair Attendants who are contract employees for Southwest are not authorized to perform “lift and transfer” procedures for customers. Southwest‟s longstanding policy is to have its own employees perform these maneuvers. Contractors are only authorized to assist passengers who are ambulatory and do not require lifts of physical assistance beyond a stable arm. Thus the statement in the Complaint that Mr. Drum was given “instruction on techniques for manually lifting a passenger to assist them in transferring from a wheelchair” is not pertinent to his work for Southwest

. The PrimeFlight and Southwest training records described in detail above show conclusively that Mr. Drum received the training required by Part 382.141(a)(i)&(ii) and that both companies fully complied with the ACAA and the Department‟s implementing regulations in this area. Accordingly, Mr. Drum‟s claim that Southwest and PrimeFlight failed to provide him with adequate training is entirely without merit and should be dismissed

. 2. ALLEGATION: “Southwest Airlines and PrimeFlight Failed to Provide Employee Training Required Under 14 C.F.R. § 382.141(a)(3).” The Complaint alleges that “none of the training Drum received included recognizing requests for communication accommodation from individuals whose hearing or vision is impaired and to use the most common methods for communicating with these individuals that are

3 Due to the extensive nature of the training materials, only pages that specifically covered ACAA and Part 382 issues relevant to this matter are included in the attachments.

### Southwest Airlines Co.

Page 7 readily available and to use established means of communicating with these passengers when they are available, as required under 14 C.F.R. § 382.141(a)(3) and 14 C.F.R. § 382.143(a)(4).” RESPONSE: SOUTHWEST DENIES THIS ALLEGATION. Southwest and PrimeFlight training records signed by Mr. Drum show that he received training in full compliance with 14 CFR § 382.141(a)(3). Moreover, the records show that Southwest provided Mr. Drum with this training every other year, exceeding the regulatory requirement contained in 14 CFR. § 382.141(a)(5) to provide it every three years. Specifically, training on proper assistance to vision and hearing impaired passengers was covered in PrimeFlight‟s Initial Training, in both the Customer Service Training (class #420) and the Sensitivity Training (class #421 ). In fact, the Sensitivity Training focused entirely on ACAA requirements and guidelines for assisting and interacting with passengers with disabilities. See Exhibit B, pp. 11
-25. As shown in Exhibit C, Mr. Drum acknowledged in writing that he received these courses on May 12, 2005. In addition, training on proper communication with vision and hearing impaired passengers is also thoroughly covered in Southwest‟s recurrent Disability Awareness Training

. This training specifically covered recognizing requests for communication accommodation from individuals whose hearing or vision is impaired and direction on how to best communicate with these individuals in full compliance with 14 C.F.R. § 382.141(a)(3)

. See Exhibit F, Best Practices, pp. 15
-17. Mr. Drum signed training records acknowledging that he received and completed this training in 2007, 2010 and 2012. See Exhibit G. Moreover, as an additional measure to ensure disabled

### Southwest Airlines Co.

Page 8 passengers receive all of the services that they require, PrimeFlight employees are trained to call a Southwest Airlines Complaint Resolution Official (CRO) in the event that they are unsure of how to assist a person with a disability or in the event the person with a disability has a complaint. Finally the Complaint references training requirements contained in 14 C

. F

. R

. § 382. 143(a)(4). However, these requirements only apply to “personnel whose employment in any given position commences after May 13, 2009.” Since Mr. Drum was hired by PrimeFlight in 2005, these requirements are inapplicable in this case

. Once again, the documented training materials and sign
-in sheets described above demonstrate that the allegations contained in the Complaint are either false and or inapplicable and should therefore be dismissed. 3. ALLEGATION: “Southwest Airlines and PrimeFlight Failed to Provide Adequate Equipment in Sound Working Condition Required Under 14. C.F.R. § 382.91(b).”

RESPONSE: SOUTHWEST DENIES THIS ALLEGATION. In accordance with 14 CFR § 382.51(b)(2), Southwest contracts with Aviation Mobility, Inc. to provide and maintain the wheelchairs used by its contract employees at PHL

. A review of the equipment inspection, adjustment, and replacement records indicate that the wheelchairs are well maintained in full compliance with the regulatory requirements

. Exhibit J shows an example of the Wheelchair Maintenance Logs that Aviation Mobility uses to ensure the wheelchairs are in good working order. Each wheelchair is uniquely identified on these logs and Aviation Mobility monitors 22 aspects of each wheelchair to ensure it remains in sound working condition

. Some of the categories include “Right

### Southwest Airlines Co.

Page 9 Fork & Bearing”, “Left Foot Plate”, and “Anti
-Fold Bar” for example. Southwest removes from service any airport wheelchair that is reported as being unsafe, damaged, or not in working condition and requests service from its contracted wheelchair provider to inspect and repair or replace the chair. For example, Exhibit J shows that wheelchair B18P08042 was replaced with a new wheelchair on September 27, 2012. Consistent with training for all PrimeFlight employees, Mr. Drum received instruction in his Initial Training that he should not use chairs with missing parts or that are not in good working condition. Mr. Drum was also clearly instructed that he should report any equipment problems to management immediately so that they can be fixed by Southwest‟s contracted wheelchair repair facility. See Exhibit B, pp. 27
-28 (“If you feel a chair is unsafe, RED TAG it and contact your Supervisor.” Emphasis in the original.) Accordingly, this allegation is also without merit and should be dismissed.

III. AFFIRMATIVE DEFENSES Southwest asserts the following affirmative defenses to the Complaint in accordance with Rule 408(b) of the Department‟s Rules of Practice. A. The Complaint fails to state a claim on which relief can be granted. B. Any actions of Southwest as they relate to Mr. Drum were in full compliance with the law. C. Southwest, and/or PrimeFlight, have met or exceeded all Part 382 training requirements as they relate to Mr. Drum. D. The Complaint has failed to state any facts that will enable the Department to institute an enforcement proceeding.

### Southwest Airlines Co.

Page 10
IV. MOTION TO DISMISS There is no factual basis whatsoever for this Complaint. As shown in detail above, Southwest devotes significant and appropriate resources to training its employees and contractors in full compliance with the Air Carrier Access Act and the Department‟s implementing regulations in Part 382. In response to every allegation at issue here, Southwest has provided factual evidence of compliance that is beyond dispute and has shown the Complaint‟s allegations to be utterly false and without foundation. Far from being legitimate, this complaint, and the five almost identical complaints SEIU filed simultaneously against other airlines, are part of an SEIU unionizing campaign for PrimeFlight employees. To manipulate the DOT‟s complaint process for this self
-serving purpose, based on nothing more than patently false allegations, is an improper use of the Department‟s procedures that should be soundly rejected. Moreover, the filing of such a factually baseless complaint warrants sanctions as an abuse of the Department‟s process and resources. At the very least, the Complaint should promptly be dismissed with prejudice. Respectfully submitted,
______________________)_ Leslie C. Abbott June 20, 2013

### CERTIFICATE OF SERVICE

I hereby certify that on June 20, 2013, a copy of the foregoing was served via e
mail on the following persons: Sam.podberesky@dot.gov Blane.workie@dot.gov Conor.hanlon@seiu.org mmarudus@primeflight.com

______________________________ Dorothy C. Sauvinet

# EXHIBIT A

# Training Record

- Name Date of Hire Job 

### Frank Drum 

### 5/10/2005

•

### WorkplaceS~ • Back

# nrot~ct**and~** vlew • Sensitivity Traiilina A -Lifting

-



### -



### -

-

-

-

## !I

# ~ il t

## ~ f


# EXHIBIT B

# WHEELCHAIR ASSISTANCE TRAINING MANUAL
Customer Service Class #420 Sensitivity-Air Carrier Access Act #421 Safety Class #521 Wheelchair Assistant Operations Guide # 

# 820

ProprietaryInformation: For use byPrimeFJightA viat/on personnelonly. Unauthon"zed dissemination of this document orinformation containedherein isprohibited.

PrimeFiightAviation, WheelchiJir Troining Manual 

### 1 · Class #420, #421, #521 and #820 04/2009 NOTE: All training minimums must exceed the standards outlined by PrimeF/ight Aviation dient air operator. PropriefBry Inlbtmation: For use by PrimeRightAviation Personnel only

.. Unauthorizedmssemination ortflls document or Information contained herein Isprohibited.

## TABLE OF CONTENTS

Topic Purpose Wheelchair Training Requirements 

### Initial Classroom Hours On the Job Training Recurrent Training Customer SeRVice Training 

### Outstanding Customer Service Characteristics of Outstanding Customer Service How to Provide Outstanding Customer Service Customer Service Review Sensitivity Training -Air Carrier Access Act 

### Americans with Disabilities Act {ADA) Air Carrier Access Act (ACAA) Definition of Disability ACAA Don'ts and Dos Exit Row Restrictions The Ten Commandments Common Sense and Being sensitive Interactive Training Common Sense Tips Customer service Summary Wheelchair Safety 

### Know Your Equipment Seating Customers Lifting Tips Transporting Customers Aisle Chair Transfers Wheelchair Assistance Operations Guide 

### Wheelchair Customer Service Objective Know Your Security Screening Proper Conduct Training Evaluation Acknowledgement ofTraining On-The-Job & Remrrent Training Page 

### 3 4 5 5 5 6 

### 7 

### 9 

### 13 

### 17 18 

### 19 20 20 

### 21 21 

### 22 23 

### 24 25 25 

### 26 27 

### 28 29 

### 30 31 

### 32 

### 33 34 

### 35 

### 36 37 

### 38

PrfmeRightAviation, Wheelchair Training Manual 

### 2 Oass #420, #421, #521 and#820 04/2009 NOTE: All training minimums must &ceed the standards oufiined by PrlmeFI!ght Aviation client air operator. Proprietary Information: For use by PrimeRightAv/ation Personnelonly

.. Unauthorized dissemination ofthis dOCllment orinformation contLJ!ned herein isprohibited.

# I ! 

# ! PURPOSE This manual contains information, methods, and procedures that apply to your overall responsibilities and performance with physically challenged customers who request Wheelchair Transport Assistance. As Primeflight _Aviation Team Members, it is all our duty to provide safe and comfortable quality assistance to all our customers especially to 

### our physically challenged customers. 

## POLICY 1. Primeflight Aviation's policy is to provide comfortable, quality assistance to all our customers 2. At no time will PrimeFiight employees handle or transport infants or small children. 

### If assistance with infants or small children is requested, politely explain that handling small children is against company policy and offer to help in another way, possibly 

### with the customer's baggage or other items the passenger is carrying. Try to help them with their belongings so they can concentrate on canying their children safely. Never assist or allow passengers to carry occupied strollers up or down escalators or stairs. Please direct them to the nearest elevator. (effective 7/15/03)

PrlmeAightAviation, Wheelchair Training Manual 

### 3 Oass #420, #421, #521 and #820 04/2009 NOTE: All training minimums must exceed the standards outlined by PrlmeRight Aviation dient, air operator. Proprietary Information: For use by PrimeRightAviation Personnel only

.. Unauthorized dissemination ofthis doaJment orinformation contained herein isprohibited.

# WHEELCHAIR TRAINING REQUIREMENTS

PrimeRightAviation, Wheelchair Training Manual 

### 4 Oass #420, #421, #521 and #820 04/2009 NOTE: All training minimums must exceed the standards outlined by PrimeRight Aviation dient, air operator. Proprietary Information: For use by PrimeAightAviation Personnel only

.. Unauthorized dissemination oftllis document orinformation contained herein isprohibited

## TRAINING REQUIREMENTS
1. 

### All PrimeFiight Aviation Wheelchair Operators must have Customer Service Training. 2. All**Primefli~ht** 

### Aviation Wheelchair Operators must receive initial classroom training at least 2-4 hours in customer service, sensitivity awareness with regards to disabled passengers, safety, Hazcom and wheelchair assistant operations guide. 3. All PrimeFiight Aviation Wheelchair Operators must receive at least 4-8 hours of On-the-lob (OJT} training with a. qualified operator or instructor. 4. Any Primeflight Aviation employee who may be asked to handle wheelchairs (i.e. Skycaps) must be trained as thoroughly as those employees whose sole job is wheelchair operation. 5. All PrimeFiight Aviation Wheelchair Operators are required 

## to receive recurrent training annually.
NOTE: Initial and recurrent training minimum time required may be based on the contract requirements, or by our client air operator.

PrimeF!ightAviation, Wheelchair Training Manual 

### 5 aass #4ZO, #421, #521 and #820 04/2009 NOTE: All training minimums must exceed the standards outlined by PrimeRight Aviation dlenC air operator. Proprietary Information; For use by PrimeF!ightAviation Personnel only .• Unauthorized dissemination oftills documentor information contained herein is prohibited

## CUSTOMER SERVICE TRAINING CLASS# 420

PrimeFiightAviation Wheelchair Training Manual 

### 6 Oass #420, #421, #521 and #820 04/2009 NOTE: Nl training minimums must exceed the standards outlined by PrlmeRight AVIation dienC air operator. Proprietary Jnfonnatlon: For use by PnineF!IghtAvtation Personnel only .• Unauthorizeddissemination ofthis dorument or lnfannatlon contained herein Is prohibited.

## OUTSTANDING CUSTOMER SERVICE Definition Outstanding customer service is showing the customer that you are concerned about them as an individual. That concern is displayed by providing a professional and efficient service and giving each customer friendly, personalized attention. Our relationship with the airlines is special because we represent the airlines to 

### their customers. Most passengers think that the Wheelchair Assistants work directly for the airlines. We have to exceed the airlines' standards for providing customer service to the airlines customers. Customer service is very important to the airlines because passengers choose an airline that they "like". The airlines expect 

### Primeflight Aviation to do everything possible to encourage customers to "like" the airlines. So our relationship with passengers, and people who are meeting and sending off passengers, is extremely important to 

### Primeflight Aviation because these people are valued customers of the airlines. Airlines are dedicated to providing quality customer service to every passenger. Airlines sell more than just transportation: The package is a complete package. 

### Who are Our Customers There are many other people who are customers: people who work for the airport, other contractors and even other 

### Primeflight Aviation employees. All these people deserve outstanding customer service. Giving outstanding customer service to this group of people has many benefits. First, 

### it promotes teamwork among the people who work at the airport. Second, the other customers who see a high level of cooperation between people who work at the airport get a good feeling about safety and security of the airport. And, having an atmosphere of teamwork and cooperation makes the work environment better for the Wheelchair Assistants. 

### Ease Customers' Emotions Many times, our customers have higher levels of emotions than normal. This may be caused by many things: they are unfamiliar with the airport1 

### they have a fear of flying, they are tense from their job, they may 

### be running late or they may be nervous about meeting someone. When we provide outstanding customer service, we help calm the customers' intense emotions.


### Help Customers Understand the Process Another key part of outstanding customer service is communicating with customers about what we want them to do, what we have to do and why we have to take some actions. This communication is important to the customers because they may view our actions as being an invasion of their privacy. Also, because most people have a fear of the unknown, customers will feel more comfortable with the process when we clearly explain the procedure to them beforehand.

PrimeAightAviaffon, Wheek:f1air Training Manual 

### 7 Gass #420, #421, #521 and#820 04/2009 NOTE: All training minimums must exceed the sfEndards outlined by PrimeFiight Aviation dient air operator. Proprietary Infonnation: For use byPrimeRightAviation Personnel only •. Unauthorizeddissemination ofthis document or Information contoined herein Isprohibited.

### Make Customers' Experience at the Airport Pleasant Our efficiency and outstanding treatment of the customers help ensure the customers have a pleasant experience at the airport. This is important to the image of the air travel industry. When we provide the customers with a pleasant experience they will 

### continue 

### to choose flying as their favorite way 

### to travel. 

### Why 

### is it important to Primeflight Aviation Team M.embf!rs Providing outstanding customer service benefits PrimeFiight Aviation. This section points out some of the benefits. 

### Better Work Environment When the entire PrimeFiight Aviation team gives outstanding customer service, it makes the work environment better. 

### lob Security The better service PrimeFiight Aviation provides to all our customers, the better opportunity PrimeFiight Aviation has to future contract opportunities
- if successful. The more opportunitie.s for PrimeFiight Aviation creates more opportunities for promotion and relocation. 

### lob Satisfaction Being part of a successful team and knowing that you personally contribute 

### to that success gives a person a feeling of satisfaction. Interacting with customers in a friendly, calm environment is more satisfying than a hostile, tense environment. Also, knowing that you help make a customer's experience better gives a feeling of personal achievement.

PrimeRightAviationr Wheelchair Training Manual 

### 8 

### aass #420, #421, #521 and #820 04/2009 NOTE: All training minimums must exceed the standards outlined by PrimeFiight Awation dient, air operator. Proprietary Information: For use by PrfmeRightAviation Personnel only

.. Unauthorized disseminalion ofthis dOOJment orinformation contained herein isprohibited.

### Characteristics of Outstanding Customer Service Primeflight Aviation recognizes six broad categories of characteristics that are key to providing outstanding customer service. Listing these characteristics helps us discuss, teach and evaluate customer service. The following sections introduce· the characteristics of outstanding customer service. 

### Professiona Iism Professionalism is the basis of our image as a high quality service org_anization. Displaying professionalism in our appearance and behavior helps the customers realize that we do an excellent job of keeping the flying environment safe. Additionally, our customers expect us to behave professionally. The most important aspects of professionalism are appearance

. and job knowledge.


### • Appearance Appearance is the first thing a customer sees. Every customer, either consciously or unconsciously, forms an initial opinion that's based on the appearance of the airport. The work area should be neat and orderly. Each employee must comply with the uniform and personal appearance and grooming standards. Professional appearance reinforces the customer's opinion that we are knowledgeable and effective. 

### So displaying professional appearance is the 

### first step in achieving the goal of providing outstanding customer service. Professional appearance also includes the conduct displayed by employees when they are away from their work area, such as on their way to and from breaks. 

### As Primeflight Aviation team members, we must present dignified coAduct at all times.



### • lob Knowledge Job knowledge is a part of customer service because to be a professional, a person has to have specific expertise. The expertise that Primeflight Aviation team members have is in aviation services. They must understand the responsibilities and authorities of each person in the airport. And Primeflight Aviation team members must know their equipment capabilities and limitations. Once you have superior job knowledge, you can use that knowledge 

### to give outstanding customer service. Your knowledge will let you help the customers get through the airport more effectively and efficiently. When you have the opportunity to display your job knowledge to your customers in a subtle way, the customer's perception that we are knowledgeable and effective is reinforced. 

### Efficiency Providing efficiency in our operations is a large part of the Primeflight commitment to outstanding customer service. Our customers want to see that we are working to get them through the airport as quickly as possible
- safely. The efficient operations of the service depend on providing guidance to the customers and being patient with the customers.

PrimeFJightAviation, Wheelchair Training Manual 

### g Class #42Dr #421, #521 and #820 04/2009 NOTE: All training minimums must. exceed the standards outlined by PrimeRight Aviatlon client, air operator. Propn"el:iJry Information: For use by PrimeFllghtAviation Personnel only .• Unauthorized dissemination ofthis documentor information conl:iJined herein isprohibited.i i

# i**~** • Providing Guidance Providing guidance to the customers means actively working with them to achieve the goals of successfully transporting the customer. Providing guidance to customers causes several good things to happen. First, the person you guide will understand what you want them to do. This immediately helps them get through the process more efficiently. Second, the people who are in the vicinity will see you working with the customer. This is good because they appreciate your active work 

### to ensure their safe transport. And third, the customers remember what to do the next time they come through the service. The customers are actually trained to do what we expect of them. Actively guiding the customers improves the efficiency of transport right now and continues to enhance customer service in the future.



### • Patience Patience 

### with your customers' means that you treat your last customer of the day just as well as you treated your first customer. You have to remember that some of the customers are unfamiliar with the service. This may be their 

### first time at the airport. Some customers, despite your efforts to keep the atmosphere friendly, may become hostile or uncooperative. Patience with all customers reduces the possibility of an adverse relationship developing between the team members and the customers. Displaying patience to each customer shows them that you are concerned about them as an individual. 

### Empathy Empathy means understanding your customers' situations and feelings. Having empathy helps us to provide outstanding customer service because putting ourselves in the place of the customer gives us an idea of what they need and expect. For example, if you can tell that a ·customer is in a bad mood, you should realize that the customer will appreciate when you take a low key approach to serving them. In order to understand the customers' situations and feelings, you need to consider some information that is common to many customers. The next three paragraphs give background about many customers' feelings toward their airport visit. Many people have stronger emotions than normal when they get to the airport, even if they visit the airport quite regularly. This may be because they are nervous about flying, nervous about a loved one flying or nervous about meeting someone. They may be nervous just because the airport is unfamiliar to them. · Since 9/11 customers understand the need for security and they want to feel safe and

. secure. However, some customers feel that the security process is not for them since they are not a threat to security. Customers agree to go through the security process with the expectation that we will keep any other customers from threatening their safety. Most people are used to being able to go anywhere they want without being questioned. Your customers have a specific purpose for being at the airport. The customers want to get 

### to where they are headed. They do not want to wait in line or go through unnecessary processes. PrimeRightAviation, Wheelchair Training Manual 

### 10 aass #420, #421, #521 and#820 04/2009 NQTE: All training minimums must exceed the standards outlined by PrimeF!ight Aviation**dien~** air operator. Proprietary Information: For use by PrimeRightAviation Personnel only •. Unauthorized dissemination ofthis document orinformation contained herein isprohibited.

### Once you understand the general feelings customers have, you can use your sense of perception to understand each customer's needs. Then a good way to show the customer that you have empathy is to involve them in the service.



### • Penoeptiveness A wheelchair attendant with a keen sense of perception has the ability to quickly recognize a customer's situation and feelings. Looking a person in the eye Is the first step in reading them. A customer's facial expressions tell a lot about them. Perceiving the customer's situation lets you empathize with them, which in turn allows you to provide outstanding customer service.



### • Involve Customers in 

### the Process 

### Involving the customers means you talk to them about the service. People are uncomfortable with the unknown. And people like to know why they are asked to do something. You can help the customers feel more comfortable by familiarizing them with the service and giving brief explanations why actions are required- and what steps you 

### will take to assist them to their travel destination. Involving the customers in the service shows that you understand their feelings. 

### Tactful Communication 

### Tactful communication is a major factor in the level of service provided to the customer, Tactful communication is so important because that is how we convey the other characteristics of outstanding customer service. The overall message we send to the customer must tell them indirectly that we are giving them outstanding custCilmer service. Your message to the customer is sent in a variety of ways through spoken words and body language.



### • Delivery The words you choose and the way you speak those words contribute to tactful communication. Carefully selecting the words of your message sets the stage for creating a cooperative situation. Use softening statements in your conversation with the customers. The volume and tone of your voice support the sincerity of the words you choose.

• Body 

### Language Body language is a secondary but very important aspect of your communication with customers. Eye contact, facial expression, posture and hand motions send messages that either reinforce or contradict your spoken words. Courteousness/ Friendliness 

### Courtesy is important to customer service because it brings friendly, personalized attention to the process. Customers expect to be treated in a friendly manner. And when we go far beyond their expectations, the customers recognize and appreciate the treatment as outstanding customer service. The best way to display courtesy to your customers is Pr/meRightAviation, Wheelchair Training Manual 

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### through respect, friendliness and helpfulness. Friendliness is shown by using words like "please" and "thank you." You can also be friendly by initiating a short conversation with your customers. PrimeFiight Aviation team members friendliness helps keep a feeling of teamwork between the customers and us.

• Respect 

### Respect is shown by using words like "sir" and "ma'am." Showing a sense of purpose in your actions also displays respect to your customers. Involving the custo!llers in the service shows respect. Before performing actions like making a sharp turn or going down a incline, explain exactly what you are going to do and why. Then ask the customer for their permission to proceed.



### • Helpfulness Helpfulness means doing more than simply transporting customers. Being helpful is shown by assisting customers with their personal belongings. Also, helpfulness includes providing instructions and directions to customers, and answering questions they may ask. Customers notice helpfulness offered by PrimeFiight Aviation team members. 

### Attentiveness 

## I Action Oriented Attentiveness means PrimeFiight Aviation team members have the sophistication to recognize the kind of service a customer requires. We have to realize that each customer has different needs and then fill those needs. When we are attentive to the

### n~s of the customers, the service runs efficiently and the customers experience the individual attention they expect. The important ingredients of attentiveness are flexibility, concentration and being action oriented. Being action oriented involves recognizing a potential problem and taking action to avoid that problem. Knowing the rules and regulations and relying on your experience, you can provide guidance to help customers get through the airport area quickly.



### • Flexibility Flexibility means being ready to take action based on what the customer does. A customer may request an extraordinary procedure or ask for special help. Primeflight Aviation team members must listen closely to their customers to figure out what they need. Being flexible to the needs of your customer is important to giving individual attention.



### • Concentration Concentration means that we keep contact with the customer from the time we greet them as they arrive until we transport them to their destination. We keep contact with the customers by maintaining eye contact and speaking with them during their journey. When we concentrate on each individual, they feel good about the service they received and confident in the level of service and safety we provide.

PrlmeFI!ghtAviation Wheelchair Training Manual 

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### HOW DO I Provide Outstanding Customer Service? Customers with Disabilities Customers with disabilities are special because they often have different needs than other customers. You may have a customer in a wheelchair, hearing or sight impaired. We cannot give one simple rule for giving outstanding customer service to people with disabilities. There are too many situations that can come up. However, we can give some suggestions to help you figure out how to give outstanding customer service on an individual basis to each customer with disabilities. The next course will cover this subject in detail.



### Professionalism • Remember that each customer is an individual.

• Remember that each customer has individual needs.

• Talk to the customer instead of speaking to someone else who may be

with the customer.

• Ask what the customer needs.

Professionalism is displayed by maintaining an official looking appearance and personality. Additionally, having superior job knowledge allows you to show your professionalism. 

# vAppearance Uniform • Wear your uniform with pride and with strict adherence to the PrimeFiight Uniform Standard. Personal Grooming • Fully comply with the PrimeFiight Personal Appearance Standard. Conduct at airport • Remember you represent PrimeFiight Aviation and our dient at anytime

you are wearing your uniform. • Always behave in a dignified, low key manner. • Think of people as your customers even when you are away from the

work area. Example: Someone may ask you what time it is or for directions. Be friendly and help them out as best you can. If you are unable to answer the question, assist the customer to a source that can give them the correct answer. 

# vJob Knowledge Job Responsibilities • Know PrimeFiight Aviation and air carriers policies and procedures. • Know the responsibilities of each person in the airport.

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# f '



### Job Authority • Working together as a team, displays to customers that PrimeFiight**~viation** 

### team members are aware of their responsibilities.

• Know the authorities of each person in the airport. Equipment capabilities • Understand the safety and operational rules for all equipment.

• Know the limitations of all equipment. 

# vEfficiency Efficiency is displayed to customers by getting them through the airport as quickly as possible
-- safely. Your actions should be providing guidance to the customers. And you must have patience with every customer. Provide Guidance Verbally and non-verbally

Patience • Greet customers and get them ·started on the right track 

### during transport. Guide them verbally and with hand motions to what they need to do when they approach and proceed through the transport process. • Always thank customers and remind them to pick up their carry-on

items.

Remember you and customers have the same goal • Never put blame on a customer or make them feel that they did

something wrong. • Give every customer, from your first customer of the day to the last, the

same level of outstanding customer service. • Never argue with a customer, client or PrimeFiight employee. 

### vEmpathy Empathy is displayed to customers by showing them and telling them that you understand their feelings and situations. Look each customer in the eye 

### to get a sense of their mood. Involve the customers in the service by clearly explaining exactly what you are going to do, why you have to do it and verify that the customer consents to the actions. Perceptiveness Recognize the customer's feelings and situation • Make eye contact with each customer and look at their facial expression

to figure out their situation (sad, mad, in a hurry, confused, happy). • Tell the customer that you recognize their situati.on Involve Customers Talk to the customers about the service • Describe to the customer exactly what you are going to do. • Give short explanations why actions are required. PrimeF/ightAviabon, Wheelchair Training Manual 

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# I I**~** ·i 

# j 1 

# I

! • Get consent from the customer before you take action. Have customers assist as much as possible (if applicable) 

### • Try to avoid handling customers' belongings unless they ask for help or

you offer help and they accept. 

## VTactful Communications The message your customers receive depends on your ability to tactfully communicate. You communicate with your customers through spoken words**~nd** body language. Spoken Words Use softening statements in your conversations with customers • Offer a pleasant greeting

Example: ''Good Morning sir" "Hello Mam 1 how are you this afternoon?" • Immediately FOLLOW your Greeting with an offer of help

Example: "How may I help you? (Mani?) • Disarm and customer hostilities by agreeing with them.

Example: "I understand ma'am." "I can appreciate that.'' "I hear what you're saying." "I see your point." • Thank customers for going through the seating 

## I screening process.

Example: "Thank you for your cooperation." "Thank you. Have a nice day." "Thank you. Good Bye;" Carefully select your words • Avoid using the word "you" when giving instructions or explanations.

The word "you" often comes across as threatening or aggressive. • Avoid using the word "Can" when offering help or explanations. The

word "may" is far more congenial. • Use simple tenns instead of technical words orjargon. This helps the

customers understand the process better. • When in doubt, use fewer words rather than more words. Use a pleasant tone and volume • Speak to customers with respect and directness. Do not use a

commanding voice that makes customers feel like criminals or a patronizing voice that makes customers feel 5 years old. Body Language Use body language to communicate with customers • Our smile is our handshake. Give each customer a smile. The smile you

offer depends on the customer. • Make eye contact with every customer. • Use facial expressions to add believability to your communications. PrlmeRightAviation, Wheelchair Training Manual 

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### !i

• Use hand motions and gestures to help the customers understand what you want them 

### to do. · • Use a head nod or tilt to acknowledge a customer or add interest to

your communication. 

## ,t Courteousness 

## I Friendliness You display courteousness to customers by following the golden rule: treat others the way you would like to be treated. Choose friendly words or phrases • Use words like "please" and "thank you." Respect Use words that convey respect • Use words like "sir" and "ma'am." Show a sense of purpose in your actions • Address situations as the top priority Helpful Assist customers. with their personal belongings • Ifyou notice a person having trouble, offer to help. Answer questions the customers may ask • Give good directions when a customer asks where something is located. • Ifyou do not know the answer to a customer's question, direct them to

someone who can answer the question. 

## ,t Attentiveness 

## I Action oriented Attentiveness is displayed to customers by recognizing things we can do to help them get through the airport in the safest- quickest and easiest way. Once we recognize the customers needs, we must follow through to be sure we complete our work with the customer. Flexibility Be ready to take action based on what the customer does Usten closely to customers to figure out what they need • Be sensitive to questions that customers ask about the service. Concentration Keep contact with each customer • Every customer receives a "welcome" to the airport, guidance through

the airport, and a ''thank 

### youn for their cooperation. Look for unusual situations and take action to avoid problems • When a customer looks confused, give guidance to the customer. Use your knowledge of rules and regulations to guide customers through the service

PrimeRightAviation, Wheelchair Training Manual 

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.. Unauthorized dissemination ofthis document orinfonnation contEined herein Is prohibited.

### REVIEW HOW TO PROVIDE OUTSTANDING CUSTOMER SERVICE Be Professional 

### o Maintain a neat looking appearance and mature personality. Know your job and responsibilities. • Appearance o Wear your uniform cleaned and pressed.
o · Be in fuil uniform at all times. Pants, shirt, tie, hat and jacket. • Personal Grooming o Be showered and clean shaven at all times o Hair should be neatly styled and trimmed. • Conduct at the Airport o Remember you represent Primeflight Aviation and the airlines anytime you are wearing your uniform 

### o Always behave in a dignified and low key manner. Loud talking, cursing and horse play are not acceptable behaviors. 

### Customer Service • Always have a friendly smile when greeting a customer. • Always be courteous; go out of your way for the customer. • Inquire if the customer needs assistance to be seated 

### in a wheelchair-"Would you like

me to assist you?" If the answer is yes, proceed by extending a strang hand and let the customer communicate their needs to you. It is important to "ask" the customer and then "listen" for their response. It is important that the chair is locked and on a level surface. Adjust the footrest to the proper height. If the answer is "no", ask the customer ifthere is anything else that you could do for them. • Assist customers with flight numbers and gate departures by requesting to see

customer's ticket jacket.

· • Do not exaggerate your speech when communicating with a hearing impaired customer. Maintain eye contact, slow your speech somewhat, but speak normally. If you still have trouble communicating, write the information down on paper. • Speak directly to a person with a disability. If they are with somebody, avoid saying

things like, "tell her she needs 

### to

... " or "ask him if he would like

..." The proper way to communicate is to say "you can
..." or "would you like

..." • Solicitation of any 

### type, either verbally or displaying actions which can be interpreted

as such is absolutely forbidden and grounds for dismissal. In addition, "cruising" the terminal asking to assist customers with their baggage is also forbidden.

PrimeF/JghtAviaffon, Wheelchair Training Manual 

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# I

f



# SENSITIVITY TRAINING - AIR CARRIER ACCESS ACT ·Class# 421

PrimeFI!ghtAviation, Wheelchair Training Manual 

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## WHAT IS THE AMERICANS WITH DISABIUTIES ACT? (U.S. Equal Employment Opportunities Commission, U.S. Department of Justice, Civil Rights Division) Over 43 million Americans have one or more physical or mental disabilities and with that comes widespread discrimination/ which persists in such critical areas as employment, public accommodations/ education/ transportation and many other areas of public use. In 19901 the American Disabilities Act (ADA) was passed to abolish discrimination based on disability. The ADA was developed to provide clear/ consistent1 enforceable standards addressing discrimination against people with disabilities and ensure that our Federal Government plays a significant role in enforcing the standards established in this Act. It is our responsibility to uphold and enforce the rules and regulations the ADA mandates. Our nation's goals regarding individuals with disabilities are to ensure equality of opportunity/ full participation/ and economic self-sufficiency. NOTE: Reference Department ofLabor1 ADA Act Barriers to employment/ transportation/ public accommodations/ public services/ ·and telecommunications have imposed staggering economic and social costs on American society and have undermined our well-intentioned efforts to educate 1 rehabilitate, and employ individuals with· disabilities. By breaking down these barriers/ the Americans with Disabilities Act (ADA) will enable society to benefit from the skills and talents df individuals with disabilities 1 will allow us all to gain from their increased purchasing power

and ability to use it1 and will lead to fuller/ more productive lives for all Americans. The Americans with Disabilities Act gives civil rights protections to individuals with disabilities similar to those provided to individuals on the basis of 

### race 1 color1 

### sex1 national origin 1 

### age 1 and religion. 

### It guarantees equal opportunity for individuals with disabilities in public accommodations1 employment/ transportation/ State and local government services/ and telecommunications. Falr1 swift1 and effective enforcement of this landmark civil rights legislation is a high priority ofthe Federal Government. For 

### answers to additional questions, call 

### the ADA 

### Information Line 

### • 800-514-0301 (voice) 

### • 800-514-0383 

### (TIY)

PrfmeAightAviation, Wheelchair Training Manual · 

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.. Unauthorized dlssl!mlnation ofthis document orinformation contained herein isprohibited.

# I

,, il

# ~

# ~ 

# I
J

# ~ ., 'I**~** 

# I
I 

## AIR CARRIER ACCESS ACT In 

### 1986, Congress passed the Air Carrier Access Act, requ1nng the Department of Transportation (DOD to develop new regulations so that persons with disabilities would not be discriminated against. The latest revisions to the ACAA go into affect in May 2009. DOT Part 

### 382 regulations, referred to as the Air Carrier Access Act, clearly explains the responsibilities of the traveler, the air carriers, the airport operators, and the contractors (PrimeFiight Aviation), who collectively make up the system which moves millions of passengers
. The Air Carrier Access Act is designed to minimize the special needs that travelers 

### with disabilities face as they negotiate their way through the nation's air travel system from origin to destination. This is met by: • By recognizing that physical barriers encountered by customers with disabilities can

frequently be overcome by employment simple changes. • By adopting the principle that many difficulties confronting customers with hearing or

vision impairments will be relieved if they are provided access to the same information that is available to all other passengers. • Through training of all employees who come in contact with persons with disabilities,

to understand their needs and how they can be accommodated quickly, safely, and with dignity. NOTE: See 

### 14 CFR Part 

### 382 for more information 

### (382.61 Training- in Appendix)


## DEFINITION OF DISABILITY Individuals with a disability
- means any individual who has a physical or mental. impairment that, on a permanent or temporary basis, substantiality limits one or more major life activities, has a record of such impairment, or is regarded as having such an impairment. As 

### used in this definition, the phrase: • Physical or mental impairment means: 

### o Any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more of the following body systems: neurological, musculoskeletal, special sense organs, respiratory including speech organs, cardiovascular, reproductive, digestive, genitourinary, hemic, lymphatic, skin, and endocrine; or o 

### Any mental or psycho1ogical disorder, such as mental retardation, organic brain syndrome, emotional or mental illness, and specific learning disabilities. The term physical or mental impairment includes, but not limited to, such diseases as orthopedic, visual, speech, and hearing impairment; cerebral palsy, epilepsy, muscular dystrophy, multiple sclerosis, cancer, heart disease, diabetes, mental retardation, emotional illness, drug addiction, and alcoholism. Major life activities mean functions such as caring for one's self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, and working. PnmeRightAviation, Wheelchair Tratning Manual 

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# * ACAA DON'Ts

- Require a "Fee" or a Tip for Services. Leave a customer in an immobile position more than 30 minutes.

- Deny services offered all other customers.

- Take away any customer's mobility/disability assistive device.

- Treat the Customer different than others, or as a burden.

- Force or Impose Service on someone who does not want or need it (i.e. making a deafor blind individual ride in a wheelchair).

- "Abandon" a customer until you are assured their companion or inbound party Is present and ready to assist onward travel (Ground, Rai1 or Air).

- Never distract a disabled individual's Service**Animal~** 

### they are working animals and NOT pets.

- Forget who the Carrier's Complaints Resolution Officer is (CRO).

- Allow a Disabled individual to bypass·security screening. 

# * ACAADOs In most contract locations, our assistance service STARTS at the Departures Area Curbside and only ENDS at the Arrivals Area curbside or Parking Garage.

·- When assisting an individual with a mobility challenge, at their request, allow for stops along the route at: · 

# * Accessible Restrooms (Note: we do not assist the customer with specific re.S,troom. functions) 

# * Fast Food locations (Note: Customers may elect to go to a ''sit down" restaurant1 

### but they must 

### be advised they will need to re-request assistance through the restaurant or other means to continue their assistance through the airport.) 

### Know where the Assist animal "relief area" is at your airport; and upon request, take or guide the customer with the animal to that**lo~tion.** 

### Upon arrival at a departure gate, advise the Airline Representative of the customer's name, location, and disability

### type {i.e. Deaf, Blind, Immobile) Provide written Flight information (delays, gate changes) to Deaf Customers Provide verbal Flight information (delays, gate changes) to Blind Customers 

# * EXIT ROW RESTRICTIONS in the ACAA

·- In order to qualify to sit in an AIRCRAFT EMERGENCY EXIT ROW SEAT the customer must: 

# * Be 

### Over Age 15 

# * Be able to READ, UNDERSTAND AND SPEAK ENGUSH 

# * Be able to lift 

### up 

### to 50 lbs. 

# * Be willing and able to assist in the event ofan emergency/evacuation 

# * Acknowledge and follow crew instructions

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### The Ten Commandments of Communicating with People 

### with Disabilities 

### I. Speak directly rather than through a companion or sigh language Interpreter who may be present II. Offer to shake hands when introduced. People with limited hand use or an artificial limb can usually shake hands and offering the left hand is an acceptable greeting. III. Always identify yourself and others who may be with you when meetJng someone with a visual disability. When conversing in a group, remember to identify the person to whom you are speaking. 

### o When dining with a friend who has a visual disability, ask if you can describe what is on his or her plate. IV. If you offer**assistance~** wait until the offer is accepted. Then listen or ask for instructions. V. Treat Adults as adults. Address people with disabilities by their first names only when extending that same familiarity to all others. Never patronize people in wheelchairs by patting them on the head or shoulder. VI. Do not lean against or hang on someone's wheelchair. Bear in mind that people with disabilities treat their chairs as extensions of their bodies. 

### o And so do people with guide dogs and help dogs. Never distract a work animal from their job without the owner's permission. VII. Listen attentively when talking with people who have difficulty speaking and wait for them to finish. 

### If necessary, ask short questions that require short .answers, or a nod of the head. Never pretend to understand: instead repeat what you have understood and allow the person to respond. VIII. Place yourself at eye level when speaking with someone in a wheelchair or on crutches. IX. Tap a person who has a hearing disability on the shoulder or wave your hand to get his or her attention. Look directly at the person and speak clearly, slowly, and expressively to establish if the person can read your lips. Ifso, try to face the light source and keep hands, radios, etc. away from your mouth when speaking. o 

### If a person is wearing a hearing aid, don't assume that they have the ability to discriminate your speaking voice. o Never shout at a person. Just speak in a normal tone of voice. X. Relax. Don't be embarrassed 

### if you happen to use common expressions such as "See you later" or "Did you hear about this?" that seems to relate to a person's disability.

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### COMMON SENSE AND BEING SENSITIVE The sensitivity training·deals specifically with the courtesy and treatment of the physically challenged. Common sense and being sensitive to others are key in showing any individual respect. This is especially important when encountering disabled customers. It is important for you to understand the proper way to approach, communicate and resolve any problems or questions regarding the physically challenged. On the previous page, were "The Ten Commandments Of Communicating with People With Disabilities". This list touches on important issues that have a direct affect on the way you communicate and conduct yourself while dealing with the physically challenged. After reviewing this list, your trainer will ask you questions and set up scenarios for you to practice. 

## Questions 

## for Discussion
1. Why is it important to ask before you help a disabled passenger?

2. Why is it important to Hsten carefully when assisting a disabled passenger?

3. If you approached a passenger who was having difficulty walking, what would you do?

4. How would you assist a blind passenger with a guide dog?

5. How would you assist a paraplegic in their own wheelchair?

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## Interactive Instructions: Split the training group into pairs. One person will act as the transporter, while the other person acts as the disabled individual. Put yourself into the "shoes" of each character. Switch roles when the scenario is finished. 

### Scenario 1 

### A passenger in a wheelchair approaches you and asks for your assistance. The passenger is both excited and confused. The passenger explains he has never flown before and he is baffled as to what services the airport provides. How should you handle the request? NOTES:

____________________________________________________ _



### Scenario 2 

### A passenger calls out to you for assistance. They need to 

### be transferred from a lobby seat to a wheelchair and then to their gate. The passenger needs assistance putting their wheelchair together. How should you handle this request? NOTES:

____________________________________________________ _



### Scenario 3 The wheelchair assistant is walking down the concourse and spots a mentally disabled person wandering around confused and disoriented. You approach them and ask them if they need assistance. They say yes, but cannot speak clearly. How would you handle this situation? NOTES:

__________________________________________________ __

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.. Unauthotized dissemination of this document orJnfotmatfon contained herein Isprohibited.After completing the interactive training scenarios, the group should review their findings to share the different ways situations can be handled and to ensure that they will achieve exceptional customer service. Some common sense and sensitivity tips: • Speak directly to**th~** person - not their companion • Ifyou have a question
- ask
- in a no1111al tone of voice • Always tell your customer what you are doing and how
- to ensure they are aware of

where you are going and how you are going 

### to get them through (sharp tums1 narrow doors, steep ramps) · • Treat braces and artificial limbs as respectfully as you would an actual part of the

body. Never take canes, crutches or walkers from a customer unless asked. • Be conscious of the customers' needs when they are using a service animal
- ask the

customer to what is best for their service animal, and know where the service animal "relief area" is at your airport.


### SUMMARY Customer service training is nothing more than reminding you of what is expected of you in appearance, demeanor, and job personality. The more you care about yourself in how you are perceived, the better you are perceived. PrimeFiight Aviation is asking that you care about your reputation 1 about the reputation of the company, and the reputation of the client while you are in uniform. We want you to respect the job, the company and our client enough to protect them. You protect them by treating each customer that you come in contact with as the customer that wlll make or break your contract, because they truly are.

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## i 

# l

WHEELCHAIR SAFETY Transferring and Transporting Customers CLASS #521

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## Know your equipment: Standard Wheelchair Key Components: • Brakes • Leg Rests • Main Wheels • casters

Typical Aisle Chair Key Components: • Hand Brake Release •Top Lifting Handles • Base Lifting Handles • Safety Belts (2-3 kinds!) • Leg Rest • Head Rest • Main Wheels • Casters

Pre-Use Chair Check • When in doubt, check it out! • Some Carriers may have a checklist 

## • RED TAGGING (Tag Out)
NQ.:QSAR DO'NOT 

## OP.EJtATE

PrimeF!ightAviation, Wheelchair Training Man112! 

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## i I 

### Seating Customers
When assisting a customer- these are the basic rules for transferring a customer 

### to or from a wheelchair:

• A Passenger though NEVER sit in a chair before it has been checked for safe

operations. Check the casters, brakes, footrests, wheels and handles to make sure they are operating properly. Check for loosened bolts or connections. If you feel a chair is unsafe, RED TAG it and contact your Supervisor.

• Before assisting the customer into or out of the wheelchair/ make sure that the brakes

on both wheels are set and the footrests are in the "up'1 position.

• Position the wheelchair as close as possible to the customer keeping all four wheels on

a solid surface at all times.

• Explain your intentions 

### to the customer regarding how you plan to assist in their

transfer and ask for any information that you may need to know about their unique physical needs such as supporting their knees in a bent position during the transfer/ areas of soreness or other spedal body positioning. You will need assistance in transferring a passenger whose legs and/or hips require support. Inquire whether customer is willing and has sufficient upper body strength to assist in the transfer. If the answer to both questions is yes, they should use their existing seat and the locked wheelchair as support for their hands while shifting. their body weight into the wheelchair.

• Always. ask for help prior to transferring an adult customer with questionable upper

body strength. Failure to do so can result in back injuries 

### to the customer and/or assistant.

• Always talk about the transfer with the customer prior to making the 

### lift. Inform

him/her that you 

### will begin lifting after counting aloud 

### to three.

• When assisting a transfer by yourself, approach the customer from the front, straddle the passenger's knees/ place your arms under their arms 

### with your hands on their shoulder blades and 

### lift them as close as possible to your body. Use your legs to 

### lift, keeping your back as straight as possible with your rear end tucked in 

### to flatten the natural spinal curve.

• Making small, even steps on the balls of your feet/ pivot yourself and the customer until you can lower them into the wheelchair. (DO NOT lWISf YOUR BACK DURING TRANSFER. USE YOUR FEET TO GRADUAU.Y MAKE THE PIVOT) Maintain a firm, but gentle grip on the customer, making sure that they are sitting far enough back in the wheelchair so that it won't tip forward. You can ask the customer 

### to use one hand to feel for the arm rest to help guide them into the seat. PrimeRightAviation, Wheelchair Training Manual 

### 28 aass #420, #421, #521 and #820 04/2009 NOTE: All training minimums must exceed the standards outlined by PrimeA!ght Aviation dient, air operator. Propnetary Information: For IJSe by PrimeAightAviation Personnel only •. Unauthorfzeddissemination ofthis document orinfotmation contained herein isprohibited.• After lowering the customer into the chair, go behind the chair and look to make sure they are all the way back in the seat. (this 

### will decrease the possibility of tipping forward during transit)

• Lower the foot rests and place the customer's feet on them securely. (inform the customer of your intentions to toudl their feet)

• Make sure the customer's arms and legs are in a safe position before transporting.

• Always check to see that the customer is comfortable prior to transferring or transporting. 

## LIFTING TIPS • Safe lifting means protecting your back while you 

### lift.

• Before you lift another person, think about the lift. Can you 

### lift the customer by yourself? Do you need help?

• When you 

### lift a customer, be sure to bend at your knees, hug the load close to your body, and raise yourself up with the strong muscles in your thighs. o Place your knees on either side of the customer. o Stand with your feet shoulder width apart and knees bent. o To 

### lift the customer place your hands under the arms with your hands under the customer's shoulder blades.

• Remember never to twist while lifting; instead, move one foot at a time in the direction you want to go and then tum with your leg muscles.

• During the transfer, make sure you have open communication with the customer. Set a countdown for signaling the start of transfer.

PrimeRightAviation, Wheelchair Training Manual 

### 29 

### aass #420, #421, #521 and #820 04/2009 NOTE: All training minimums must exceed the standards outlined by PrimeRight Aviation dient, air operator. Proprietary Information: For use by PrimeRightAv/atton Personnel only .• Unauthorizeddissemination ofthis document orinformation contained herein is prohibited.

### TRANSPORTING CUSTOMERS:

• Try to choose routes that have the smallest inclines possible, and 

### NEVER use stairs or escalators.

• When entering elevators/ back the chair over the threshold both going in and out. This is easier and safer than going forward. Explain to the customer what you are doing so they do not become alarmed.

• Never allow a wheelchair to descend the jetway unassisted.

• When crossing over steep inclines (i.e. the Jetway); ALWAYS back 

### the wheelchair down an Incline to 

### avoid the risk of a fall. NEVER push wheelchairs FORWARD 

### down an incline! Sudden changes of the floor angle or contact with jetway expansion joints can cause the front casters 

### to catch, causing the chair 

### to tip forward and eject the customer. KNOW IF YOU ARE WORKING A "REGIONAL11 JET.

• When backing customers down the jetway1 grip the wheelchair handles firmly to be able to decrease the wheelchair/s momentum and maintain control.

• Always keep the customer informed of what you are doing while negotiating sharp turns, narrow doors and steep ramps.

• To prevent tipping 1 do not allow the customer to lean forward further than the front of the arm rests during transportation.

• During transportation, continuously scan the floor for loose debris 1 holes or expansion joints that can easily cause the front casters to stop and result in the wheelchair tipping over forward.

• Periodically check the -customer 1S feet and wheelchair foot rests.



### • Never assist more than one wheelchair at a time.

• Never allow a rider to sit in the lap of a wheelchair occupant.



### • If you are not physically strong enough to assist a disabled customer**-STOP~** GET ADDITIONAL HELP. Failure to S0 1 or getting in a 

### HURRY can jeopardize the safety of the customer, yourself and possibly others!

PrimeFiightAviation, Wheelchair T!Clining Manual 

### 30 aass #420, #421, #521 and#820 04/2009 NOTE: All training minimums must exceed the standards outlined by PrimeAight Aviation**dfen~** air operator. Propdetary Information: For use by PrimeFI!ghtAviation Personnel only .• Unauthorized dissemination ofthis document orlnfo!T11atlon contained herein Isprohibited.

## TRANSFERRING IN AND OUT OF AISLE CHAIRS:

• Ask the customer about any specific requirements for transferring, such as support for the lower limbs, sensitivity or soreness prior to performing the transfer.

• When lifting a customer to/from aisle chairs, 

### always obtain assistance from an airline customer service agent or another Primeflight Aviation employee. Position one person standing behind the customer. They must place his/her arms beneath the customer's arms and around the chest. Ask the customer to cross his/her arms on the chest. Using an overhand grasp, gently, but securely grip the customer's foreanns. The second assistant, approaching from the front, places both allTls under and around the customer's thighs, just above the knees. Both assistants should lift simultaneously after a count of three from the assistant lifting the torso. Remember 

### to bend your knees prior to lifting.

• the attendant lifting the torso initiates the countdown. • Use more than two attendants when the customer is a large adult with questionable upper-body strength. • Lift with your legs, not your back. • Never transfer a customer to or from an aisle chair by yourself. Remember that persons in wheelchairs are as diverse as able-bodied persons. There are a variety of physical conditions that could necessitate the use of wheelchairs. In some circumstances, people in wheelchairs may resent the assumption that they need assistance. When a passenger comes into an airport in his/her own wheelchair and is obviously capable of transporting themselves under their own power, offer assistance with other tasks 

### first, such as checking, or transporting baggage, ticketing or direction to airport facilities. Never assume that people in wheelchairs require any more assistance that able-bodied persons. You may assume that a customer needs assistance 

### if he/she is in a wheelchair provided by the airlines/airport. Always attempt to make initial contact with the person in the wheelchair by looking directly tnto their eyes and cordially introducing yourself. 

### If the person is visually impaired, it may be necessary to communicate directly with their companion.

• Prior to movement of an occupied aisle chair, make sure the customer is securely strapped into the aisle chair to prevent them from falling or shifting their weight, which could cause the entire chair to tip over.

PrimeFfightAvtation, Wheelchair Training Manual 

### 31 Oass #420,. #421, #521 and #820 04/2009 NOTE: All training minimums must exceed the standards oot!lned by PrimeR/ght Aviation dient, air operator. Proprietary Jnfonnatlon: For use by PrimeFfightAviation Personnel only •• Unauthorized cKssemination ofthis document orinformation contained herein isprohibited.

## WHEELCHAIR ASSISTANTS OPERATION GUIDE CLASS #820

PrimeFiightAviation, Wheelchair Training Manual 

### 32 Oass #420, #421, #521 and #820 04/2009 NOTE: All training minimums must exceed the stiJndards ootlined by PrlmeAight AViation**dien~** air operator. Proprietary lnfotmation: For use by PrlmeAightAviation Personnel only., Unauthorized dissemination ofthis document orinformation contained herein Isprohibited

### WHEELCHAIR ASSISTANTS OPERATION GUIDE

This is the PrimeFiight Aviation Wheelchair Assistants Operations Guide. It contains the official methods and· procedures that apply to your overall responsibilities and performance as Wheelchair Assistants. The simplicity of the instructions as expressed in the following pages should be given your fullest attention at all times. We should always remember that physically challenged customers require the best service that you can give. 

### WHEELCHAIR ASSISTANTS CUSTOMER SERVICE SERVICE OBJECTIVE The purpose of your position with PrimeFiight Aviation is 

### to provide safe and comfortable quality assistance to customers who are physically challenged. 

### CUSTOMERS WHO ARE PHYSICALLY CHALLANGED Customers who are physically challenged are special because they often have different needs than other customers. The following techniques can be used 

### to help you deal with customers who are physically challenged:

• Remember that each customer is an individual

• Remember that each customer has individual needs

• Talk to the customer instead 

### ofspeaking to someone else who may 

### be with the customer.

• Ask the customer what they need.

The important detail to remember, when dealing with customers who are physically challenged, they are people just like. the rest of us. People who are physically challenged deserve that same respect and attentiveness that we give 

### to all our customers.

PrimeFiightAviation, Wheelchair Training Manual 

### 33 aass #420, #421, #521 and #820 04/:Z009 NOTE: All training minimums must exceed the standards outlined by PrfmeF/fght Aviation dient air operator. Proprietary Information: Foruse by PrfmeF/ightAviation Personnel only

.. Unauthorized dissemination ofthis document orinformation cvntained herein Is prohibited. ·

### KNOW YOUR SECURITY SCREENING

• NO FIREARMS, WEAPONS, PEPPER SPRAY, KNIVES, BATS, GOLF CLUBS, BOX KNIVES, TOY WEAPONS or SCISSORS

• 3-1-1 (carry-On) Liquids Rule o 3.4 Ounces per container Maximum o One 1-Quart Bag for all liquid containers (sealed) o 

### One Bag per customer o Exceptions exist for certain items (i.e. baby formula/Mother's Milk)

• Disabled Customer Screening Rules 

### o 

### An individual with a disability must undergo the same security screening as any other member of the traveling public. o 

### If an individual with a disability is able to pass through the security system without activating it, the person shall not be subject to special screening procedures. Security personnel are free to examine an assistive device that they believe is capable of concealing a weapon or other prohibited item. 

### If an individual with a disability is not able to pass through the system without activating it, the person 

### will be subject to further screening in the same manner as any other passenger activating the system. o Security screening personnel at some airports may employ a hand-held device that 

### will allow them to complete the screening without having to physically search the individual. If this method is still unable 

### to clear the individual and a physical search becomes necessary, then at the passenger's request, the search must 

### be done in private. o 

### If the passenger requests a private screening in a timely manner, the carrier must provide 

### it in time for the passenger to board the aircraft. Such private screenings will not be required, however, to a greater extent or for any different reason than for other passengers. However, they may take more time. o 

### Personal Oxygen Bottles are prohibited beyond the checkpoint. Check with the Carrier for specific Rules.

PrlmeA!ghtAviation, Wheelchair Training Manual 

### 34 

### aass #420, #421, #521 and #820 04/2009 NOTE: All training minimums must exceed the standards ouUined by PlimeFiight Aviation dient, air operator. Proprietary Information: For use by PrfmeFiightAviation Personnel only.. Unauthorized dissemination ofti1is document orinformation contained herein isptrihibitecf.

# j Proper Conduct
1. Wheelchair Assistants should always have a friendly face/smile in greeting the customer. 

### 2. Greet with the words "Good Morning"1 

### Good Afternoon" or Good Evening"/ whichever is appropriate. 3. Inquire if they need assistance to be seated in the wheelchair -"Would you like me to assist you?" If the answer is 

### yes 1 

### woceed by extending a strong hand and be guided by the customer's need. 

### It is important to ensure the chair is locked and on a level surface. If the answer is "no", stand behind the chalr1 

### holding the handles, after you have adjusted the foot rests. 

### 4. Always be courteous, go out of your way to make the customer feel comfortable. 

### 5. Inquire of the flight number and gate of departure by requesting to see the customer's ticket jacket, "May I please see your ticket jacket." Upon reviewing the ticket jacket, repeat the flight number and gate of destination to the customer1 

### thereby reconfirming this information. 

### 6. Be patient. 

### If a customer asks you the same question two or three times, answer politely each time. Avoid any tonality or body language that reveals annoyance on your part. 

### 7. Proceed to the destination being mindful of other people 1 

### uneven surfaces, ramps, closing elevator doors, etc. 

### 8. Soliciting tips in any manner, either verbally or displaying actions which can be interpreted as such, is 

### absolutely forbidden and grounds for dismissal. In addition "cruising" the terminal asking to assist customer with their baggage Is also forbidden. 

### 9. When in the arrivals area, remember to ensure the safety of your customer if you are retrieving bags from the carousel. 

### 10. When taking a customer to the arrivals area, the determination must be made if further assistance is required beyond this area. Discourage as much as possible, further assistance to another terminal or to the parking lot if there are other members of their party that may help them. Remember that there are many customers that require assistance and it is important to check-in with the dispatcher as soon as possible. Advise the customer as follows: "ma'am this is as far as I am permitted to take 

### you1 

### I have 

### to return to my station.'/ Obviously, good judgment is necessary as well as good customer service skills. 

### NEVER leave a physically or mentally challenged customer alone anywhere without being specifically assured of their continued weel-being. 

### 11. Delays and all unusual/unscheduled assignments while away from your base station must 

### be communicated 

### tb your dispatcher. 

### 12. Before returning to your station after assisting a customer, call the dispatcher 

### to see if there are additional requests in the area you are in. 

### 13. If there are not additional requests, return immediately 

### to the base station and await your next assignment. 

### 14. Follow all safety and lifting procedures.

PrimeRightAviation, Wheelchair Training Manual 

### 35 Oass #420, #421, #521 and #820 04/2009 NOTE: All training minimums must exceed the standards oulfined by PrlmeFIIght Aviation dient air Operator. Proprietary Information: For use by PrimeRightAviation Personnel only.. Unauthorized dissemination ofthis doaJment or Information cvntainet:J herein Is prohibited.

# ·----'.- '

PRIME FLlGHT HARASSMENT, DISCRIMINATION AND DIVERSITY 

## HARASSMENT AND DISCRIMINATION POLICY HARASSMENT AND DISCRIMINATION Primeflight is committed to providing a work environment that is not hostile, and free of discrimination and unlawful harassment. Actions, words, jokes, or comments based on on individual's. sex, race, ethnicity, age, sexual orientation, disability, religion, national origin or any other legally protected characteristic will NOT BE TOLERATED. As an example, racial discrimination (both overt and subtle) is a form of employee misconduct that is demeaning 

### to another person, undermines the integrity of the employment relationship, and is strictly prohibited. If an employee feels he or she is the subject of harassment, they must first advise the offending person that the behavior is unwanted. If this act would present a physical danger or undue suffering for the employee, then notification of management is required immediately. IF the supervisor is unavailable or the employee believes it would be inappropriate to contact that person, the employee should immediately contact the Human Resource Manager at 1-800-801- 5783 'or the Regional Vice President. Employees may make reports without fear of retaliation or reprisal. Any supervisor who becomes aware of possible unlawful harassment or discrimination should promptly advise the Human Resource Manager for your region who will investigate the matter in a timely and confidential manner. Anyone engaging in unlawful harassment or discrimination or creating a hostile work environment will be subject to disciplinary action, up to and induding termination of employment. Every complaint of harassment will be treated seriously, and each incident will be investigated immediately. ·All due effort will be made to maintain confidentiality and i:Jie dignity of all parties involved. 

### SEXUAL HARASSMENT Discrimination because ofsex or sexual harassment of any employee is strictly prohibited and · PrimeFiight Aviatibn WILL NOT TOLERATE such conduct. Sexual harassment is defined as unwanted sexual advances, or visual, verbal or physical conduct of a sexual nature. The definition includes many forms of offensive behavior, including but not limited to the following: Unwanted sexual advances Offering employment benefits in exchange for sexual favors Making or threatening reprisals after a negative response to sexual advances Visual conduct: leering, making sexual gestures, displaying of sexually suggestive objects or pictures, cartoons or posters

. Verbal sexual advancements of propositions

# .......



# . . .**r;;;;;;;;;;;~ht** PRIME FLIGHT HARASSMENT, DISCRIMINATION AND DIVERSITY ' IIVIAltfiN!iERWCU Verbal abuse of a sexual nature, graphic verbal commentaries about an individual's body, sexually degrading works used to describe an individual, suggestive or obscene letters, notes or invitations Physical conduct: touching, assault, impeding or blocking movements Unwelcome sexual advances, requests for sexual favors or other verbal or physical.conduct of a sexual nature constitutes harassment when: · Submission to such conduct is made either explicitly or implicitly, a term or condition of an individuals employment.

. Submission to or rejection of such conduct by an individual is used as the basis for an adverse employment declsion(s) affecting the individual. Such conduct has the purpose or effect of substantially interfering with an individual's work performance or creating an intimidating, hostile'or offensive work environment. No supervisor shall threaten or suggest that an employee's refusal to submit to sexual advances will adversely affect the employee's employment, wages, advancement, assigned duties, shifts or any other condition of employment. Other types of prohibited conduct by a supervisor, coworkers, clients or venders include sexual advances, proposltions 1 verbal abuse of a sexual nature, suggestive touching, suggestive gestures and comments, graphic verbal descriptions of an individual's body and the display in the work place of sexually suggestive objects or pictures. If an employee believes that he or she is being subjected to sexual harassment the employee should immediately notify his or her supervisor, the Regional Human Resource Manager at 1-800- 801-5783 and/or the Regional Vice President An individual investjgation will be undertaken and appropriate sanctions and cor(ective measure will be instituted if the employee's allegations warrant such action. Persons who commit acts of intimidation and harassment 

### will be disciplined according to the severity of 

# the case. Appropriate discipline may indude actions up to and including termination of employment. Employees are assured that this procedure has been established for their**ben~fit** and to allow them the freedom of expressing their feeling anc!jor complaints. No**eniploy~s** need fear he or she will be penalized for registering any such complaint. Employees may make reports without fear of retaliation or reprisal. PrimeFiight Aviation will not tolerate any form of sexual harassment and is committed to a prompt and impartial investigation while maintaining maximum feasible confidentiality in the resolution of any complaint. For more information, you may contact your regional Human Resource Manager at 1-800-801- 5783. By signing below, I acknowledge that I have received this policy and clearly understand that the company 

### will not tolerate any type of discrimination or harassment. 

### r.-**]{'_~** 

# lfl**-~**

# s DatePRIME FUGHT HARASSMENT, DISCRIMINATION AND DIVERSITY


## Diversity .,.., "In this Togethe(' Definition of Diversity di.ver.sity the condition of being different
We all come from different backgrounds, beliefs,**cultures~** races, creeds, ages, and experience. As a member ofthe PrimeFiight Aviation Team, we all have to take personal responsibility to ensure that everyone from our co-workers to our customers feel:

• Welcome • Mutual Respect We can also continue to build our relationships by working together as a TEAM to embrace diversity by ·
• Exploring and acknowledging differences • Keeping an open mind • Thinking before you speak • · Taking responsibility to change behavior- yours or someone else's Overall, we must continue valuing and promoting difference
- by trying to M.E.E.T. on common ground. M - Make 

### lime To Discuss 

### &.
- Explore And Acknowledge Difference !;_-Encourage Respect For Each Other T -Take Responsibility Please take a few minutes to answer the following questions. This "Quiz" will be reviewed in the upcoming Video entitled "In This Together". Please Circle your response. 1.



### 2. If you arrived at work in 

### a bad**~oOd,** do yOU

....? a. Try to avoid others 

## t?· Warn others to stay clear (C) Leave it at the door. When Offered a juicy bit of gossip at work, do you
.....

### ? a. Usten, but keep it to yourself b. Get it all and pass it on 

# (0 Refuse to hear it.

# ·----•,- f


# ·· ·rlmeF!ight PRJME FLIGHT HARASSMENT, DISCRIMINATION AND DNERSITY

.·.**·~!lii\Tfnfii1Utvu:tu;**
3.



### 4.

5.



### 6.



### 7. Do you do what you say you will do? 

### a. Eventually b. If it matters 

### @. Always If what I say offends you ...•• a. I'll wait until yodre not around b. 

### I'm just being real 

## @ 111 stop When it comes 

### to sexual 

### attraction at work

....? (if,) Look but don't touch 

## b. Look, if they »'ant you to

c. Don't look, don't touch Who**ev~** said, Live arid Let Uve

.... (,gJ was sincere but na'fve

b. had no strong beliefs t:. got it right Always using please and thank you at work is a. nice, but impractical b. annoying and fake 

## @ common courtesy 

### WATCH VIDEO

__.;_ "In It 

### Together' NOTES:-------------------------------------------------------PRlME FUGHT HARASSMENT, DISCRIMINATION AND DIVERSITY


## Acknowledgment of Receipt of Primeflight Aviation Harassment, Discrimination and Diversity Training

Employee's Si9nature Date

# EXHIBIT 

# C

### Name: 

# fF/ZfJIIJj{ 

# Oil(/**r~i** Date of Classroom Training:

____ 

## 6;:::;__-

# ~-..J.t...;}_-.,.9r.:.....;~ 3:::;..·

-""'

-'-'-'-'.

# ---~-----~ Trainer's

# Name=----~~~r.:::/;,. ..

# c:..:~:::.·..:...:..._-"/~c-·**~--~!:.::·** ::.4:_

# ~:;.:::::...:::...:....::...___

# ~ __ _


### Wheelchair Attendant Signature

PrimeFilght Aviation, Wheelchair Training Manual 

# :0 Jd 

# -o**~** Date

Class #420, #421, #521 and #820 40 2/2003 NOTE: All training minimums must exceed the standards outlined by PrlmeFiight Aviation dlerit, air operator. Proprietary Information: For use by PrimeFIIght Aviation Personnel only

.. Unauthorized dissemination of this document or Information contained herein is prohibited.

# EXHIBIT D'

..



### .**~.<··:t.'j~:.** 

### . .

.. ,... ··**:···::'~~,:~** 

### ·Prim.eflight Aviation Wheelchair Program Quiz 

### PRIMEfliGHI AVIATION WljJ;ELCHAIR SERVICES PBQGRAM 

### .QUIZ

,...... 

### Name**~-** 

### ;)..'lfer Date___i0**I~** 

## I 

# o**~(** 

### Location 

# f 11 L, 

### Score: 100_----'----



### Instructions; · Read questions carefully. 

### Provide the 

### best answer 

### foreach question. If you do not understand 

### a question; 

### ask your instructor.



# Jj_2. Which phrase from the list 

### below is not a main purpose 

### of the 

### Wheelchair Services Operations? 

### a. Each customer 

### is an Individual. 

### b. Talk to the customer not someone else 

### who may be 

### with the customer.
c. Provide advice to 

### the customer on which hotels to stay 

## at. Which 

### phrase from the list 

### below is 

### not a main purpose of the Wheelchair Services Operations?

a. Provide safe and comfortable quality assistance to the customer. b. Leave 

### the customer alone once arrived at destination.

c. Be sensitive to the customer's individual needs and delivering what is promised.

··· PrimeFlight Aviation, ·wheelchair Training Manual

Class #420, #421, #521, and #820 2/2003

### N~T~: All. training minimums must exceed the standards outlined by 

### PrimeFlight 

### A

v1atwn 

### Chent, air operator. · 1

## 3.



# il_4.


# Ls.

!3 6.



## f3 7. 

### To verify boarding information you need to:.
a, 

### Inquire ofthe flight 

### number 

### and gate departure 

## by requesting to see 

## the· customer's ticket jacket. b. 

### Ignore customer 

### and ask ticket agent 

### for information.

c.**Proc~ed** 

### through concourse without looking 

### at ticket, because 

### you know the airport. 

### Before 

### assisting the 

### customer into or out of 

### the wheelchair, make sure the brakes on both wheels are set and the footrests are in the uprightposition.

a. True b. False Try to use the shortest 

### possible route to the 

### destination, even 

### if 

### you 

### have to use stairs.

a. True b. False When crossing over steep inclines (i.e. the Jetway) 

### always back the customer 

### down the incline to avoid the risk of a 

### fall.

a. True 

### b. False You should always count 

### your tips when your 

## receive them to be sure you were properly rewarded for your services.


### a. True b. False

:PrimeFJight Aviation, 

### 'Nheelchair Training Manual Class #420, #421, #521, and #820 

### 2
2/2003 NOTE: All training minimums must exceed the standards outlined 

### by PrimeFlight Aviation Client, air 

### operator.
.I 

### I. 

## ,. ! 

# Ls.

10.



### 11. 

# fL_12. _ ·.· · ·Primeflight Aviation. Wheelchair Pro

### gram Quiz Moving a customer from the wheelchair to an aisle chair can 

## be very 

## strenuous on your 

## back. It 

## is important to use the proper lifting techniques when doing so.
a. Be sure to stabilize weight with your legs 

### and not your back. 

### b. Explain 

# to the customer exactly 

## what you will be doing.



### c. Place your arms under the customer's arms with your hands under the customers 

### shoulder blades. 

### d. All of the above. 

### Aisle transport is used 

### to assist customers 

### who cannot walk' at a

### !I and are unable to get on or off the aircraft 

### by themselves.


## a. True 

### b. False He1zardous Materials have 

### to 

# be checked at the ticket counter;·



## . a. True



### b. False 

### When transporting the passenger·from the baggage area 

## to the 

### outside, always use ramps to navigate over curbs.


### a. True b. False Safety of our passengers is our most 

### important responsibility.


## a. True 

### b. False PrimeFlight Aviation, Wheelchair Training Manual Class #420, #421, #521, and 

### #820 2/2003 NOTE: All 

### training minimums must exceed the standards outlined by 

### PrimeFlight Aviation Client;air operator.
. . 3

# EXHIBIT E

# l

'i 

### ,j il

# ~

# ~ j I**~,** I 

### Initial Training for Wheelchair Attendants Required On-The-Job T·raining (minimum 4-8 hours) Tour of the Airport fq.cilities (emergency exits) Review company policies and procedures Proper use of all required equipment (demonstrations) Shadow an experienced Wheelchair Assistant for a minimum of 

### 2-4 hours '

- -

### ~ 

### Supervised Observation by an experienced Wheelchair Assistant of the OJT trainee performing job function · $.-.Supervisor/Manager meets with the experienced Wheelchair Assistant and the Q.JT trainee
- to discuss training and to determine if prepared to work essential job functions (knowledge and skill level) Recurrent Training (every 6 months) 

### By signing below, the employee and the manager is acknowledging that the em lo ee did receive On-The:..Job trainin
- as outlined above. On-The-Job Training

### Comple~d on (date):

_

### _...__---=5'----'--~/."'-'Z_-_IJ-'--------­ 

# p /C /Jj/1{ 

### 0 tlt/J¥1

Date 

### Recurrent Training 

### (every 6 months - a minimum of 2-4**ho~rs)** 

### Recurrent Training should review all topics- from On-The-Job training -to include- review of the Customer Service Sensitivity training.
Date ofRecurrent Training=-------'--- Employee Signature Manager's Signature Date 

### of Recurrent Training:

_______ _ Employee Signature Manager's Signature Date 

### of Recurrent Training:

_______ _ Employee Signature · Manager's Signature
PrimeFIIght Aviatlon, Wheelchair Training Manual Class #420, #421, #521 and #820 41 2/2003 NOTE: All training minimums must exceed the standards outlined by PrtmeFIIght Aviation client, air operator.**~** Proprietary Information: For use by PrtmeFIIght Aviation Personnel only

.. Unauthorized dissemination of this document or information contained herein Is prohibited. ·

# EXHIBIT F1 i GROUND OPERATIONS TRAINING



### Type
Training Synopsis

Who Needs To Be Trained

Training Requirements
Training Deadline

Archive Information

Required Training Time

Effective April 6, 2005 r 

# Wheelchair and Assistive Devices Training 2005 Course Description

SWA Required

Wheelchair and Assistive Devices training material incorporates the following: 

## • Understanding the Customers' wheelchair or assistive device is an extension of the person 

## • Understanding the importance of communication to the Customer and Coworkers when handling the wheelchair or assistive device 

## • Completing a wheelchair inspection tag 

## • Handling the wheelchair or assistive device in a careful manner keeping the Customer in mind



## • Customer Service Agents 

## • Ops Agents 

# • Ramp Agents 

## • Customer Service Supervisors 

# • Ops Supervisors 

## • Ramp Supervisors 

## • Customer Service Managers 

# • Ramp & Ops Managers 

## • Assistant Station Managers 

## • Station Managers 

## • Southwest Airlines Skycaps 

## • Contract Skycaps 

# • Wheelchair Attendants

One-time only
Training must be completed by May 31, 2005.

Station: May 31, 2005 Ground Ops Website: June 30, 2005

One hour classroom training including time for discussion and Q&A

1 of2Course Information Folder Course Description Materials 

## • • Sign Off Sheet 

## • Wheelchair and Assistive Devices Instructor Guide 

## • Wheelchair Inspection Tag PowerPoint 

## • Video- "It Can Make a Difference"
Signoff Requirements All Employees must sign off on the Wheelchair and Assistive Devices signoff sheet. Completed signoff sheets will be retained in the master CIF.

Web Location Ground Ops Home Page/All Classifications/Southwest Required Training/Wheelchair and Assistive Devices Training 2005
Subject Content Questions 

## • Heather Tolmachoff SON 792-2428 

## • Amy Shipley SON 792-5644 

## • Joni Sauer-Folger SON 792-7889 

## • Ron Katzenberg SON 792-2429

Documentation And Non applicable Compliance Questions Training Information Training material should be discussed in a classroom setting, with ample time allowed for questions. Any of the following individuals can provide the required training sessions: 

## • Station Training Supervisor 

## • Customer Service Supervisor 

## • Ops Supervisor 

## • Ramp Supervisor 

## • Customer Service Station Trainer 

## • Ops Station Trainer 

## • Ramp Station Trainer 

## • Station Manager Wheelchair and Assistive Devices training will be incorporated into Initial Training beginning June 1, 2005. All applicable Employee's must have received Wheelchair and Assistive Devices training prior to the May 31, 2005 deadline.

Effective April 6, 2005 2 of2Station:Pf±LWN646(6103)...••....j._,,,I"·--•··.,•.,._,_.IL.,CONTRACTEMPLOYEETRAININGLOGSubjectTrainedlUhee!ckuf.;)fJ61-41117I#l(fI44'111fo<J41111K.4l:!nIIIoZ/41171-<-(<../717Io<./.i.(7t7I-</-4717II74Lf71(

# EXHIBIT G;....Jf...,,.-..,..•.,..••,.."....·....................----·----1--..··---------·t=t·=·-'I-·----·-l...i-,1.J:...·st-··t·........aton...--·.,--...······_.;""\rlrIC:ontrcjctTrainer;'fi,a.ii_tin!'f''..l:lbov.e-hc.tye...(oSio9)'"'4...·•.i.lli•l"!"t11J____jL__•··t••.,-..,...,.•.,.•r•·•··,,·······-·-·-·-·-·_......,-····--...·-.···---·-------'"·•--·-ContractEmployeeT...Lratntng·•.agSt.!l:ljectTrained:J:)ftlA).?DllStation:Y+tLThiscertifiesthattheindividual(s)namedabovehavebeentrainedandtestedsatisfactorilyinaccordancewith.SouthwestAirlinesTrainingProgram.WN-646(05/091__.

# EXHIBIT H

## Lesson Plan: CRO DAW Recurrent 2013 SESSION CHECKLIST
SUMMARY This training covers the most common disability-related incidents throughout the previous year. Revisiting these topics will ensure Customer satisfaction and Employee compliance.
NOTE: This checklist should be used before your training session to secure all logistical items. MATERIAlS 0 CRO DAW Recurrent 2013 PowerPoint
0 Markers, pens, pencils, note pads
0 Copies ofWN-314 and WN-315 forms
0 laptop/Desktop PC with projector OBJECTIVES 0 Understand federal regulations and how they apply to Southwest Airlines 0 Recognize assistive devices and disabilities 0 Understand preboarding 0 Recognize best practices when interacting with Customers with disabilities 0 Explain use of the PTK 0 Describe how to select a Safety Assistant 0 Categorize assistance animals 0 Evaluate Customer's medical state 0 Demonstrate use of the PTK (CROs only) 0 Evaluate a Customer's ability to fly (CROs only) [] Propose resolutions to complains (CROs only)
AUDIENCE 0 Customer Service Agents 0 CROs
TIME FRAME 0 The DAW training will take approximately 60 minutes. 0 The CRO training will take approximately 90 minutes.

©2013 Southwest Airlines Company Page 1

### Lesson Plan: CRO DAW Recurrent 2013 SECTIONS Section 1: Federal Regulations Section II: Assistive Devices 

## & Disabilities Section Ill: Preboarding Section IV: Best Practices Section V: PTK 

## & Safety Assistants Section VI: Assistance Animals Section VII: Medical Considerations Section VIII: CROs

©2013 Southwest Airlines Company Page 2

## Lesson Plan: CRO DAW Recurrent 2013 

## FEDERAL REGULATIONS 15 Minutes

1. OPEN the CRO DAW Recurrent 2013 PowerPoint. Display slide 1.

2. WELCOME the Students to CRO/DAW Customer Service Recurrent. 3. SUMMARIZE
• We are covering some of the more common Customer complaints from the past year. • The first portion ofthis training includes Disability Awareness, for all Customer contact Employees. Advance to slide 2.

4. SUMMARIZE
• The second portion of the training refers to the duties of a Complaint Resolution Official (CRO). It is important for all Employees to understand the role of a CRO. • The training will also ensure compliance with 14 CFR Part 382 as required by the DOT. Advance to slide 3.**·-~**...**of~m:~air)** .**•Efllud:•~.wltt-~(~edt} ·~~to~ICJ~otcriri** 

©2013 Southwest Airlines Company Page 3

### Lesson Plan: CRO DAW Recurrent 2013

5

. SAY These are the objectives we will be covering during the training. • Understand federal regulations and how they apply to Southwest Airlines
• Recognize assistive devices and disabilities
• Understand preboarding
• Recognize best practices when interacting with Customers with disabilities
• Explain use ofthe PTK
• Describe how to select a Safety Assistant
• Categorize assistance animals
• Evaluate Customer's medical state
• Demonstrate use ofthe PTK (CROs only)
• Evaluate a Customer's ability to fly (CROs only)
• Propose resolutions to complaints (CROs only)
Advance to slide 4.

Co mp la rn ts Re.,o l u tr o tl Offr ual (CRO)

6

. ASK Who is a CRO? • EXPECTED RESPONSE o All Ops Agents, Ops Sups, CS Sups and Managers in the Stations are CROs. Click to animate.
7. SAY A CRO must be on duty during all flight activity. Click to animate.

©2013 Southwest Airlines Company Page 4

### Lesson Plan: CRO DAW Recurrent 2013

Advance to slide 5.

8. ASK What is 14 CFR Part 382? • EXPECTED RESPONSE o A federal regulation that protects Customers with Disabilities. 9. SAY 14 CFR Part 382 is a regulation implemented by the DOT providing instructions to air carriers regarding the transportation of Customers with disabilities. 10. SAY You can find the regulation in two locations. Click to animate. 11. SAY The first is on SWAUfe. Click to animate. 12. SAY The second is on southwest.com. 13. Have the Students log onto SWALife, and locate and open 14 CFR Part 382. 14. DEMONSTRATE how to assist Customers by looking up topics within the regulation by using the Find feature. Advance to slide 6.

15. SAY This is a screenshot of 14 CFR Part 382 as it is seen on SWALife. Click to animate. 16. SAY The Find feature is located at the top of the screen. 17. EXPLAIN Failure to honor a Customer's request to view or obtain a copy of the regulation may result in a fine of no less than $27,500 per incident.

©2013 Southwest Airlines Company Page 5

### Lesson Plan: CRO DAW Recurrent 2013

Advance to slide 7.

DEMONSTRATE how to access the online CRO Reference Guide. This guide includes the sections of 14 CFR 382 that apply to Southwest Airlines, and Southwest's policies regarding each regulation. Advance to slide 8.

Click to animate. 18. DEMONSTRATE how to use the Search feature to look up Portable Oxygen Concentrators (POCs)

. Point out the regulation, as well as Southwest's policy

. Advance to slide 9.

19

. SAY There are a few federal policies you need to be familiar with. • ADA- governs the rights of people with disabilities in public areas
. • ADAAA- amendments to the ADA policies, added in 2011. • ACAA- governs the rights of individuals with disabilit ies in airports and on airplanes.

Advance to slide 10.

©2013 Southwest Airlines Company Page 6

## Lesson Plan: CRO DAW Recurrent 2013

20. ASK Can anyone define "disability" according to 14 CFR Part 382? 21. DEFINE Disability- A physical or mental impairment that, on a permanent or temporary basis, substantially limits one or more major life activities, has a record of such impairment, or is regarded as having such impairment. Click to animate.
22. ASK Can anyone define "discrimination" according to 14 CFR Part 382? 23. DEFINE Discrimination- the act, practice, or instance of discriminating categorically rather than individually. Essentially, discrimination occurs when an individual receives treatment based on criteria, often stereotypes or generalizations, of a broader category or group to which they belong. 24. SAY It's important that you recognize discriminatory treatment by airline Employees. Some examples of discriminatory treatment from 14 CFR Part 382 include: • Limiting the number of Customers with disabilities traveling on a flight. • Requiring Customers with disabilities to accept special services they did not request. For example, requiring a Customer with a visual disability to use a wheelchair and attendant. 25. SAY There are many more examples of discriminatory treatment. Have Students share their experiences and/or awareness of these instances.

©2013 Southwest Airlines Company Page 7

## Lesson Plan: CRO DAW Recurrent 2013 ASSISTIVE DEVICES 

## & DISABILITIES 

## 5 Minutes
Advance to slide 11.

1. SAY When you think of an assistive device, many ofyou immediately think ofa wheelchair. It is important to note that assistive devices may be any device used by a Customer for their disability. Click to animate.
2. SAY Some examples incluc;le a walker, cane, POC and Segway (when used by a Customer with a disability). 3. SAY If a Customer discloses that they have an assistive device in their bag, recommend that they carry it on the plane if it is possible, to prevent damage

. 4. SAY Assistive devices do not count toward baggage limits when they are in their own bag. 5. SAY lfthe Customer chooses to check the bag, the CSA must make sure to check this bag as a medical device. NOTE: 

### Syringes and life sustaining medications are consideredassistive devices. Advance to slide 12.

6. SAY There are times when Customers request to have their wheelchair stowed in the cabin. 7. SAY On a 717, there are no wh eelchair storage compartments; therefore, the wheelchair must be strapped to seats lOA and lOC by following these steps

. • Remove the blue seat track covers Click to animate.

• Attach th e restraints

©2013 Southwest Airlines Company Page 8

# I

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### Lesson Plan: CRO DAW Recurrent 2013

• Place the folded/collapsed wheelchair into Row 10, Seats A through C, with the front of the chair facing the window. Click to animate.

• Lock the wheels. (No portion of the wheelchair may be in the aisle area.) • The outboard restraint must be weaved through the wheelchair to the opposite side and back through the wheelchair toward Seat lOA, leaving the clasp exposed when completed. • The restraint on the inboard seat track must be placed through the bottom leg of Seat lOA and pulled in the opposite direction back to the right wheel ofthe chair. The restraint will then be placed outside ofthe right wheel and weaved back through the chair in an upward direction. Click to animate.

• Place the buckle into the clasp to lock the two (2) restraints. • Tighten both restraints until the wheelchair is secure.
8. SAY Ifthe Customer with the disability insists that their chair must be stowed in the cabin instead of in the cargo bin, it is important to note that seat strapping the chair may require moving people from lOA and lOC, or possibly denying boarding to Passengers.

Advance to slide 13.

9. ASK Who is required to complete an Assistive Device Inspection Tag? • EXPECTED RESPONSE o The first point of contact. Advance to slide 14.

©2013 Southwest Airlines Company Page 9

## Lesson Plan: CRO DAW Recurrent 2013

10. SAY Customers can provide written instructions. Southwest.com provides a template, which the Customer may bring with them to the airport. 11. SAY It is also important to understand that when we receive a Customer's written instructions, we are required to follow the written instructions unless doing so poses an increased risk to the Customer, an Employee, orthe assistive device. 12. SAY Written instructions are to be stapled to the Assistive Device Inspection Tag, with the instructions facing out. Advance to slide 15.

13. EXPLAIN that another important awareness piece is the ability to different iate between obvious and hidden disabilities. Click to animate. 14

. SAY Some examples of obvious disabilities include: Click to animate.

• Spinal cord injury • C erebral palsy • Stroke • Tourette Syndrome Click to animate.
15

. SAY S ome examples of hidden disabilities include : Click to animate.

• Heart disease • Claustrophobia • Alzheimer's disease • Peanut Dust Allergy
16. SAY The important take away here is that we cannot make assumptions based on appearance
. Hidden disabilities are just as valid as obvious disabilities. 17

. SAY Additionally, we cannot require a Customer with a disability to reveal t heir disability.

© 2013 Southwest Airlines Company Page 1 0

### Lesson Plan: CRO DAW Recurrent 2013

• Before creating a Special Service Request (SSR), it is important to let the Customer know the SSR is being created.
• Ifthe Customer does not want the SSR, we must honor their wishes. • We cannot require them to accept assistance. Advance to slide 16.

18. SAY Our responsibility to Customers with disabilities does not necessarily end within our terminal. The DOT requires airlines to provide assistance for our Customers with disabilities to most areas ofthe airport property. For example, SWA is responsible for providing assistance to: • Other gates • Other airlines • Other terminals • The curb outside • Baggage claim • Animal relief areas for assistance animals

©2013 Southwest Airlines Company Page 11

## Lesson Plan: CRO DAW Recurrent 2013
PRE BOARDING 

## 10 Minutes
Advance to slide 17.

1. ASK If a Customer with a disability requests preboarding, what are the two questions you may ask? • EXPECTED RESPONSE o Do you need assistance boarding? o Do you have a specific seating need? Click to animate. 2. SAY The first question: "Do you need assistance boarding?" Click to animate. 3. SAY The second question: "Do you have a specific seating need?" 4. SAY Ifthe answer is "No" to both of these questions, the Customer with a disability may not preboard; however, he or she may qualify for extra time boarding if needed. Advance to slide 18.

5. SAY These are examples of Customers who qualify for preboarding due to specific seating needs. • Customers who need an aisle wheelchair • Customers trave ling with a Safety Assistant • Customers traveling with assistance animals • Customer who have fused/immobilized leg 6. SAY Customers requiring the use of an aisle chair, a Safety Assistant, assistance anima ls, or a second seat due to a fused/immobilized leg(s) require specific seats.

©2013 Southwest Airlines Company Page 12

### Lesson Plan: CRO DAW Recurrent 2013

7. SUMMARIZE
• On an AirTran flight, the first boarding announcement that is made is for preboarders. • AirTran has the same qualifications as SWA for who is eligible to preboard. • AirTran does have blue preboard authorization sleeves similar to SWNs, but because of advanced seat assignments, Customers do not always ask for a blue sleeve or for preboarding privileges. • Passengers whose PNR indicates they have an infant or wheelchair, are blind or deaf, or have a pet or service animal, or have a POC, are automatically assigned to boarding zone 3, which boards after business class. This offers a little extra time for these Customers to board, regardless of where they are seated in the cabin. 8. EMPHASIZE that the biggest difference between Southwest and AirTran's preboarding procedures is that AirTran Customers are not used to asking for the blue sleeve, so Employees will need to remind Passengers to obtain one for the purposes of preboarding. Advance to slide 19.

9. ASK Which preboarding Customers do not receive a blue preboarding sleeve? • EXPECTED RESPONSE oUM's oLEO's o COS's o People who need extra time 10. EXPLAIN that blue sleeves are reserved only for Customers with disabilities requiring priority preboarding. Blue sleeves are not to be used forUM's, LEO's, COS's or people who need extra time boarding. Advance to slide 20.

Click to animate.

©2013 Southwest Airlines Company Page 13

## Lesson Plan: CRO DAW Recurrent 2013

11. EXPLAIN that even for aircraft swaps, all Customers with disabilities, including local Customers, must be permitted to preboard before any able bodied through Customers are permitted to board.

© 2013 Southwest Airlines Company Page 14

### lesson Plan: CRO DAW Recurrent 2013 

## BEST PRACTICES 10 Minutes
Advance to slide 21.

1. SAY Let's talk about some best practices when interacting with Customers with disabilities. 2. SAY For all Customers with disabilities: • Wait for instructions. A Customer with a disability will tell you the type of assistance he or she may need. • Never assume you know what type of help is needed or that the Customer requires assistance. • Speak directly to the Customer with a disability. • Do not refer to a Customer's disability unless it is relevant. Click to animate. 3. SAY For Customers who are blind or have low vision: • Let them know where they are and where you are taking them. • It is commonly understood that touching the back ofyour hand to the back of the hand of a Customer who is blind is an offer to guide them somewhere. • Be descriptive when giving directions. Click to animate.
4. SAY For Customers in wheelchairs: • Check on unattended Customers in our wheelchairs every 30 minutes; even ifthey are not in an airport wheelchair, and even ifthey are not traveling alone, unless the Customer has waived our obligation to do so. • Stand back far enough so that a Customer in a wheelchair does not need to look up at you. • Do not lean on a wheelchair or any other assistive device. • Avoid referring to groups of people by their condition or disability, such as "my wheelchair Passengers" or "the deaf people", etc. • Communicate preboarding with Flight Attendants so they are expecting the Customers and can assist as necessary. • Walk backwards down steep jetbridges, when it is safe and practical to do so. • Communicate with the Customer to determine ifthe Customer is able to walk onto the aircraft. Provide assistance for the Customer and their carryons.

©2013 Southwest Airlines Company Page 15

## Lesson Plan: CRO DAW Recurrent 2013

Advance to slide 22.

5. SAY Let's review our best practices for assisting Customers with disabilities at the gate and jetbridge. Click to animate.

• Rely on yourtraining and common sense when making decisions, and always do what is in the Customer's best interest and what's in the interest ofyour own personal Safety. • Ifa Customer's instructions contradict our training, we must follow the Customer's instructions as long as it will not cause harm to anyone. Click to animate.

• Try to have an extra wheelchair in yourjetbridge before arrival. • Avoid pushing a wheelchair against the flow oftraffic in the jetbridge. • Communicate with and come to agreement w ith the Customer before attempting to assist them

. 6

. SAY Remember, even when you ' re not sure wh at to do, the way you treat the Customer is just as important as the service you provide. Advance to slide 23.



# ----·--,..

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# --

7. SAY Maya Angelou said it best, "I've learned that people will forget what you said, people w i ll forget what you did, but people will never forget how you made them feel. "

©2013 Southwest Airlines C ompany Page 16

### Lesson Plan: CRO DAW Recurrent 2013

Advance to slide 24.

8. SAY let's talk about what happens when you have Customers with allergies onboard along with assistance animals or pets. 9. SAY First and foremost, you would offer to create a buffer zone between the Customer with the allergy and the assistance animal or pet; seating them at opposite ends of the plane. 10. SAY When there are conflicts that cannot be resolved by creating a buffer zone, refer to the job aid regarding Customers with allergies. This is available on SWAlife to assist you in resolving concerns about pet allergies. Click to animate.
11. SAY The first scenario here reveals that the Customer with the Allergy has a medical certificate, while the Customer with the Animal has a pet. 12. ASK Who travels? • EXPECTED RESPONSE o Customer with allergy Click to animate.
13. ASK Which required CRO form would be needed? • EXPECTED RESPONSE oNone Click to animate.
14. REPEAT these steps to reveal each scenario, asking who travels and which required CRO form is needed. Continue until the entire table is uncovered. 15. SAY We cannot guarantee that there is no dander or peanut dust on our airplanes. 16. DEMONSTRATE how to locate this job aid at SWAUfe>Ground Ops>References>lob Aids> CustomerService and Operations sections > Resolving Travel Conflicts for Customers with Animal Allergies.

©2013 Southwest Airlines Company Page 17

# EXHIBIT I:1 ( 

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14 CFRPart 382 [Docbt-. OST-2004-19482; OST-2005-22298; OST-2006-23999)**~s** 2105-AC9i; 2105-AC29; 2105-AD41}**~ondiscl·iminadon** on the Basis ofDisability in Air TrnYel AGE:'I;CY: Department ofTr.mspotUtion. Office oftbe Secretary**ACTIO~:** Final Rull!' Sl.::\IMARY:**The~** ofTr:anspo.nation is aDll"f"!ding its. Air Carrie: AccC"Ss Act (ACAA) rules to applyto foreign carrie!:s. The final rule also adds newprm.isions concerni!lg passengers >Ym USC" medical oxygen and passengct"S who are deafo.rbard-of-hearing. The role also reorganizes andupdate's 1he esu:ire ACAArule. TbeDepartment will respond to some matters raised in this ndemakingbyissuing a subsequent supplementalnotice ofproposed rulemaking. EFFECm'"E DATE: This role is effective May 13. 2009.

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# EXHIBIT 

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# Aviation Mobility· Maintenance Log 8041-A Arrowridge Blvd

. Charlotte , NC 27273 704-665-971 1 704
-665-7933 Fax

B18N14876 18"

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20461 18" 37884 18" 37886 18 " 06-37372 18" 06-37378 18" 06-37379 18" 06-37384 18 " 07-40668 18" 07-40669 18" 07-40871 18" 07-40872 18" I I I I I I I I I I I I R I I R

R I R I R I I I I I I I A I I A A A A R I I A I I I I I I I I A I I A A A A I I I I I I I I I A I A A A A R I R A A A A I I I A I A A A A I REPI.6**''~~ACEDIN{OSERWCE** I I A A A A R R I R R A A R R I A R A A R INVENTORY INVENTORY INVENTORY INVENTORY INVENTORY INVENTORY INVENTORY INVENTORY INVENTORY INVENTORY INVENTORY A I I I A A R R I I I A A I I I I A A R A A I R R R I I I I I I I R A A R R R I A A I A A I I A A A A R

R A I I A A R R A I I A A I A A A

- I A A R FOR OFFICE USE ONLY

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Name: Doug Johnson DATE ENTERED : -- --1 INITIALS:**Station:.:.P~H~L-----------**

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