Persons with Disabilities: A Heightened Awareness
By Lawrence G. Perry
One of the many effects of the Americans with Disabilities Act of 1990 (ADA) was an increased awareness of, Oand attention to, the special needs of some persons with disabilities in an emergency evacuation situation. Two areas of the ADAs Title III regulations address this issue: provisions for providing areas of rescue assistance, and a general provision addressing all policies and procedures of public accommodations.
Areas of Rescue Assistance
The ADAs Accessibility Guidelines (ADAAG) require that areas of rescue assistance be provided wherever a required means of egress (an exit route) is inaccessible. This provision applies only to newly constructed, non-sprinkler buildings. An area of rescue assistance is a compartment where persons unable to use the stairs would be directed to go to await further instructions or assistance in evacuation. This area must be in a fire-rated enclosure, have direct access to an exit, and contain an emergency communication system.
A research project conducted by the National Institute of Standards and Technology (NIST) raises some major concerns regarding this concept. Research on fire growth and evacuation speeds of persons with varying levels of mobility indicated that in a non-sprinklers building, persons on the floor where a fire originated might be overcome by smoke before reaching the area of rescue assistance. It was also shown that the area of rescue assistance might remain safe only for a matter of minutes, depending upon a wide variety of factors, including pressure differentials, exterior temperature and wind speed, and the nature of the fire. This study indicates the need to further explore this entire concept before embracing it as the solution. One positive note: this study clearly indicated that a functioning sprinkler system provides a more than adequate safety factor, allowing time for evacuation of all building occupants.
Nondiscriminatory Policies and Procedures
The Title III regulations do not require that emergency plans or evacuation plans be developed; however, where such a plan exists, it is a policy or procedure of the facility. The Justice Department Title III regulations require that reasonable modifications be made to ensure that persons with disabilities are offered the same services as other persons. Therefore, where an emergency plan exists for the general building population, it must include provisions for persons with disabilities.
Two separate groups of individuals should be addressed by the emergency plan: the known population of persons needing assistance (typically the employes in the building), and the potential unknown population (including visitors, customers, and clients). The strategies for providing assistance will depend on the nature of the individuals disability, the capabilities of any in-house emergency team, the capabilities (including response time) of local authorities, the building configuration and systems, and the nature of the emergency. Each of these factors must be considered thoroughly when developing the plan.
Determining the needs of specific individuals should be handled very carefully to avoid stereotypical assumptions. Requiring someone with a visible mobility impairment to follow a different evacuation procedure than other individuals would violate the ADA, unless it can be proven that a threat to the health or safety of others would result. Rather than making assumptions about individual capabilities, a preferred approach would be to ask each building occupant if they would require any special assistance in an emergency situation. An effort can then be made to provide the type of assistance requested. This method works for the known building population; unfortunately, the unknown population cannot typically be questioned in advance.
Where an internal emergency team is provided, they should be trained to provide the widest type of assistance possible. This may include training to assist persons with hearing impairments who are unable to hear public address announcements, assist persons with vision impairments to the exit, operation of the elevators under Phase II service (where permitted by local authorities), use of stair descent chairs for evacuating persons with mobility impairments, and as a last resort, training in methods of various carry methods for persons in imminent danger. Local authorities should be consulted to determine the level of internal performance that would be expected by, or permitted by, the responding authorities.
In addition to satisfying an obligation under the ADA, addressing the potential needs of persons with disabilities in the emergency planning process will increase the overall effectiveness of the emergency plan. Proper advance planning will permit quick response to any emergency situation, thereby reducing the threat both to those persons requiring assistance, and those assigned to provide the assistance.
This article, a sidebar to Lawrence Perry's "Preparing for an Emergency," was adapted from V7#4.
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