EFFECTIVE ACCESS

FOR PEOPLE WHO ARE DEAF OR HARD OF HEARING

OVERVIEW OF HEARING LOSS

Approximately 36 million American adults report some degree of hearing loss.1 

Hearing loss is a spectrum disability. The type of assistance required is 

dependent on a variety of factors including but not limited to the person’s degree 

of hearing loss, whether a hearing aid or cochlear implant is used, the age the 

person lost their hearing, the level of auditory training received, the person’s 

current age and the nature of the listening situation. The chart (Exhibit A) 

provides an overview of the type of assistance needed based on the degree of 

hearing loss. The assistance required is not as precise as the chart appears 

since there is overlap between groups.

Three types of access should be offered whenever there is sound output (live 

voice or recorded audio) in order to have full and consistent access for people 

who are deaf or hard of hearing:

1- Auditory- Assistive Listening System/Devices and

2- Visual- Captioning and

3- Qualified Interpreters

OVERVIEW ON TYPES OF ACCESS AVAILABLE FOR PEOPLE WITH 

HEARING LOSS

A. Auditory: Assistive Listening System/Devices 

In the US, the Americans with Disabilities Act of 1990 (ADA) requires that all 

places of public accommodation with 50 or more fixed seats provide an Assistive 

Listening System (ALS). (The elimination of the fixed seat requirement is 

awaiting the Department of Justice’s approval.) We recommend a lower number 

such as 20 seats since many smaller public venues still pose difficulty for people 

with hearing loss. 

1- How an ALS works

A signal is transmitted through an ALS. The systems, currently, available are 

either a radio frequency (FM), infrared light or magnetic induction to the receiver, 

which may be either an Assistive Listening Device (ALD) or a telecoil (T-coil) in a 

hearing aid or cochlear implant. ALDs enable visitors to increase the volume and 

 

1

http://www.nidcd.nih.gov/health/statistics/quick.htm
receive the sound directly from the source of sound to their ear, which eliminates 

the negative effects of distance, noise and reverberation on sound clarity. 

2- Benefits

Hearing a presentation provides certain benefits. An ALD allows someone with 

residual hearing to have an equal opportunity to effectively participate and 

receive the same benefits of sound (loud, soft, angry, happy, sad, singing etc.) 

with a reasonable modification.

 

3- Types of ALS’ (The Transmitter)

There are, currently, three types of ALSs available: 

 FM- works via a radio frequency.

 Infrared- works via a beam of invisible light.

 Induction Loop- is an audio frequency magnetic signal. 

There are several factors that would determine which system is effective for each 

site. The Kennedy Center’s Guide to Assistive Listening Systems for Theaters at 

http://nadc.ucla.edu/AssistiveListeningDevicesGuidePerformingArtSettings.pdf is 

a useful tool to aid in assessing which system is effective for each site. Some 

factors to consider include but are not limited to environmental concerns, privacy 

issues, the setting, portability, the size of the space, the environment, 

construction materials (for instance, metalwork can absorb or distort magnetic 

fields – see below), the impact of installing the system in the space and cost.

 FM 

An FM radio system works well in large spaces, outdoor settings and where an 

induction loop or infrared system cannot work due to electromagnetic 

interference or bright light, respectively. 

An FM system is not suitable if there is the possibility of FM interference e.g. 

airplanes or if there are privacy concerns since the FM signal can be picked up 

outside the room. Most Broadway theaters do not use an FM system because 

someone could stand outside a theater and record the signal.

Portable FM systems are also ideal for guided tours in order to overcome poor 

acoustics that can challenge even people who do not have a hearing loss. This 

type of system also works well for a room that, typically, does not have the need 

for a permanent system, as a back-up system when the main system fails or in 

places that cannot have a system easily repaired such as on cruise vessels.
 Induction Loop 

An induction loop system utilizes an electro-magnetic coil to create a magnetic 

field. Unlike FM and infrared systems, induction loops are hearing aid 

compatible. Hearing aids or cochlear implants with T-coils receive the sound 

signal directly via their T-coil. Many hearing aids and cochlear implants worn by 

people now have a T-coil. Phones, audio guides or sound enhancement devices 

that are T-coil compatible have a transmitting inductive coupler within the device.

The construction materials used in a building impact whether an induction loop 

can be utilized and how it needs to be configured. This could impact whether the 

system can be used in post-construction settings. It is important that the system 

when installed meets the IEC60118-4 standards for field strength and frequency 

response. An induction loop is often placed in a simple perimeter configuration in

small settings but a more sophisticated arrangement may be required in larger 

settings. 

With an induction loop system, people with T-coil equipped hearing aids or 

listening devices conveniently avoid the need to self-identify, locate, check out, 

wear and return visible headsets or neck loops. The venues do not need to 

distribute or maintain as many headsets or neck loops. The loop system 

maximizes the customized output of the person’s own hearing aid. Thus loop 

systems, when installed, are more likely to be used. Receivers and headsets 

should still be available for those without suitably equipped hearing aids.

Because of their user-friendliness, induction loops have become the major 

assistive listening technology around the world. Induction loops are the only 

type of ALS, currently, available in transitory settings such as mass transit when 

there is insufficient time to distribute and collect the receivers. 

 Infrared 

An Infrared system works via a beam of invisible infrared light. This system 

affords privacy since the receiver must be in the path of light to receive the 

signal, which itself is confined by the walls of the room or auditorium. Many 

Broadway theaters utilize this system.

This system does not work well in large stadium settings where the distance is 

too great to receive the signal or in daytime outdoor settings where the daylight 

interferes with the signal. 

4- ALDs (The Receiver)

There are different styles of receivers for assistive listening systems. Ear bud 

headsets are available that fit directly into the ear. They are not recommended, 
since they require people with hearing aids to remove their aids. Many people 

are also uncomfortable inserting something in their ear that has already been 

inserted in another person’s ear even when cleaned.

Other types utilize headphones or neck loops plugged into the output jack of the 

receiver, which is typically the size of a deck of playing cards. Headsets typically 

do not work for people who wear behind-the-ear (BTE) hearing aids and for some 

people who have more than a mild hearing loss, because the sound output is 

likely to be insufficient. The design of some headsets means that they don't 

confine the sound to the listeners' ears, and other people nearby could be 

disturbed. The headset should be to suit the circumstances.

People who have T-coils in their hearing aid or cochlear implant can receive 

signals directly through their hearing aid/cochlear implant when an induction loop 

is used. However, they will need to use a neck loop in conjunction with an FM or 

infrared receiver to convert the FM or infrared signals to a magnetic field that can 

then be picked up by their T-coil. Neck loops allow the person’s own hearing aid 

or cochlear implant to regulate the volume. The FM or infrared receiver must 

have a jack for plugging in the neck loop. Most one-piece headsets lack jacks.

It is important to ensure that a sufficient number of receivers are available at any 

given place of assembly. In the US, the requirements are detailed in the ADA 

Accessibility Guidelines (“ADAAG”). ADAAG can be found at www.accessboard.gov. For your reference, “Technical Support for ALS” (Exhibit B) is 

attached.

5- Considerations

Some considerations to keep in mind when installing and using an ALS:

 The entire space should receive the signal.

It is important to check the signal at each seat especially under overhangs. 

There should not be any dead spots. 

 High-quality microphones should be used to ensure best possible 

quality of sound.

 The distance between the microphone and the speaker should be 

minimal in order to provide sufficient clarity.

When speakers are not talking from a microphone-equipped podium, they should 

be provided with wearable microphones rather than these being placed on the 

stage or hanging from the ceiling. Stage or ceiling microphones are, however, 

suitable as a back up but not as a primary source of sound transmission. 

 The equipment should be tested and maintained regularly.

The ALS equipment should be checked and maintained regularly similar to other 
equipment. Rechargeable batteries should be charged daily.

B. Visual

1- Benefits

ALDs should not be expected to benefit the full spectrum of people with hearing 

loss. Some people with hearing loss are unaware they cannot hear well, are in 

denial about their hearing loss, or may have a hearing loss that is too severe to 

enable them to benefit from an ALD. (See Exhibit A) A visual component is 

needed but it is not substitute for the auditory part. Both are necessary since 

people with residual hearing will want to hear and many people use captioning to 

fill in the words they miss. Reading does not have the same impact as hearing 

the spoken words. That is why silent movies no longer exist. In addition, 

captioning does not generally work for children below approximately nine years 

old because most don’t have sufficient reading skills.

2- Types Available

The visual offering is dependent on a variety of factors including but not limited to 

whether the situation is transitory, whether the person need to respond, whether 

the person need to look at a particular place at a particular time or is the 

communication brief.

a. Captioning

Captioning is the written form of what is stated similar to a court reporter 

transcribing a witness’ statement except it incorporates additional details 

including the identification of the person speaking, background sounds, music, 

and unstated feelings. Captioning should have a high degree of accuracy and 

reflect what is stated. It might seem obvious but, sadly, it isn't. Poor quality 

captioning does not provide effective access. Recommended captioning 

standards are in Exhibit C.

Captioning contracts should include standards and not be selected based on 

price alone. There are two types of captioning, open or closed.

 Open Captioning (OC) 

Open captioning is always visible and is recommended since the captioning is 

always visible. The captions appear either directly on the film, on a data strip 

below the film, on a data screen adjacent to the lecture or a play or on the 

scoreboard at a sporting event. It should not appear above a film or in an area 

adjacent to the event. Visitors are not required to self-identify to receive the 

assistance they require and staff time is also saved, since employees do not 

need to activate the captions.
OC should be offered for lectures and other spoken presentations. This type of 

captioning is also known as Communication Access Real-time Translation 

(CART). CART is live verbatim captioning. It provides access for people whose 

hearing loss is more profound and cannot or will not use the ALS. CART should 

be offered for specifically scheduled lectures, presentations or when requested. 

The CART provider’s captioning skills must be checked prior to hiring the 

company. Poor quality CART does not provide effective access. Also, the CART 

provider should ensure there is a back-up person in case of illness or 

emergency.

 Closed Captioning (CC) 

Closed captioning is not recommended since it needs to be activated and the 

captions are only seen by those who self-identify. The captions are either seen 

on the screen only when someone turns on the captions or when a special data 

panel is affixed to the seat which is called Rear Window® Captioning. The data 

panels need to be cleaned and maintained after each use. Closed captioning is 

useful for DVDs.

.

b. Paper and Pen

Paper and pen should be available at all concession; information and ticket 

desks for people to write their questions down and/or receive answers. This 

method is not effective for more than a few words but is an important back up.

c. PDAs

Personal Digital Assistants (PDAs) are hand held devices that contain can 

display text. They are not effective as communication aids when there is a 

corresponding visual component that requires a person to look at a specific 

place, at a specific time such as at a theater, on an amusement park ride or while 

watching a video since it is impossible to read the text and look at the location 

simultaneously. Drivers are not permitted to read PDAs while driving for this 

reason. In addition, a person may need glasses when reading a PDA but not for 

distance. Changing back and forth is awkward, disruptive, frustrating and can 

cause eyestrain.

A PDA is preferable to a transcript because information can easily be searched 

on a PDA and it is less bulky than a large transcript. They are useful to 

communicate in one to one situations.

d. Transcript 

Transcripts are only effective when they are short, time is not of the essence, the 

communication is only oral with no corresponding visual component such as 

radio broadcasting or audio recording so the person is not required to look at a 
specific place at a specific time. Transcripts should be available in regular and 

large print. 

Unlike a PDA, a transcript’s information cannot easily be searched and the 

transcript can be cumbersome. 

C. Qualified Interpreters 

Qualified interpretation such as American Sign Language (ASL), oral, 

transliteration or cued speech needs to be offered in the format that an individual 

requires to achieve effective communication. ASL is a visual language with its 

own syntax and grammar that is quite different from spoken/written English 

language.

Qualified sign interpretation should be offered for scheduled and/or announced 

events and/or upon request with reasonable advance notice. Other forms of 

interpretation should also be available upon request. All interpreters should be 

certified. The qualified interpreter should ensure there is a back-up person in 

case of illness or emergency.

The majority of people with hearing loss do not use sign language. It should still 

be included as a component of access but it is not a solution for access. 

CONCLUSION

Access should cover the full spectrum of people with hearing loss. Three types of 

access should be offered whenever there is sound output (voice or audio) in 

order to have full and consistent access for the entire population of people who 

are deaf or hard of hearing:

1- Auditory- Assistive Listening System/Devices and

2- Visual- Captioning and

3- Qualified Interpreters

The Hearing Access Program, established in 2002, is the only organization 

dedicated to helping the world’s corporations, cultural and entertainment 

institutions, government agencies, and mass transit organizations improve their 

accessibility to people with hearing loss. This document was developed in 

consultation with organizations representing people with hearing loss.

Prepared and copyright protected by The Hearing Access Program, 4/19/09

Janice Schacter 212-988-8099 Jschacter@nyc.rr.com
EXHIBIT A: Hearing Loss Overview

POPULATION CHART

Hearing Loss Population = 36 Million1

Nature of Loss Potential Accommodation

 Mild to Moderate  Assistive Listening Device (Headset)

 Captioning

 Moderate to Severe  Assistive Listening Device (Neck Loop, 

Headset or Induction Loop System)

 Captioning

 Severe to Profound  Assistive Listening Device (Neck Loop or 

Induction Loop System)

 Captioning

 Qualified Interpreter

1. National Institute on Deafness and Other Communication Disorders (NIDCD)
EXHIBIT B: Technical Support

Technical Support for Assistive Listening Systems

The assistive listening device (“ALD”) distributors need to be trained to test the 

equipment before it is given to the patron. According to Josh Gendel, Director of 

Technology at The League for the Hard of Hearing, this can be accomplished by 

purchasing two inexpensive pieces of equipment from Radio Shack. The Radio 

Shack Mini-Audio Amplifier #277-1008 sells for approximately $11.99 and the 

Telephone Bug #44-533 sells for approximately $3.99. Placing the Bug next to 

the neck loop can quickly test the neck loop. Any sound the neck loop receives 

will be heard through the Mini-Audio Amplifier. 

The equipment should be tested to ensure it is working and also works in the 

attendee's seat prior to the start of the show. The signal should be strong 

enough, there should be sufficient number of IR emitters and the placement of 

the emitters should be checked. 

The pre-show sound test is accomplished by having a CD or MP3 player playing 

prior to the start of the show but run only through the assistive listening system. 

The audience cannot hear the sound unless they are wearing an ALD. Anyone 

whose seat is not receiving the signal or whose neck loop/headset is not working 

would be able to make arrangements prior to the start of the event. This 

alleviates disturbances during the event. The customer is satisfied rather than 

disappointed. 

This system is currently implemented at Disney World in Florida and in New York 

at most Broadway theaters and Avery Fischer Hall.

Prepared and copyright protected by The Hearing Access Program, 3/09

Janice Schacter 212-988-8099 Jschacter@nyc.rr.com
EXHIBIT C: Captioning Standards

Recommended Captioning Standards 

A. Potential Issues

1. Captioning must be monitored and reviewed.

2. The captioning standards used by companies are considered 

proprietary information so they vary by company. 

3. Service Level Agreements need to be included in contracts.

4. Some captioning companies may be failing to upgrade their technology 

and software. The result is consumers are receiving an inferior 

product. E.g. some companies use upper case and not mixed case 

because they have not upgraded their software. 

B. Captioning Formats

1. Pre-Recorded e.g. videos

a. Words

 No deletion of letters.

 No combining of words.

 Include all spoken words verbatim and don’t paraphrase.

 There should be a 100% accuracy rate.

b. Music

 Include the words for all music.

 Describe type of music when the music does not have 

words. E.g. dramatic music.

c. Sounds

 Identify all sounds unless obvious.

 Include “ums”. It is dangerous to allow a captioner to 

make editorial decisions.

d. Conversations

 Include background conversations.

 Identify the speaker when not visible.

 Identify the speaker with upper case and a colon. E.g. 

SUSAN: Yes, I want dinner versus using parentheticals.

 Place captioning in position of speaker’s location when 

there are multiple speakers on screen.

 No paraphrasing.

e. Caption Placement

Captions should not obscure information relevant to 

understanding or enjoying a program such as but not 

limited to covering people’s faces or descriptive banners. 
f. Captioning Style

 Use mixed case letters. Television screens now permit 

the adjustment of font size. Updated software no longer 

deletes the descenders of letters such as “g” or “q”. 

Therefore, upper case should not be used.

 Require Pop-up versus roll-up format. 

 Begin pop-up as the person speaking begins the first 

word of the pop-up.

g. Announcements and Previews

 Require the captioning of all announcements and 

previews.

 Include all captioning requirements and standards in all 

contracts with production companies and advertisers.

2. Live Events e.g. lectures

a. Mixed case should be required.

b. A Coordinator should assist the Captioner.

The coordinator can supply a list of words to the Captioner that are 

likely to be used during the event. The presenter should supply 

their presentation in advance or if not their exact presentation at 

least a list of topics, names and any points likely to be discussed. 

This allows the captioner to program the information into their 

computer and thus lessen the number of potential errors. 

c. Include the captioner’s name in the credits.

This can be either a real or fictitious company produced name. 

Giving ownership to the captioner will be an incentive to the 

captioner to work harder to ensure the words are spelled correctly.

C. Conclusion

Captioning is like any other product or service that is bid. The standards 

should be reviewed annually and as technology changes. Also, price 

should not be the sole determiner for obtaining a contract. Quality 

captioning cannot be obtained when captioning contracts are based on 

price alone.

Prepared and copyright protected by The Hearing Access Program, 10/10/07

Janice Schacter 212-988-8099 Jschacter@nyc.rr.com