Employers' Guide to Including Employees with Disabilities in Emergency Evacuation Plans

I. 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) has guidance that discusses what information employers are allowed to gather when developing an emergency evacuation plan.⁴ 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 accommodation ideas. In addition, employers should contact local fire, police, and HazMat departments to determine what services they can offer. Finally, employers can contact other resources such as JAN. JAN can provide specific accommodation ideas on a case by case basis. The following is an overview of frequently suggested accommodation ideas for emergency evacuation.⁵

⁴ Fact Sheet on Obtaining and Using Employee Medical Information as Part of Emergency Evacuation Procedures, http://www.eeoc.gov/facts/evacuation.html.

⁵ For information on products visit JAN’s Searchable Online Accommodation Resource (http://AskJAN.org/soar).

General Accommodations:

• Employers should have emergency alarms and signs showing the emergency exit routes. These alarms and signs should be accessible and maintained in proper working order.

• Employers may want to implement a "buddy system" for all employees. A 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 Americans with Disabilities Act Accessibility Guidelines (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 respirator masks.

  • Locate information on TTYs from JAN’s SOAR at http://AskJAN.org/cgi-win/OrgQuery.exe?Hea84.

  • Locate information on respirators from JAN’s SOAR at http://AskJAN.org/cgi-win/OrgQuery.exe?Sol523.

Motor Impairments:

• 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.

  • Locate information on emergency evacuation devices from JAN’s SOAR at: http://AskJAN.org/cgi-win/OrgQuery.exe?Sol193.

• Employers should remove any physical barriers (boxes, supplies, furniture) to insure a barrier-free route of travel out of the building.

• 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:

• 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 ADAAG specifically addresses alarms.

• 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.

  • Locate information on paging devices from JAN's SOAR at http://AskJAN.org/cgi-win/OrgQuery.exe?Sol493.

  • Locate information on alerting devices from JAN’s SOAR at http://AskJAN.org/cgi-win/OrgQuery.exe?Sol419.

• Employers should install tactile signage and maps for employees with vision impairments. Braille signage, audible directional signage, and pedestrian systems are also available. These products may benefit other people who must navigate smoke-filled exit routes.

  • Locate information on tactile signage from JAN’s SOAR at http://AskJAN.org/cgi-win/OrgQuery.exe?Sol231.

  • Locate information on tactile graphics and maps from JAN’s SOAR at http://AskJAN.org/cgi-win/OrgQuery.exe?Sol401.

• Employers may also want to provide alpha-numeric pagers or other communication devices to individuals with speech impairments so they can communicate with personnel in an emergency.

  • Locate information on communication aids from JAN’s SOAR at http://AskJAN.org/cgi-win/OrgQuery.exe?Sol267.

Cognitive/Psychiatric Impairments:

• Employers should consider ways of communicating with people who have cognitive impairments. For example, some individuals may benefit from pictures of buddies, 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.

After effective accommodations are chosen, employers should decide who will be involved in implementing the evacuation plan, commit the plan to writing and share it with employees for feedback, practice the plan to make sure it works, and modify the plan as needed.