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 coworker”‟ 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 email 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 

Proprietary Information: For use by PrimeFJight A viat/on personnel only. Unauthon"zed dissemination of 

this document or information contained herein is prohibited. 

PrimeFiight Aviation, 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 PrimeRight Aviation Personnel only .. Unauthorized mssemination or tflls document or Information contained 

herein Is prohibited. 
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 of Training 

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 

PrfmeRight Aviation, 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 PrimeRight A v/ation Personnel only .. Unauthorized dissemination of this dOCllment or information contLJ!ned 

herein is prohibited. 
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) 

PrlmeAight Aviation, 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 PrimeRight Aviation Personnel only .. Unauthorized dissemination of this doaJment or information contained 

herein is prohibited. 
WHEELCHAIR TRAINING REQUIREMENTS 

PrimeRight Aviation, 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 PrimeAight Aviation Personnel only .. Unauthorized dissemination of tllis document or information contained 

herein is prohibited 
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!ight Aviation, 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!ight Aviation Personnel only .• Unauthorized dissemination of tills document or information contained 

herein is prohibited 
CUSTOMER SERVICE TRAINING 

CLASS# 420 

PrimeFiight Aviation 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!Ight A vtation Personnel only .• Unauthorized dissemination of this 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. 

PrimeAight A viaffon, 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 by PrimeRight Aviation Personnel only •. Unauthorized dissemination of this document or Information contoined 

herein Is prohibited. 
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. 

PrimeRight Aviationr 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 PrfmeRight Aviation Personnel only .. Unauthorized disseminalion of this dOOJment or information contained 

herein is prohibited. 
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 I ism 

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. 

PrimeFJight Aviation, Wheelchair Training Manual g 

Class #42Dr #421, #521 and #820 04/2009 

NOTE: All training minimums must. exceed the standards outlined by PrimeRight A viatlon client, air operator. Propn"el:iJry 

Information: For use by PrimeFllght Aviation Personnel only .• Unauthorized dissemination of this document or information conl:iJined 

herein is prohibited. 
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. 

PrimeRight Aviation, 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 PrimeRight Aviation Personnel only •. Unauthorized dissemination of this document or information contained 

herein is prohibited. 
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/meRight Aviation, Wheelchair Training Manual 11 

Gass #420, #421, #521 and #820 04/2009 

NOTE; All training minimums must exceed the standards outlined by PrimeRight Aviation dienC air operator. Proptfetaty 

Information: For use by PtfmeFI/ght A viat/on Personnel only .. Unautflotfzed dissemination of this document or information contained 

herein is prohibited. 
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!ght Aviation Wheelchair Training Manual 12 

Class #420, #421, #521 and #820 04/2009 

NOTE: All training minimums must exceed the standards outlined by PrimeF!Ight AvfaUon dienC air operator. Proprietary 

infom1atfon: For use by PrimeF!ight Aviation Personnel only .. Unauthorized dissemination of this dOCTJment or information contained 

herein is prohibited. 
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. 

v Appearance 

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. 

v Job Knowledge 

Job Responsibilities 

• Know PrimeFiight Aviation and air carriers policies and procedures. 

• Know the responsibilities of each person in the airport. 

PrimeAight Aviation, Wheelchair Training Manual 13 

Class #420, #421, #521 and #820 04/2009 

NOTE: All training minimums must exceed the standards outlined by PrimeRight Aviation dient; air operator. Proprietary 

Jnfonnation: For use by PrimeF!ight Aviation ~rsonnef only .. Unauthori2ed diSsemination of this document or infonnatfon cvntalned 

herein Is prohibited 
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. 

v Efficiency 

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/ight Aviabon, Wheelchair Training Manual 14 aass #420, #421, #521 and #820 04/2009 

NOTE: All training minimums must exceed the standards outlined by PrimeFI/ght Aviation dlent, air operator. Proprietary 

Intonnation: For use by PrtmeRight Aviation Personnel only .. Unauthottzed dissemination of this document or infbnnatton contained 

herein Is prohibited. 
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. 

V Tactful 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 Mam1 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 or jargon. 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. 

PrlmeRight Aviation, Wheelchair Training Manual 15 aass #420, #421, #521 and #820 04/2009 

NOTE: All training minimums must exceed the standards oufiined by PrfmeAight Aviation cHent, air operator. Proprietary 

InformaUon: For use by PrimeFiight A VJatton Personnel only •• Unauthorized dissemination. of this doc1lment or Information a:mtained 

herein is prohibited. 
d 

!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 

• If you 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. 

• If you 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 

PrimeRight Aviation, Wheelchair Training Manual 16 aass #420, #421, #521 and #820 04/2009 

NOTE: All training minimums must exceed the standards outlined by PrimeRight Aviation dlent air operator. Proprietary 

Infonnation: For use by PrimeRight Aviation Personnel only .. Unauthorized dissemination of this document or infonnation 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 if there 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/Jght Aviaffon, Wheelchair Training Manual 17 aass #420, #421, #521 and #820 04/2009 

NOTE: All training minimums must exceed the standards outlined by PrlmeAight Aviation d/ent air operator. PrOprietary 

Information: For use by PrimeFIIght Aviation Personnel only .. UnauthDrlzed dissemination of this document or information contained 

herein is prohibited. 
I 

f 

SENSITIVITY TRAINING - AIR CARRIER ACCESS ACT 

·Class# 421 

PrimeFI!ght Aviation, Wheelchair Training Manual 18 

Oass #420, #421, #521 and #820 04/2009 

NOTE: All training minimums must exceed the standards ouUined by PrimeFiight Aviation dient air operator. Proprietary 

Information: For use by PlimeAight Avtauon Personnel only .. Unauthorized dissemination of !his document or /nfonnatian conli!fned 

herein 1$ prohibited. 
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 educate1 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 disabilities1 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 race1 color1 sex1 national 

origin1 age1 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 of the Federal Government. 

For answers to additional questions, call the ADA Information Line 

• 800-514-0301 (voice) 

• 800-514-0383 (TIY) 

PrfmeAight Aviation, Wheelchair Training Manual · 19 

aass #420, #421, #521 and #820 04/2009 

NOTE: All training minimums must exceed the stondards outlined by PrimeFiight Aviation dlent, air operator. ProplietBry 

Informadon: For use by PrimeFlight Aviation Petsonnel only .. Unauthorized dlssl!mlnation of this document or information contained 

herein is prohibited. 
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. 

PnmeRight Aviation, Wheelchair Tratning Manual 20 

Class #420; #421, #521 and #820 04/2009 

NOTE: All training mlntmums must exceed the standards outlined by PrimeRight Aviation dienC air operator. Proprietary 

Information: For use by PtimeFiight Aviation Personnel only.. Unauthorized dissemination ot this document or information coniJJined 

herein is prohibited. 
* 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 

deaf or 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 of an emergency/evacuation * Acknowledge and follow crew instructions 

Pr/meRight Aviation, Wheelchair Training Manual 21 

aass #420, #421, #521 and #820 04/2009 

NOTE: All training minimums must exceed the standerds outJ/ned by PrfmeFIIght A vtaUon dient, afr operator. Proprietary 

Information: For use by PrlmeRight Aviation Personnel only .. Unauthorized dissemination of this document or information contained 

herein Is prohibited. 
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. If so, 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. 

PrfmeFI/g/Jt Aviation, Wheelchair Training Manual 22 

Oass #420, #421, #521 and#820 04/2009 

NOTE: All training minimums must exceed the standards outlined by PrtmeRight Aviation dient, air operator. Proprietary 

Information: Far use by PrlmeAight Aviation Personnel only •. Unauthorized dissemfnaUon of this document or Information contained 

herein is prohibited. 
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? 

PtimeRight Aviation, Wheelchair Training Manual 23 

Oass #420, #421, #521 and #820 04/2009 

NOTE: All training m!nimums tTJust exceed the standards outlined by PrimeR/ght Aviation dient, air operai1Jr. Proprtewry 

InfDlmation: For use by PrlmeRight Aviation Personnel only.. Unauthorized dissemination of this document or Information contained 

herein is prohibited. 
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: __________________________________________________ __ 

PrimeA/ght A vlatfon, Wheelchair Training Manual 2 4 

Gass #420, #421, #521 and #820 04/2009 

NOTE: All training minimums must exceed the standards outlined by PtimeF!Ight Aviation dlent; air operator. Proprietary 

Infonnation: For use by PrimeRight Aviation Personnel only .. Unauthotized dissemination of this document or Jnfotmatfon contained 

herein Is prohibited. 
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 

• If you 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 reputation1 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. 

PrfmeRight Aviation, Whee/choir Training Manual 25 

Oass #420, #421, #521 and #820 04/2009 

NOTE: All training minimums must exceed the standards outlined by PtimeF!ight Aviation dlent_ air operator. Proprierery 

Informalion: For use by PrfmeR!ght A via/ion Persorlnel only .. Unauthorized dissemination of this dOCllment or information contained 

herein is prohibited, 
i 

i 

l 

WHEELCHAIR SAFETY 

Transferring and Transporting Customers 

CLASS #521 

PrlmeRfght Aviation, Wheelchair Training Manual 26 

Class #420, #421, #521 and #820 04/2009 

NOTE: All training minimums must exceed the standarrfs outlined by PrimeAight Aviation dient, air operator. Proprietary 

Information: For use by PrfmeFiight Aviation Personnel only .. Unauthorized dissemination of this document or information contained 

herein is prohibited. 
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!ight Aviation, Wheelchair Training Man112! 27 aass #420, #421, #521 and #820 04/2009 

NOTE: All training minimums must exceed the standards ouliined by PrimeRight Aviation dient, air operator. ProprietaJY 

Jnfotmaaon: For use by PtimeRight Aviation Personnel only.. Unauthorized dissemination of this document or Information mntained 

herein Is prohibited. 
I 

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. 

PrimeRight Aviation, 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 PrimeAight Aviation Personnel only •. Unauthorfzed dissemination of this document or infotmation contained 

herein is prohibited. 
• 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. 

PrimeRight Aviation, 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 PrimeRight A v/atton Personnel only .• Unauthorized dissemination of this document or information 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 tipping1 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 debris1 holes or expansion 

joints that can easily cause the front casters to stop and result in the wheelchair 

tipping over forward. 

• Periodically check the -customer1

S 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 S01 or getting in a HURRY can jeopardize the safety 

of the customer, yourself and possibly others! 

PrimeFiight Aviation, 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!ght Aviation Personnel only .• Unauthorized dissemination of this document or lnfo!T11atlon contained 

herein Is prohibited. 
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. 

PrimeFfight Avtation, 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 PrimeFfight Aviation Personnel only •• Unauthorized cKssemination of this document or information contained 

herein is prohibited. 
WHEELCHAIR ASSISTANTS OPERATION GUIDE 

CLASS #820 

PrimeFiight Aviation, 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 PrlmeAight Aviation Personnel only., Unauthorized dissemination of this document or information contained 

herein Is prohibited 
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 of speaking 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. 

PrimeFiight Aviation, 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: For use by PrfmeF/ight Aviation Personnel only .. Unauthorized dissemination of this document or information 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!ght Aviation, 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 PrfmeFiight Aviation Personnel only.. Unauthorized dissemination of ti1is document or information contained 

herein is ptrihibitecf. 
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 yes1 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 people1 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. 

PrimeRight Aviation, 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 PrimeRight Aviation Personnel only.. Unauthorized dissemination of this 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 of sex 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, proposltions1 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 

Date 
PRIME 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 of the 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/ZfJIIJ j{ 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: 1 00_----'----

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 of the 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. 

_ ·. · · ·Prime flight 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 tl t/ 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 of Recurrent 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 F 
1 

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 of2 
Course 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 of2 
Pf±L 

CONTRACT EMPLOYEE 

TRAINING LOG 

Subject TrainedlUhee!ckuf. ;)fJ6 

1-41117 

I #l(f 

I 44'111 

fo<J4111 

1 K.4l:!n 

I 

I 

I oZ/4117 

1-<-(<../717 

I o<./.i.(7 t7 

I -</-4717 I I 7 

4Lf71 ( 
EXHIBIT G 

; .... 

Jf 

.................... 

- ---·----1-- .. ··---------· t=t·

-· ----·- l ... i- ,1. 

J 

: . . . 

·st-· ·t· ... 

..... aton . ..--·.,-- ... ······ 

_

C:ontrcjct Trainer;' 

. .l:lbov.e-hc.tye .. . 

(oSio9) 
"t 

1 

1 

J 

___ _jL __ 

·······-·-·-·-·-· 

_ ...... , -···· -- ... ·- . ···---·------- '"·•--· -

Contract Employee 

T .. . L ratntng ·•.ag 

Station: Y+tL St.!l:ljectTrained: J:) ft lA) .?Dl

This certifies that the individual(s) named above have been trained and tested satisfactorily in accordance with. SouthwTraining Program. 

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 of this 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 of the PTK 

• Describe how to select a Safety Assistant 

• Categorize assistance animals 

• Evaluate Customer's medical state 

• Demonstrate use of the PTK (CROs only) 

• Evaluate a Customer's ability to fly (CROs only) 

• Propose resolutions to complaints (CROs only) 

Advance to slide 4. 

Compla rn ts Re.,olutro tl Offrual (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 of you immediately think of a 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 considered assistive 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 wheelchair 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 the restraints 

©2013 Southwest Airlines Company Page 8 
I II 

! .. 1' 

ill 

t 

~ II 

H 

~; f 

1 

l : '! ' 

1 '

I 

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 of the 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 If the 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, or the 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 

• Cerebral palsy 

• Stroke 

• Tourette Syndrome 

Click to animate. 

15. SAY Some 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 10 
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. 

• If the 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 of the 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 If the 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 traveling 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 animals, 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 of your 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 if they are 

not in an airport wheelchair, and even if they 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 if the 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 your training and common sense when making decisions, and always do what is 

in the Customer's best interest and what's in the interest of your own personal Safety. 

• If a 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 your jetbridge before arrival. 

• Avoid pushing a wheelchair against the flow of traffic in the jetbridge. 

• Communicate with and come to agreement with the Customer before attempting to 

assist them. 

6. SAY Remember, even when you're not sure what to do, the way you treat the Customer is just 

as important as the service you provide. 

Advance to slide 23. 

----·--,.. ..... -·--,.. .... 

-- 7. SAY Maya Angelou said it best, "I've learned that people will forget what you said, people will 

forget what you did, but people will never forget how you made them feel." 

© 2013 Southwest Airlines Company 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> 

Customer Service and Operations sections > Resolving Travel Conflicts for Customers with Animal 

Allergies. 

©2013 Southwest Airlines Company Page 17 
EXHIBIT I 
:1 

( 

: 

; ... 

' ' 

r r. 
abilities 

_ . •, -

. .• 

.. - . . 

use.of the-PTI( 

·, • T n ..___, • 

:customer!s mediCai:State 

L .. ".- ... 

J ' - ' __ .,. 'I 

trate of 9n,y) 

r ,. • • · 

(CRQs. orily) 

- ,... • ' ' J 

(CROs only) 

, 

,._.. ·- ... . -

·- •• • .---. • '• I•• • .,. • • 

~ondiscriminadon on th!! Basis of Disability in .-\0· Trani 

73 FR 27614, :\lay 13, 2008., as modififll by: 

• Correction ~ooo of 74 FR 11469, March 18, 2009 

• Correctimt~otkeof75FR4488S Juh- 30,2010 

This doCllliU!Ilt indudK the modifkadon'> fro.m both Correction ~otkes. 

14 CFR Part 382 

[Docbt-. OST-2004-19482; OST-2005-22298; OST-2006-23999) 

~s 2105-AC9i; 2105-AC29; 2105-AD41} 

~ondiscl·iminadon on the Basis of Disability in Air TrnYel 

AGE:'I;CY: Department ofTr.mspotUtion. Office of tbe Secretary 

ACTIO~: Final Rull!' 

Sl.::\IMARY: The~ ofTr:anspo.nation is aDll"f"!ding its. Air Carrie: AccC"Ss Act (ACAA) rules to 

apply to foreign carrie!:s. The final rule also adds new prm.isions concerni!lg passengers >Ym USC" medical 

oxygen and passengct"S who are deaf o.r bard-of-hearing. The role also reorganizes and update's 1he esu:ire 

ACAA rule. Tbe Department will respond to some matters raised in this ndemaking by issuing a 

subsequent supplemental notice of proposed rulemaking. 

EFFECm'"E DATE: This role is effective May 13. 2009. 





! 

t1 

ll 

EXHIBIT J 
Aviation 

Mobility· 

Maintenance Log 

8041-A Arrowridge Blvd. 

Charlotte, NC 27273 

704-665-971 1 

704-665-7933 Fax 

B18N14876 18" 

06-38382 18" 

022010454 22" 

D22N13882 22" 

B18N14881 18" 

D22M12989 22" 

07-40879 18" 

B22E12442 22" 

B18P08042 18" 

07-40864 18" 

37884 18" 

06-37379 18" 

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 . 

Name: Doug Johnson 

DATE ENTERED: ----1 

INITIALS: 

Station:.:.P~H~L-----------

Date 

I I I PHL sw 8/13/2012 

I I I PHL sw 8/25/2012 

R I I I PHL sw 8/29/2012 

R I I I PHL SW 8/29/2012 

I I I PHL sw 9/9/2012 

I I I I PHL sw 9/17/2012 

I I I PHL SW 9/20/2012 

I I I I PHL sw 9/21/2012 

PHL sw 9/27/2012 

I I I PHL sw 10/11/2012 

I I I PHL SW 10/11/2012 

I I I PHL sw 10/15/2012 

PHL sw 11/1/2012 

PHL sw 11/1/2012 

PHL sw 11/1/2012 

PHL sw 11/1/2012 

PHL sw 11/1/2012 

PHL sw 11/1/2012 

PHL _sw H/1/2012 

PHL sw 11/1/2012 

I PHL sw 11/ /2012 

PHL sw 11/1/2012 

PHL sw 11/1/2012 

'HC: ' 3).xls 
07-40875 18" IM{ENTORY PHL sw 11/1/2012 

07-40878 18" INVENTORY PHL SW 11/1/2012 

' 

07-40881 18" INVENTORY PHL sw 11/1/2012 

07-10442 18" INVENTORY PHL sw 11/1/2012 

B18N14780 18" INVENTORY PHL sw 11/1/2012 

B18N14872 18" INVENTORY PHL sw 11/1/2012 

B18N14876 18" INVENTORY PHL sw 11/1/2012 

B18N14881 18" INVENTORY PHL sw 11/1/2012 

818016143 18" INVENTORY PHL sw 11/1/2012 

B18P08042 18" INVENTORY PHL sw 11/112012 

D22010454 22" INVENTORY PHL SW 11/1/2012 

B22E12436 22" INVENTORY PHL sw 11/1/2012 

B22E12438 22" IIY"lCIY I VI'{ r PHL sw 11/1/2012 

B22E12440 22" INVENTORY PHL sw 11/112012 

B22E12443 22" INVENTORY PHL sw 11/1/2012 

B22E12445 22" INVENTO~Y PHL sw 11/1/2012 

B22E12937 22" IN\tt::.N I UIH PHL SW 11/1/2012 

D22M12481 22" INVENTQRY PHL sw 11/1/2012 

D22N13882 22" INVENTORY PHL SW 11/1/2012 

07-40967 18" R I I R R R A A I I A A I A A I NO I I PHL sw 11/3/2012 

07-40874 18" I I I R A A A A I I A A I A A R NO I I PHL SW 11/3/2012 

07-40881 18" R I R I A A A A R R A A I A A R NO I I PHL sw 11/5/2012 

B18P08042 18" I I I I I I I A A I I I I I I I I I I PHL SW 11/1312012 

B18N14881 18" I I I I I I I I I I I I I I I I I I I PHL sw 11/1412012 

06-37376 18" I I I I A A A A R R I I I A A R I I I PHL SW 11/14/2012 

D22010454 22" I I :1" I I I I I I I A A I I A A I I I I I PHL sw 11/18/2012 

07-40887 18" R I I R A A A A A A I R I A A R I I I PHL SW 11/26/2012 

B22E12441 22" I R I R I I A A A A A A I I R R R I I I I PHL sw 11/26/2012 

07-40868 18" R R R I A A A A R R A A I A A R I I I PHL sw 12118/2012 

D22N13882 22" I I I I R I I I A A I I I I R A R I I I I PHL , SW 12120/2012 

D22010454 22" I I I I A I I I A R I A I I I I I I I I I PHL sw 12120/2012 

B22LK12438 22" R I I I I I A A A A R R I I I I R R I I I PHL SW 12120/2012 

'"""' ,,~