Evacuation Preparedness

Providing for the safe evacuation of employees with disabilities is a critical part of an organization's safety program.

IN the past 30 years, the United States has enacted several laws addressing workplace safety, including specific regulations for air, fire, construction, and occupational safety. Despite these advances, there is currently no federal law requiring that employers have emergency evacuation plans.

However, recent events such as the Oklahoma City bombing and 9/11 have shown that planning in advance for emergency evacuation can dramatically increase the survival rate of employees during emergencies.

Advanced planning can be especially important for employees with disabilities who may not be able to descend steps independently, detect auditory alarms, or recognize dangers created by an emergency. This article provides information to help employers manage the safety of employees with disabilities during emergency evacuation.

Existing Guidelines
Although there is currently no comprehensive federal law that requires employers in general to have emergency evacuation plans, federal law does require that some employers have such plans. For example, employers in certain industries may have obligations to develop emergency evacuation plans under the Occupational Safety and Health Act (OSH Act) or under state and local law. The OSH Act does not require that all employers have emergency action plans; however, the act does require that employers from particular industries (e.g., metal, chemical, and grain handling facilities) have emergency action plans (1910.38).

In addition, employers may have to consider emergency evacuation of employees with disabilities under the Americans with Disabilities Act of 1990 (ADA). Title I of the ADA applies to private employers with 15 or more employees, state and local government employers, employment agencies, labor unions, and joint labor-management committees (29 CFR Part 1630). Federal employers are covered by the Rehabilitation Act of 1973 (29 CFR Part 1614). Both laws prohibit employers from discriminating against people with disabilities in regard to any employment practices or terms, conditions, and privileges of employment. Though employers are not required to have emergency evacuation plans under the ADA, if employers covered by the ADA opt to have such plans they are required to include people with disabilities. Further, employers who do not have emergency evacuation plans may nonetheless have to address emergency evacuation for employees with disabilities as a reasonable accommodation. Title I of the ADA requires employers to provide reasonable accommodations to the known limitations of employees with disabilities.

Safely Evacuating Employees with Disabilities
Safety personnel can design their emergency evacuation plan to include employees with disabilities using the following three steps:

Step 1: Plan Development
The first step for including employees with disabilities in emergency evacuation plans is plan development. Plan development begins with identifying accommodation needs. One of the best ways to identify accommodation needs is to ask employees whether they have limitations that might interfere with safe emergency evacuation. The Equal Employment Opportunity Commission (EEOC), the enforcing agency for Title I of the ADA, recently issued guidance that discusses what information employers are allowed to gather when developing an emergency evacuation plan.2 According to this guidance, there are three ways that an employer may obtain information:

* After making a job offer, but before employment begins, an employer may ask all individuals whether they will need assistance during an emergency.

* An employer also may periodically survey all of its current employees to determine whether they will require assistance in an emergency, as long as the employer makes it clear that self-identification is voluntary and explains the purpose for requesting the information.

* Finally, whether an employer periodically surveys all employees or not, it may ask employees with known disabilities if they will require assistance in the event of an emergency. An employer should not assume, however, that everyone with an obvious disability will need assistance during an evacuation. For example, many individuals who are blind may prefer to walk down stairs unassisted. People with disabilities are generally in the best position to assess their particular needs.

The ADA requires employers to keep all medical information confidential. However, first aid and safety personnel may be informed, when appropriate, if the disability might require emergency treatment or if any specific procedures are needed for emergency evacuations.

In addition to requesting information from employees, employers might want to hold mock evacuation drills to help identify needs that employees are unaware of; conduct hazard analyses to help identify hazards specific to the workplace; develop a method to identify visitors with special needs; and contact local fire, police, and hazmat departments for guidance.

Once accommodation needs have been identified, the employer should choose effective accommodation options. Often, employees with disabilities are a good resource for ideas. In addition, employers can contact resources that specialize in providing accommodation ideas.

Many of the accommodations and products mentioned in this article may benefit all employees during evacuation; however, when developing an evacuation plan it is important to consider that employees with motor, sensory, cognitive, psychiatric, or respiratory impairments may have specific accommodation needs.

Motor Impairments. Motor impairments are those that limit an individual in body movement. Multiple sclerosis, arthritis, cerebral palsy, quadriplegia, stroke, and back, knee, foot, and arm injuries are a few examples of motor impairments. The following accommodation ideas may benefit employees with motor impairments when evacuating:

* To evacuate individuals with motor impairments, employers can purchase evacuation devices. These devices help move people with motor impairments down the stairs or across rough terrain. If evacuation devices are used, personnel should be trained to operate and maintain them.
* Employers should remove any physical barriers (boxes, supplies, furniture) to ensure a barrier-free route of travel out of the building, especially for those employees who use a mobility aid such as a cane, scooter, or wheelchair.
* For individuals who use wheelchairs, employers may want to provide heavy gloves to protect individuals' hands from debris when pushing their manual wheelchairs, a patch kit to repair flat tires, and extra batteries for those who use motorized wheelchairs or scooters. Arrangements should also be made to make wheelchairs available after evacuation.

Sensory Impairments. Sensory impairments are those that limit an individual in one of the five senses. Vision, hearing, and speech loss are examples of sensory impairments. The following accommodation ideas may benefit employees with sensory impairments when evacuating:

* Employers should install lighted fire strobes and other visual or vibrating alerting devices to supplement audible alarms. Lighted strobes should not exceed five flashes per second due to risk of triggering seizures in some individuals. Section 4.28 of the Americans with Disabilities Act Accessibility Guidelines (ADAAG) specifically addresses alarm requirements.
* Employers may want to provide alerting devices, vibrating paging devices, wireless communicators, or two-way paging systems to alert individuals with hearing impairments of the need to evacuate.
* Employers should install tactile signage and maps for employees with vision impairments. Braille signage, audible directional signage, and pedestrian systems also are available.
* Employers may want to provide alpha-numeric pagers or other communication devices to individuals with speech impairments so they can communicate with others in an emergency.

Cognitive and Psychiatric Impairments. Cognitive and psychiatric impairments are those that limit an individual in neurological functioning. Mental retardation and traumatic brain injury are examples of cognitive impairments. Post-traumatic stress disorder (PTSD) and depression are examples of psychiatric impairments. The following accommodation ideas may benefit employees with cognitive and psychiatric impairments when evacuating:

* Employers should consider ways of communicating with people who have cognitive impairments. For example, some individuals may benefit from pictures of co-workers and emergency personnel, color coding of escape doors and areas of rescue assistance, and information on tape or CD-ROM.
* Employers should consider the effects of training for emergency evacuation. Some individuals with psychiatric impairments benefit from frequent emergency drills, but for others, practice drills may trigger anxiety. Notifying employees of upcoming practice drills and allowing them to opt out of participation may be a reasonable accommodation. In this case, another form of training for emergency evacuation procedures may be needed, for example providing detailed written instructions.

Respiratory Impairments. Respiratory impairments are those that affect the respiratory system and result in labored breathing, asthma attacks, and heightened sensitivity to ordinary substances (e.g., latex, chemicals, cleaners). Allergies, asthma, chemical sensitivity, chronic obstructive pulmonary disease, and tuberculosis are examples. The following accommodation ideas may benefit employees with respiratory impairments when evacuating:

* Employees with respiratory impairments may have limitations exacerbated by smoke, dust, fumes, chemicals, and other odors and may benefit from products such as emergency evacuation hoods, masks, and respirators.
* Employees with respiratory impairments may have breathing difficulties when walking distances and therefore have problems descending stairs. Employers may want to consider purchasing evacuation devices, relocating workstations, and working with employees to ensure availability of adequate medical supplies.

General Accommodations. Some accommodations can benefit all employees, including those with temporary limitations related to surgery, pregnancy, or injury. Two of the most important are the group buddy system and areas of rescue assistance:

* Employers may want to implement a group buddy system for all employees. A group buddy system involves employees working in teams so they can locate and assist each other in emergencies.
* Employers may want to designate areas of rescue assistance. Section 4.3.11 of the ADAAG specifically addresses areas of rescue assistance. If these areas do not have escape routes, they should have: 1) an operating phone, cell phone, TTY, and two-way radio so that emergency services can be contacted; 2) a closing door; 3) supplies that enable individuals to block smoke from entering the room from under the door; 4) a window and something to write with (lipstick, marker) or a "help" sign to alert rescuers that people are in this location; and 5) respirator masks.
After effective accommodations are chosen, employers should decide who will be involved in implementing the evacuation plan, commit the plan to writing, share it with employees for feedback, practice the plan to make sure it works, and modify the plan as needed.

Step 2: Plan Implementation
The second step for including employees with disabilities in emergency evacuation plans is plan implementation. After the final evacuation plan is written, a copy should be distributed to all employees and key personnel in accessible formats.6 In addition, an evacuation drill should be performed to make sure all employees are familiar with the plan. Finally, the plan should be integrated into the standard operating procedures.

Step 3: Plan Maintenance
The final step for including employees with disabilities in emergency evacuation plans is plan maintenance. To ensure that accommodations continue to be effective, the evacuation plan should be practiced and accommodations updated periodically. In addition, a system for reporting new hazards and accommodation needs should be developed, a relationship with local emergency departments should be maintained, and new employees should be made aware of the plan. Finally, all accommodation equipment used in emergency evacuation should be inspected and maintained in proper working order.

Conclusion
Whether or not the ADA or OSH Act require that employers design inclusive emergency evacuation plans, with proper plan development, plan implementation, and plan maintenance, employers can effectively include employees with disabilities. Though accommodations for employees should be made on a case-by-case basis, whatever the disability, it is important for employees, managers, safety specialists, and emergency response personnel to work together in implementing the evacuation plan and promoting a safe workplace.

References
1. Equal Employment Opportunity Commission. (2002). Enforcement Guidance: Reasonable Accommodation and Undue Hardship Under the Americans with Disabilities Act. Retrieved June 10, 2004, from http://www.eeoc.gov/policy/docs/accommodation.html.
2. Equal Employment Opportunity Commission. (2001). Fact Sheet on Obtaining and Using Employee Medical Information as Part of Emergency Evacuation Procedures. Retrieved June 10, 2004, http://www.eeoc.gov/facts/evacuation.html.
3. Equal Employment Opportunity Commission (2000). Enforcement Guidance: Disability-Related Inquiries and Medical Examinations of Employees under the Americans with Disabilities Act (ADA). Retrieved June 10, 2004, from http://www.eeoc.gov/policy/docs/guidance-inquiries.html.
4. The Job Accommodation Network (http://www.jan.wvu.edu), a free service of the U.S. Department of Labor, is a free consulting service designed to increase the employability of people with disabilities by: 1) providing individualized worksite accommodations solutions, 2) providing technical assistance regarding the ADA and other disability related legislation, and 3) educating callers about self-employment options.
5. Access Board, "Americans with Disabilities Act Accessibility Guidelines (ADAAG)" http://www.access-board.gov/adaag/html/adaag.htm.
6. Sutton, J. (2002). A Guide to Making Documents Accessible to People Who Are Blind or Visually Impaired. Retrieved June 10, 2004, from http://acb.org/accessible-formats.html.
7. For additional information on emergency evacuation of people with disabilities, see: Office of Disability Employment Policy, United States Department of Labor (2004). Emergency Preparedness for People with Disabilities. Retrieved June 14, 2004, from http://www.dol.gov/odep/pubs/ep/index.htm and Job Accommodation Network (2004). Emergency Evacuation Procedures for Employees with Disabilities. Retrieved June 14, 2004, from http://www.jan.wvu.edu/media/emergency.html.

This article originally appeared in the September 2004 issue of Occupational Health & Safety.

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