ADA Best Practices Tool Kit for State and Local Governments

Chapter 7 Emergency Management Under Title II of the ADA

In this Chapter, you will learn how to make emergency management programs, services, and activities accessible to everyone, including people with disabilities. Chapter 7 answers the following questions:

• What does emergency management cover?

• How does the ADA apply to emergency management?

• What are some of the common problems faced by people with disabilities in accessing emergency- and disaster-related services, programs, activities, and facilities?

• What are some of the steps that state and local governments can take to make emergency- and disaster-related services, programs, activities, and facilities accessible to people with disabilities? 

A. ADA Basics for Emergency Management

One of the primary responsibilities of state and local governments is to protect residents and visitors from harm, including assistance in preparing for, responding to, and recovering from emergencies and disasters. State and local governments must comply with Title II of the ADA in the emergency- and disaster-related programs, services, and activities they provide.¹ This requirement applies to programs, services, and activities provided directly by state and local governments as well as those provided through third parties, such as the American Red Cross, private nonprofit organizations, and religious entities.² Under Title II of the ADA, emergency programs, services, activities, and facilities must be accessible to people with disabilities ³ and generally may not use eligibility criteria that screen out or tend to screen out people with disabilities.⁴ The ADA also requires making reasonable modifications to policies, practices, and procedures when necessary to avoid discrimination against a person with a disability⁵ and taking the steps necessary to ensure effective communication with people with disabilities.⁶ The ADA generally does not require state or local emergency management programs to take actions that would fundamentally alter the nature of a program, service, or activity or impose undue financial and administrative burdens.⁷

B. What is Emergency Management?

Emergency management is wide-ranging. It includes all programs, services, and
activities related to emergencies and disasters, including:

• Preparation – advance planning for emergencies and disasters;

• Testing of Preparedness – staging emergency simulations and other approaches to testing the effectiveness of emergency preparedness;

• Notification – alerting the public to emergencies and disasters and to available programs, services, and activities;

• Community Evacuation and Transportation;

• Emergency Shelter Programs;

• Temporary Lodging and Housing;

• Social Services and Emergency- and Disaster-Related Benefit Programs;

• Emergency Medical Care and Services;

• Relocation Programs, Activities, and Services;

• Transition and Transportation Back to the Community Following an Emergency or Disaster;

• Emergency and Disaster Recovery Programs, Services, and Activities; and

• Remediation of Damage Caused by Emergencies and Disasters– repairing and rebuilding damaged facilities, removing debris, and relocation and re-introduction of state and local government programs, services, and activities following an emergency or disaster.

C. Preparation – Advance Planning for Emergencies and Disasters

An emergency management plan is the all-important first step in ensuring an effective response to emergencies and disasters. Public officials, specialists from organizations such as the American Red Cross, and community members should work together to develop a comprehensive plan to prepare for emergencies. One good way to test your emergency management plan is to enlist people with disabilities to role-play during emergency simulations. Seeking and using input from people with a variety of disabilities, and organizations with expertise on disability issues, will help ensure that your emergency planning and preparedness meet the access needs of people with disabilities in your community with respect to all phases of emergency management.

D. Notification – Alerting the Public to an Emergency

Officials must act quickly to alert the public to an impending emergency situation. But many traditional emergency notification methods are not accessible to people with disabilities. People who are deaf will not hear radio, television, sirens, or other audible alerts. Those who are blind or who have low vision may not be aware of visual cues, such as flashing lights. State and local governments need to use warning methods that ensure all residents and visitors will have the information necessary to make sound decisions and take appropriate, responsible action.

Often, using a combination of notification methods will be more effective than relying on one method alone. For instance, combining visual and audible alerts will reach a greater audience than either method would alone. Auto-dialed text telephone (TTY) messages to pre-registered individuals who are deaf or hard of hearing, text messaging, emails, and other innovative uses of technology may be incorporated into such procedures. For announcements by government officials on local television stations, providing qualified sign language interpreters and open captioning will ensure that all people tuning in are able to access the information provided. The emergency management plan should identify the steps that will be taken and the resources that will be used to ensure that emergency notifications will be accessible to all.

E. Community Evacuation and Transportation

In an emergency, people with disabilities may face a variety of challenges in evacuating to safety. A person with a mobility disability may need assistance leaving a building without a working elevator. Individuals who are blind or who have low vision may no longer be able to independently use traditional orientation and navigation methods. A deaf person may be trapped somewhere unable to communicate with anyone because the only available communication device relies on voice. State and local governments need to establish procedures to ensure that people with disabilities can evacuate the area of an emergency in a variety of conditions, with assistance when it is needed.

One step that can significantly increase the effectiveness of your planning process is to create a voluntary, confidential registry of persons with disabilities who may need individualized notification or evacuation assistance. Setting up a voluntary registry requires that procedures be implemented to ensure that the registry is voluntary, confidentiality is protected, and information is updated as needed.

Both public and private transportation may be disrupted due to overcrowding, because of blocked streets and sidewalks, or because the transit system is not functioning at all. The movement of people during an evacuation is critical, but many people, because of their disabilities, cannot drive or use traditional, inaccessible transportation. Thus, emergency plans must identify accessible forms of transportation (i.e., vehicles equipped with wheelchair lifts) available to help evacuate people with disabilities. For instance, some communities have used lift-equipped school buses, transit buses, or paratransit vehicles to evacuate people who use wheelchairs or scooters. Some people with disabilities will be able to reach mass evacuation pick-up locations independently, while others may be unable to leave their homes without assistance. Evacuation and emergency transportation plans should address the evacuation-related needs of people with disabilities.

F. Emergency Shelter Programs

When emergencies arise, communities often provide residents and visitors with safe refuge in temporary shelters. Shelters are sometimes operated by government entities themselves. More often, they are operated by a third party. Regardless of who operates a shelter, the ADA generally requires shelter operations to be conducted in a way that offers people with disabilities the same benefits – e.g., safety, comfort, food, medical care, the support of family and friends – provided to people without disabilities. Because sheltering programs are critical to ensuring the safety of people with disabilities in emergencies and disasters, ADA requirements for sheltering are discussed in greater detail in two stand-alone technical assistance documents that state and local governments can provide to shelter operators to assist them in planning to meet the needs of people with disabilities in the shelter environment. While these technical assistance documents do not address all ADA compliance issues that may arise in emergency shelters, they address a number of the most common access problems.

The first of these technical assistance documents – “The ADA and Emergency Shelters: Access for All in Emergencies and Disasters” is in Addendum 2 to this Chapter at www.ada.gov/pcatoolkit/chap7shelterprog.htm. It discusses the ADA’s nondiscrimination requirements for shelter programs. The second technical assistance document – “ADA Checklist for Emergency Shelters” is in Addendum 3 to this Chapter at www.ada.gov/pcatoolkit/chap7shelterchk.htm.The Checklist includes two assessment tools to help state and local governments and emergency shelter operators ensure that emergency shelters provide access to all: (1) a preliminary survey tool that will help in deciding if a facility has the accessibility characteristics that make it a good candidate for a potential emergency shelter, and (2) a more detailed checklist that will help identify the most common architectural barriers to access for people with disabilities found at emergency shelters.

G. Access to Social Services, Temporary Lodging or Housing, and Other Benefit Programs

State and local governments often provide social services and other benefit programs to assist people harmed by emergencies and disasters. These programs need to be accessible to all, including people with disabilities. Following are some important points to remember:

• Application procedures should not limit access by people with disabilities. For example, programs that require people to apply by telephone may exclude people who are deaf or hard of hearing. Inaccessible web-based application procedures and printed application forms may exclude people who are blind or have low vision. Programs that require in-person applications may exclude people who, because of their disabilities, are unable to leave shelters or their homes. Procedures that allow people to apply in different ways – providing auxiliary aids and services and reasonable modifications to application procedures when people with disabilities need them – is the most effective way to ensure equal access. 

• Information about social services and other benefit programs should be available in formats that people with communication disabilities can use. For example, during emergencies, announcements about the availability of social services and other benefits are often made orally, whether in radio and television broadcasts or in public announcements at emergency shelters. People who are deaf or hard of hearing may not receive information about these programs unless television broadcasts have open captions, materials describing the programs are posted on websites, or public announcements are translated by a sign language interpreter or posted on shelter bulletin boards. 

• Crisis counseling services will not be accessible to people who are deaf or hard of hearing unless appropriate auxiliary aids and services are provided. In addition, these services need to be offered in physically accessible locations so people with mobility disabilities can use them. 

• Temporary lodging or housing programs will not be accessible to people with mobility disabilities or people who are deaf or hard of hearing unless accessible hotel rooms or accessible temporary housing is available. People with disabilities may be unable to utilize temporary lodging or housing programs without assistance in locating a hotel room or housing that meets their disability-related needs, or without accessible transportation. To prepare for the potential need for temporary housing, identify in your emergency response plan available physically accessible short-term housing, as well as housing with appropriate communication devices, such as TTY's. Temporary accessible housing (such as nearby accessible hotel rooms) may be used if people with disabilities cannot immediately return home after a disaster.

H. Repairing and Rebuilding

Emergencies and disasters often damage state and local government facilities. In the recovery stage of emergency management, state and local governments often make alterations to facilities to repair such damage, construct facilities to replace those that were destroyed or extensively damaged, or move government programs, services, and activities from damaged facilities to other locations. When constructing new or replacement facilities and repairing damaged facilities, state and local governments must comply with the accessibility requirements of Title II of the ADA. They may choose from two design standards for new construction and alterations – either the Uniform Federal Accessibility Standards (UFAS) or the ADA Standards for Accessible Design (ADA Standards). If the ADA Standards are chosen, public entities are not entitled to the elevator exemption contained in § 4.1.3(5) of the Standards. If the building was newly constructed or altered after the ADA went into effect, then the design standard used at that time must be followed for the rebuilding. Alterations to facilities must not decrease accessibility.

State or local government facilities constructed after January 26, 1992 and alterations to such facilities must comply with the new construction requirements of Title II of the ADA.⁸ Alterations to facilities constructed before the ADA became effective, must comply with Title II’s requirements for alterations to existing facilities.⁹ Under the ADA Standards, alterations to primary function areas of existing facilities trigger a "path of travel" requirement – i.e., a requirement to make the path of travel from the entrance to the altered area accessible, including telephones, restrooms, and drinking fountains serving the altered area.¹⁰ Primary function areas are those where major activities take place. But a public entity is not required to spend more than 20 percent of the cost of the original alteration on making the path of travel accessible, even if this cost limitation results in less than full accessibility. Under UFAS, if an existing facility undergoes a “substantial alteration,” the public entity must provide (1) an accessible route from public transportation, parking, streets, and sidewalks to all accessible parts of the building; (2) an accessible entrance; and (3) accessible restrooms.¹¹ A “substantial alteration” for purposes of UFAS is where the total cost of all alterations in a 12-month period amounts to 50 percent or more of the value of the building.

When moving programs from a damaged facility to another location, state and local governments must ensure that the programs remain accessible to people with disabilities.¹² This requirement applies whether the program is relocated permanently or temporarily.

I. Steps to Ensure Access for All in Emergencies and Disasters

Here are some steps you can take now to ensure that emergency management programs, services, and activities are accessible to everyone, including people with disabilities.

• Advance Planning: On an on-going basis, seek and use input from people with different types of disabilities (i.e., mobility, vision, hearing, cognitive, psychiatric, and other disabilities) regarding all phases of your emergency management plan, including: 

  • preparation;

  • notification;

  • evacuation and transportation;

  • sheltering;

  • first aid and medical services;

  • temporary lodging and housing;

  • transition back to the community;

  • clean up; and

  • other emergency- and disaster-related programs, services, and activities. 

• Voluntary Registry: Create voluntary, confidential registries of persons with disabilities who may need individualized evacuation assistance, transportation, and/or notification. Establish procedures to ensure the registry’s voluntariness, guarantee confidentiality controls, and develop a process to update the registry when needed. Publicize the availability of the registry. 

• Notification: If you use emergency warning systems such as sirens or other audible alerts, provide ways to provide people who are deaf or hard of hearing prompt notice of an impending disaster. Combine visual and audible alerts to reach a greater audience than either method would by itself. Consider using telephone calls, auto-dialed TTY (teletypewriter) messages, text messaging, emails, and even direct door-to-door contact with pre-registered individuals. Also, consider using open captioning on local TV stations, and dispatching qualified sign language interpreters to assist in broadcasting emergency information provided to the public. 

• Ensure Access for People with Disabilities Who Use Service Animals: Modify “no pets” policies to enable people with disabilities to evacuate, use emergency transportation, stay in shelters, and participate in all emergency- and disaster-related programs together with their service animals. Teach first responders and the employees, volunteers, and third parties who perform emergency- and disaster-related functions that people with disabilities should not be separated from their service animals even in places where pets are typically not allowed. Only two questions may be asked to determine if an animal is a service animal: (1) Is this animal a service animal required because of a disability? (2) What tasks or work has this animal been trained to perform? If the answers to these questions reveal that an animal has been trained to provide assistance to a person with a disability, that person should be able to access services, programs, activities, and facilities while accompanied by his service animal. Service animals do not require certification, identification cards or licenses, special equipment, or professional training. 

• Evacuation and Return Home: Adopt policies to ensure that your community evacuation and recovery plans enable people with disabilities, including those who have mobility, vision, hearing, cognitive, and psychiatric disabilities to safely self-evacuate, to be evacuated by others, and to return home. 

• Transportation: Some people with disabilities will need accessible transportation. Identify accessible modes of transportation, such as wheelchair lift-equipped school buses, transit buses, paratransit vehicles, and taxis that will be available to evacuate people with disabilities during an emergency. Ensure that transportation plans address people with disabilities’ needs to transport mobility aids, such as wheelchairs or scooters, oxygen tanks or other medical equipment, and service animals. 

• Shelters – Policies: Review your sheltering program to ensure that rules, policies, and procedures comply with ADA requirements. Use the Department of Justice’s technical assistance publication, “The ADA and Emergency Shelters: Access for All in Emergencies and Disasters, ” which is located in Addendum 2 to this Chapter and at www.ada.gov/pcatoolkit/chap7shelterprog.htm All shelter operators need to know the ADA requirements discussed in this Chapter, including the Addenda. If your sheltering program is operated through any third parties, provide them with a copy of these materials. 

• Shelters – Physical Accessibility: Survey your community’s current shelters for barriers to access for persons with disabilities. Use the Department of Justice’s “ADA Checklist for Emergency Shelters,” which is located in Addendum 3 to this Chapter, and at www.ada.gov/pcatoolkit/chap7shelterchk.htm

  • If you find barriers to access, remove the barriers or work with the facility’s owner to remove them. 

  • If barriers remain, find another nearby facility that is or can be made accessible. In identifying new or alternative shelter locations, use the preliminary survey tool which will help you determine if a facility is a good candidate for a potential emergency shelter. 

  • Until all emergency shelters have accessible parking, exterior routes, entrances, interior routes to the shelter area, sleeping and recreational areas, dining facilities, and toilet/bathing rooms, identify and widely publicize to the public, including persons with disabilities and organizations with expertise on disability issues, the locations of the most accessible emergency shelters and the accessible features they provide. 

  • Adopt procedures to ensure that shelter staff and volunteers maintain accessible routes and minimize protruding objects. 

• Social Services and Other Benefit Programs: Review your social service and other emergency- and disaster-related programs, services, and activities to ensure that people with disabilities have an equal opportunity to apply for and benefit from them. 

  • Ensure that eligibility criteria do not unnecessarily screen out or tend to screen out people with disabilities – e.g., requiring a driver’s licence excludes people who, because of their disability, cannot drive; requiring a telephone number excludes many people who are deaf or have a speech disability.

  • Ensure that architectural barriers do not deny access to people with mobility disabilities. 

  • Ensure that communication barriers do not deny access to people with disabilities. Establish policies and procedures to provide the auxiliary aids and services needed to communicate effectively with people with disabilities, giving primary consideration to the auxiliary aids and services requested by an individual with a disability. 

  • Provide training so that employees and volunteers who staff these programs understand their ADA obligation to provide effective communication and make reasonable modifications to policies, practices, and procedures when necessary to avoid discrimination against people with disabilities. 

• Incident Management: During emergencies and disasters, first responders, emergency transportation drivers, and shelter staff often have questions about how to handle issues that arise. When these issues involve people with disabilities, ADA obligations are often implicated. Consider appointing one or more persons knowledgeable on ADA requirements and disability issues (ADA Incident Managers) who will be on-call throughout emergencies and disasters to provide quick guidance on issues that may involve the ADA and/or a person with a disability. 

• Recovery: During disasters, government facilities can be damaged or destroyed. When altering or rebuilding after a disaster, ensure that alterations to facilities and the design and construction of new or replacement facilities comply with all applicable federal accessibility requirements.

Chapter 7 Addendum 1: Title II Checklist (Emergency Management)

PURPOSE OF THIS CHECKLIST: This checklist is designed for use as a preliminary assessment of your emergency management programs, policies, procedures, and shelter facilities. The goal is to look at your programs, policies, procedures, and shelter facilities to see if there are any potential ADA problems.

MATERIALS AND INFORMATION NEEDED: To assess the accessibility of your emergency management programs, policies, procedures, and shelter facilities, you will need:

• a copy of your emergency planning and preparedness documents;

• a copy of materials used to train employees and volunteers who perform emergency management functions;

• a copy of materials distributed to the public on emergency preparedness and emergency management and the procedures used for distribution of such materials;

• a copy of any current contracts or other documents reflecting your relationship with other public entities and/or private organizations to provide any services related to emergency management, such as planning, prevention, preparedness, evacuation, transportation, sheltering, medical services, lodging, housing, response, social services, recovery, clean-up, and remediation;

• a list of notification methods, procedures, materials, and equipment used to communicate information about emergencies to the public, including people with disabilities (in particular, communication with people who are deaf or hard of hearing and people who are blind or have low vision);

• a copy of your policies and procedures on emergency notification, evacuation, transportation, emergency shelters, emergency food and medical supplies, temporary lodging and housing, medical services, social services, and other emergency management services;

• a list of accessible transportation and lodging resources that can be used in an emergency for evacuation, return home following an evacuation, and/or temporary lodging and housing;

• a list of the facilities designated as emergency shelters, including mass care shelters, special needs shelters, and medical shelters;

• eligibility criteria, if any, for participation in emergency management programs, services, and activities, including mass care, special needs, and medical shelters; and

• copies of the “ADA Checklist for Emergency Shelters,” located in Addendum 3 to this Chapter and at , and survey tools (metal tape measure, electronic (digital) level, pressure gauge, and digital camera).

General Emergency Management Policies and Procedures

1.   If you have a contract or other arrangement with any third party entities, such as the American Red Cross or another local government, to provide emergency planning and/or emergency management or response services, does your contract or other documentation of your arrangement contain policies and procedures to ensure that the third party entities comply with ADA requirements, as outlined in Chapter 7 of this Tool Kit, including Addenda 2 and 3?

  ◼ Yes

  ◼  No

  ◼  N/A

2.   Do you have written procedures to ensure that you regularly seek and use input from persons with a variety of disabilities and organizations with expertise in disability issues in all phases of your emergency planning, such as those addressing preparation, notification, evacuation, transportation, sheltering, medical and social services, temporary lodging and/or housing, clean-up, and remediation?

  ◼  Yes

  ◼  No

3.   Do you seek input and participation from people with disabilities and organizations with expertise on disability issues when you stage emergency simulations and otherwise test your preparedness?

  ◼  Yes

  ◼  No

Planning for Emergency Notification and Evacuation

This section helps you identify potential ADA-related problems in your plans for the emergency notification and evacuation of people with disabilities. To ensure an accurate assessment of ADA compliance, this checklist should be completed with the input and assistance of those employees and contractors who are involved in your entity’s emergency planning, notification, and evacuation programs, services, and activities.

4.   For planning purposes, have you determined the extent to which, in an emergency or disaster, people with disabilities who reside or visit your community are likely to need individualized notification, evacuation assistance, and/or transportation, including accessible transportation?

  ◼ Yes

  ◼  No

5.    Has your emergency planning identified the resources you will use to meet the needs of individuals with disabilities who require individualized notification, evacuation assistance, and/or transportation, including accessible transportation?

  ◼  Yes

  ◼  No

6.    If your emergency warning systems use sirens or other audible alerts, do you have written procedures to ensure the use of a combination of methods to provide prompt notification of emergencies to persons who are deaf or hard of hearing? (Note: Examples of methods that may be effective in communicating emergencies to people who are deaf or hard of hearing include auto-dialed TTY and taped telephone messages, text messaging, emails, open captioning on emergency broadcasts on local television stations, and dispatching qualified sign language interpreters to assist with emergency announcements that are televised.)

  ◼  Yes

  ◼  No

7.   Does your plan address the needs of people with disabilities who will require assistance leaving their homes?

  ◼  Yes

  ◼  No

8.    Do you have written procedures to ensure that your community evacuation plans enable people with a wide variety of disabilities to safely self-evacuate and, for those who cannot self-evacuate, to receive evacuation assistance ? (Note: The plans should address the evacuation needs of people who have mobility disabilities, people who are blind or have low vision, people who are deaf or hard of hearing, people with cognitive and psychiatric disabilities, people with disabilities who use service animals, and other people with disabilities who reside or visit your community who may need evacuation assistance.)

  ◼  Yes

  ◼  No

9.    Have you established a voluntary, confidential registry for persons with disabilities to request individualized notification, evacuation assistance, and transportation?

  ◼  Yes

  ◼  No

a.   If you maintain such a registry, do you have written procedures to ensure that it is voluntary, it has appropriate confidentiality controls, the information in the registry is regularly updated, and outreach to persons with disabilities and organizations with expertise on disability issues is conducted to inform them of its availability?

  ◼  Yes

  ◼  No

  ◼  N/A

10.   Does your emergency transportation plan identify accessible transportation resources that will be available to evacuate persons with mobility disabilities, including people who use wheelchairs or scooters, people who use medical equipment, such as oxygen tanks, and people who use service animals? (Accessible transportation consists of wheelchair lift-equipped vehicles.)

  ◼  Yes

  ◼  No

11.   Do your emergency plans, policies, and procedures provide for people with disabilities to be evacuated and transported to shelters together with their families?

  ◼  Yes

  ◼  No

12.    Do your emergency management plans, policies, and procedures ensure that people with disabilities are not separated from their service animals during evacuation and transportation?

  ◼  Yes

  ◼  No

Training First Responders, Staff, and Volunteers

13.    Have the following categories of individuals been trained on the information provided in Chapter 7, including Addenda 2 and 3?

a.    Emergency planners, those who designate facilities to be used as shelters, and those who make advance arrangements to address emergency staffing, equipment, medical supplies, food and beverages, and other emergency-related needs?

  ◼ Yes

  ◼  No

b. Staff and volunteers who participate in notification activities?

  ◼  Yes

  ◼  No

c.   First responders and other staff and volunteers who deal with evacuation, transportation, and emergency-related security issues?

  ◼  Yes

  ◼  No

d.    Shelter staff and volunteers and those who will be involved in routing people to shelters and deciding shelter placements for people with disabilities and their families?

  ◼  Yes

  ◼  No

e.    Individuals involved in establishing and operating temporary housing or lodging programs?

  ◼  Yes

  ◼  No

f.    Individuals who will establish and operate emergency-related medical and social service programs?

  ◼  Yes

  ◼  No

g.    Individuals who will be responsible for repair, rebuilding, and continuity of program operations following an emergency or disaster?

  ◼  Yes

  ◼  No

Physical Accessibility in Emergency Shelter Programs

This section helps you identify architectural barriers to access in your emergency shelter facilities. To ensure an accurate assessment of ADA compliance, this checklist should be completed with the input and assistance of those employees, volunteers, and representatives of third party organizations that are involved in your emergency planning and sheltering programs.

14.    Have you conducted an accessibility survey of all of your emergency shelter facilities, whether owned by government or a private entity to determine if they comply with ADA requirements? See “Checklist for Accessible Emergency Shelters,” included in Addendum 3 to this Chapter.

  ◼ Yes

  ◼  No

15.   Have you identified access barriers at any of the shelter facilities?

  ◼  Yes

  ◼  No

16.   If you found barriers at emergency shelters, have you taken steps to ensure that the barriers are removed to provide (at a minimum) the following accessible features that comply with the requirements of the ADA Standards for Accessible Design (ADA Standards): parking, exterior route from the parking to the entrance, entrance, sleeping area, dining area, toilet facilities, bathing facilities, recreational areas, emergency exit, and interior routes to all of these areas?

  ◼  Yes

  ◼  No

   N/A

17.   If all barriers have not been removed from a shelter, have you identified an appropriate number of alternate shelters that provide (at a minimum) the following accessible features that comply with the requirements of the ADA Standards: parking, exterior route from the parking to the entrance, entrance, sleeping area, dining area, toilet facilities, bathing facilities, recreational areas, emergency exit, and interior routes to all of these areas?

  ◼  Yes

  ◼  No

  ◼  N/A

18.    Until all emergency shelters have the required accessible features referenced above, have you identified and widely publicized to the public and to persons with disabilities and disability organizations the most accessible emergency shelters and the accessible features that each has?

  ◼  Yes

  ◼  No

  ◼  N/A

19.    Have you adopted policies and procedures to ensure that shelter staff and volunteers maintain accessible routes for individuals who use wheelchairs and other mobility aids?

  ◼  Yes

  ◼  No

20.    Have you adopted procedures to minimize protruding objects and overhead objects in shelters so that someone who is blind or has low vision can walk safely throughout the shelter?

  ◼  Yes

  ◼  No

21.    Have you adopted policies and procedures for shelter staff and volunteers to offer wayfinding assistance to people who are blind and those with low vision who may need assistance in understanding and navigating the shelter layout and locating shelter facilities (e.g., finding the route to the toilet room when furniture layouts change)?

  ◼  Yes

  ◼  No

22.    Have you established policies and procedures to ensure that, in the future, facilities are surveyed for accessibility and barriers to access are removed before a facility is designated as a shelter?

  ◼  Yes

  ◼  No

Policies and Procedures in Emergency Shelters

23.    Do you have supplies of informational materials routinely handed out at emergency shelters available in alternative formats (Braille, large print) for people who are blind or have low vision?

  ◼ Yes

  ◼  No

24.    Have you adopted policies and procedures for shelter staff and volunteers to provide assistance to people who are blind or have low vision by reading and completing forms and other written materials that are not available in alternative formats?

  ◼  Yes

  ◼  No

25.    Do any of your shelters have low-stimulation “stress-relief zones,” such as an empty classroom in a school building used as an emergency shelter?

  ◼  Yes

  ◼  No

• If you offer “stress-relief zones,” have you adopted policies and procedures to make these areas available on a priority basis to people whose disabilities are aggravated by stress?

    ◼  Yes
  
    ◼  No
  
    ◼  N/A

26.    Have you adopted emergency shelter eligibility policies and procedures to ensure that people with disabilities are housed at “mass care” shelters unless they are medically fragile?

  ◼  Yes

  ◼  No

27.    Have you adopted “mass care” shelter procedures to ensure that shelter staff and volunteers do not turn away people with disabilities who may need assistance with activities of daily living even though their personal care aides may not be with them?

  ◼  Yes

  ◼  No

28.    Have you adopted policies and procedures to ensure that “mass care,” “special needs,” and “medical” shelter staff and volunteers are trained and monitored so they provide safe, appropriate assistance with activities of daily living (e.g., eating, dressing, personal hygiene, transferring to and from wheelchairs) that some people with disabilities may require?

  ◼  Yes

  ◼  No

29.   If you provide a “special needs” or “medical” shelter, have you adopted eligibility policies and procedures to ensure that people with disabilities are not housed in such shelters just because they have a disability? (Note: Special needs and medical shelters are for medically fragile people who require the type of care provided in hospitals and nursing homes. Most people with disabilities are not medically fragile. The ADA requires emergency managers and shelter operators to accommodate people with disabilities in the most integrated setting appropriate to their needs.)

  ◼  Yes

  ◼  No

  ◼  N/A

30.    Have your shelter staff and volunteers received training with site-specific instructions for providing people with disabilities access to all services, activities, and programs at “mass care,” “medical,” and “special needs” shelters?

  ◼  Yes

  ◼  No

31.    Do you have written policies and procedures to ensure that people who are deaf or hard of hearing, people with speech disabilities, and people who are blind or have low vision are provided with effective communication during their stay at a shelter?

  ◼  Yes

  ◼  No

32. Do you provide a TTY at each emergency shelter for use by people who
are deaf, are hard of hearing, or have speech disabilities?

  ◼  Yes

  ◼  No

33.    Do you have written procedures to ensure that persons with disabilities who use service animals are not separated from their service animals when using emergency shelters and have full access to shelter programs, services, and activities, even if pets are normally prohibited in shelters or in certain areas of shelters?

  ◼  Yes

  ◼  No

34.    Do you have written procedures to ensure that food, water, and a receptacle and plastic bags for the disposal of service animal waste are available at emergency shelters?

  ◼  Yes

  ◼  No

35.    Have you established security procedures at shelters that allow people with service animals to take their animals outside for relief without unnecessary delays for security screening upon re-entry?

  ◼  Yes

  ◼  No

36.    Do you have written procedures to ensure that emergency shelters have back-up generators and a way to keep medications refrigerated (such as a refrigerator or a cooler with ice)?

  ◼  Yes

  ◼  No

37.    Do your written procedures on back-up generators include a plan for routinely notifying the public and disability groups of the location of shelters providing electricity and refrigeration?

  ◼  Yes

  ◼  No

38.    Does your emergency management plan provide an effective way for people with disabilities to request and receive durable medical equipment and medication while in shelters?

  ◼  Yes

  ◼  No

39.    Have you established procedures for people with disabilities to request and receive cots or beds, modifications to cots or beds, securement of cots or beds to allow safe transfer to a wheelchair, and placement of cots or beds in specific locations when needed?

  ◼  Yes

  ◼  No

40.    Have you adopted kitchen access policies to provide immediate access to food and refrigerated medications for shelter residents and volunteers whose disabilities may require it?

  ◼  Yes

  ◼  No

41. Does your emergency management plan ensure that at least some kinds of foods and beverages are available in emergency shelters for people with dietary restrictions, such as people who have diabetes or severe food allergies?

  ◼  Yes

  ◼  No

Medical and Social Services

42.    Have you established policies and procedures to ensure that medical and social services and other benefit programs are accessible to people with disabilities, including people who use wheelchairs, scooters, and other mobility aids, individuals who cannot leave shelters because of their disabilities, and people who use service animals?

  ◼ Yes

  ◼  No

43.    Have you established policies and procedures to ensure that application processes for benefit programs are designed so they do not exclude people with disabilities whose disabilities prevent them from using one particular type of application process (e.g., web-based application processes, telephone-based application processes, procedures requiring applicants to have a valid driver’s license, or procedures requiring applicants to apply in person)?

  ◼  Yes

  ◼  No

44.   Do you have policies and procedures to ensure that your medical, social service, and other benefit programs provide effective communication to people with disabilities, including people who are deaf or hard of hearing and people who are blind or have low vision?

  ◼  Yes

  ◼  No

• Do your policies and procedures include primary consideration of
  the communication method preferred by an individual with a
  disability?

    ◼  Yes
  
    ◼  No
  
    ◼  N/A

Post-Sheltering Policies and Procedures

45.    Have you adopted procedures to provide additional time, transportation, and search assistance for people with disabilities in emergency shelters to locate accessible temporary housing and support services in the community following an emergency?

  ◼ Yes

  ◼  No

46.    If you have a program to provide temporary housing to persons when they leave emergency shelters but cannot yet return home (e.g., housing in dormitories, rooms at lodging facilities, trailers), have you adopted a plan for providing prompt, equivalent temporary housing to persons with disabilities, including accessible housing for people who use wheelchairs, scooters, and other mobility aids and people who are deaf or hard of hearing?

  ◼  Yes

  ◼  No

  ◼  N/A

47.    If you have a temporary housing program, do your information materials on temporary housing include information on accessible housing (such as the specific location of accessible hotel rooms within the community or in nearby communities and transportation resources available in that area)?

  ◼  Yes

  ◼  No

  ◼  N/A

Post-Emergency Repair, Rebuilding, and Resumption of Program Operations

48.    Have you established policies and procedures to ensure that the repair and rebuilding of government facilities comply with the accessibility requirements of Title II of the ADA?

  ◼ Yes

  ◼  No

49.    Have you established policies to ensure that programs relocated from a damaged facility on a temporary or permanent basis remain accessible to people with disabilities?

  ◼  Yes

  ◼  No

Chapter 7 Addendum 2: The ADA and Emergency Shelters: Access for All in Emergencies and Disasters

One of government’s primary responsibilities is to protect residents and visitors. Providing emergency shelter during disasters and emergencies is a basic way of carrying out this duty. Shelters are sometimes operated by government entities themselves. More commonly, though, shelters are operated for the state or local government by a third party – often the American Red Cross. Regardless of who operates a shelter, the Americans with Disabilities Act (ADA) generally requires shelters to provide equal access to the many benefits that shelters provide, including safety, food, services, comfort, information, a place to sleep until it is safe to return home, and the support and assistance of family, friends, and neighbors.¹ In general, the ADA does not require any action that would result in a fundamental alteration in the nature of a service, program, or activity or that would impose undue financial and administrative burdens.² This Addendum discusses some of the key issues that emergency managers and shelter operators need to address in order to comply with the ADA when they plan for and provide shelter during emergencies and disasters. Although this Addendum focuses primarily on issues affecting shelter residents with disabilities, these issues are also generally applicable to volunteers and employees with disabilities.

A. Advance Planning

• Equal access requires advance planning. During emergencies and disasters, people with disabilities sometimes have different, disability-related needs than other individuals. Many of these needs cannot be met during emergencies and disasters without advance planning. For example, if a person’s health will be jeopardized without access to life-sustaining medication that must be refrigerated, an emergency shelter will be of little use to him unless he has access to the required medication and a way to keep it sufficiently cold. Resources of this kind will likely be unavailable unless emergency managers and shelter operators arrange to have them available well before an emergency or disaster occurs. 
  
  To provide equal access to people with disabilities, effective advance planning requires at least two steps: (1) identify the disability-related needs of the residents and visitors likely to be housed in a shelter, and (2) make the advance arrangements necessary to meet those needs in the event an emergency or disaster strikes. The most effective way for emergency managers and shelter operators to ensure that advance planning addresses the needs of people with disabilities in their community is to involve community members with a wide variety of disabilities in the advance planning process. These individuals will be able to identify the types of disability-related needs that community residents and visitors are likely to have during emergencies as well as some of the community resources that may be available to help meet those needs. 
  
  To help in the advance planning process, the following sections of this Addendum identify some of the more common disability-related needs that shelter residents are likely to have. However, since people with different disabilities will typically have different needs, the issues addressed in this document are not exhaustive. Each community will have disability-related issues specific to its own residents and visitors that need to be identified and addressed. These issues are also likely to change over time as residents move into and out of communities and as changes occur in the types of equipment, medication, and technology that people with disability use.

B. Accessibility

• Ensure that the sheltering program is accessible to people with disabilities. Disasters and emergencies are unpredictable. Even the best emergency managers cannot say with certainty when an emergency will strike, how extensive the damage will be, and which shelters will remain available to house people who must evacuate their homes. For most people, any building designated as a shelter will meet their basic emergency needs so long as it provides a safe place to eat, sleep, and take care of personal hygiene needs. But an emergency shelter is of little use to a person using a wheelchair if it has steps at the entrance or toilet rooms she cannot use. 
  
  Under the ADA, emergency sheltering programs must not exclude or deny benefits to people with disabilities.³ Emergency managers and shelter operators should therefore seek to ensure that shelters are physically accessible to people with disabilities, including people who use wheelchairs. Before designating a facility as an emergency shelter, emergency managers and shelter operators need to determine if it is accessible. Elements such as a shelter’s parking, walkway to the entrance, entrance, toilets, bathing facilities, drinking fountains, sleeping area, food distribution and dining quarters, first aid/medical unit, emergency notification system, and other activity and recreation areas need to be examined for barriers. Government facilities built since 1992 and private business facilities built since 1993 are often the best candidates for emergency shelters because they were subject to ADA requirements for physical accessibility when they were built.⁴ Some older facilities have been altered to provide physical accessibility⁵ or can be made physically accessible by using temporary measures stored on site and readily available for use in the event an emergency occurs. Other older facilities are poor candidates for emergency shelters because they have barriers that are too expensive or infeasible to remove. For guidance on emergency shelter accessibility, please see the Department of Justice’s “ADA Checklist for Emergency Shelters” at www.ada.gov/pcatoolkit/chap7shelterchk.htm. The checklist includes two assessment tools to ensure that emergency shelters provide access to all: (1) a preliminary checklist that will help emergency managers and shelter operators decide if a facility has the characteristics that make it a good candidate for a potential emergency shelter, and (2) a more detailed checklist that will help identify and remove the most common barriers to physical accessibility.

C. Eligibility Criteria

Shelters are usually divided into two categories: (1) “mass care” shelters, which serve the general population, and (2) “special needs” or “medical” shelters, which provide a heightened level of medical care for people who are medically fragile. Special needs and medical shelters are intended to house people who require the type and level of medical care that would ordinarily be provided by trained medical personnel in a nursing home or hospital.

• House people with disabilities in mass care shelters. Emergency managers and shelter operators sometimes wrongly assume that people need to be housed in special needs or medical shelters simply because they have a disability. But most people with disabilities are not medically fragile and do not require the type or level of medical care that special care and medical shelters are intended to provide. The ADA requires people with disabilities to be accommodated in the most integrated setting appropriate to their needs,⁶ and the disability-related needs of people who are not medically fragile can typically be met in a mass care shelter. For this reason, people with disabilities should generally be housed with their families, friends, and neighbors in mass care shelters and not be diverted to special needs or medical shelters. 
  
  To comply with the ADA’s integration requirement, emergency managers and shelter operators need to plan to house people with a variety of disabilities in mainstream mass care shelters, including those with disability related needs for some medical care, medication, equipment, and supportive services. Emergency managers and shelter operators must also ensure that eligibility criteria for mass care shelters do not unnecessarily screen out people with disabilities who are not medically fragile based on erroneous assumptions about the care and accommodations they require. 

• Respect the right of people with disabilities to make choices about where to shelter. In some communities, emergency managers have designated shelters specifically for individuals with disabilities or individuals with a specific type of disability. For example, a community with a school for students who are deaf may designate that facility as an emergency shelter for people who are deaf. While the ADA does not prohibit offering these types of emergency shelters,⁷ it generally does prohibit emergency managers and shelter operators from requiring people with disabilities or people with a specific type of disability to stay in such shelters.⁸ The ADA requires emergency managers and shelter operators to accommodate people with disabilities in the most integrated setting appropriate to their needs, which is typically a mass care shelter.

• House people with disabilities in mass care shelters even if they are not accompanied by their personal care aides. Some people with disabilities use personal care assistance for activities of daily living, such as eating, dressing, routine health care, and personal hygiene needs. One question that frequently arises is whether people with disabilities who use attendant care can be appropriately housed in mass care shelters. In most instances, they can. Most people with disabilities who use attendant care are not medically fragile and do not require the heightened level of medical care provided in a special needs or medical shelter. 
  
  In the past, some shelter operators maintained policies that prevented people with disabilities who regularly use attendant care from entering mass care shelters unless they were accompanied by their own personal care attendants. These policies denied access to many people with disabilities. 
  
  During emergencies, many personal care attendants – like other people – evacuate or shelter with their own families instead of staying with their clients. Shelter operators should provide support services in mass care shelters to accommodate people with disabilities who are not medically fragile but need some assistance with daily living activities unless doing so would impose an undue financial and administrative burden. Such assistance can be provided by medical personnel or trained volunteers.

• Make arrangements in advance to ensure that special needs and medical shelters have sufficient numbers of adequately trained medical staff and volunteers. Special needs and medical shelters house people with disabilities who require the heightened medical care that is ordinarily provided in nursing homes and hospitals. However, in the past, these shelters have often had too few qualified staff – or relied too heavily on volunteers with minimal training – to provide adequate care to the medically fragile people they house. 
  
  Advance planning is the only way emergency managers and shelter operators can secure enough trained medical personnel and adequately trained volunteers to ensure the safety and comfort of residents of special needs and medical shelters. 

• Keep families together whenever possible, even in special needs and medical shelters. Family members provide each other the support and assistance necessary to cope with emergencies and disasters. During these difficult times, separation from family members increases loneliness, worry, and additional stress. But while most families have been able to stay together during emergencies, individuals with disabilities have often been unnecessarily separated from their families because many special needs and medical shelters do not allow them to be accompanied by more than one person. 
  
  In disasters and emergencies, people are ordinarily allowed to shelter with their families. This benefit needs to be available to persons with disabilities as it is for everyone else. Of course, some people in special needs and medical shelters may need to be housed in medical wards apart from their families because of critical medical needs, but their families should still be housed nearby.

D. Reasonable Modifications

The ADA generally requires emergency managers and shelter operators to make reasonable modifications to policies, practices, and procedures when necessary to avoid discrimination.⁹ A reasonable modification must be made unless it would impose an undue financial and administrative burden.¹⁰ The following are examples of reasonable modifications that emergency managers and shelter operators will generally need to make:

• Modify “no pets” policies to welcome people who use service animals. Many emergency shelters do not allow residents or volunteers to bring their pets inside. But shelters must generally modify “no pets” policies to allow people with disabilities to be accompanied by their service animals. 
  
  A service animal is not a pet. Under the ADA, a service animal is any animal that is individually trained to provide assistance to a person with a disability. Most people are familiar with dogs that guide people who are blind or have low vision. But there are many other functions that service animals perform for people with a variety of disabilities. Examples include alerting people who are deaf or hard of hearing to sounds; pulling wheelchairs; carrying or retrieving items for people with mobility disabilities or limited use of arms or hands; assisting people with disabilities to maintain their balance; and alerting people to, and protecting them during, medical events such as seizures. 
  
  How can a service animal be identified? Service animals come in all breeds and sizes. Many are easily identified because they wear special harnesses, capes, vests, scarves, or patches. Others can be identified by the functions they perform for people whose disabilities can be readily observed. When none of these identifiers are present, shelter staff may ask only two questions to determine if an animal is a service animal: (1) “Do you need this animal because of a disability?” and (2) “What tasks or work has the animal been trained to perform?” If the answers to these questions reveal that the animal has been trained to work or perform tasks for a person with a disability, it qualifies as a service animal and must generally be allowed to accompany its owner anywhere other members of the public are allowed to go, including areas where food is served and most areas where medical care is provided. Questions about the nature or severity of a person’s disability or ability to function may not be asked. It is also inappropriate to question a person’s need for a service animal or to exclude a service animal on the grounds that shelter staff or volunteers can provide the assistance normally provided by the service animal. 

• Modify kitchen access policies for people with medical conditions that may require access to food. Most shelter operators restrict residents’ and volunteers’ access to the kitchen to preserve food and beverage supplies and maintain efficient kitchen operations. But people with medical conditions such as diabetes may need immediate access to food to avoid serious health consequences. Shelter operators need to make reasonable modifications to kitchen policies so that residents and volunteers with disability-related needs can have access to food and beverages when needed. 

• Modify sleeping arrangements to meet disability-related needs. To maximize efficiency, shelter operators typically provide one standard type of cot or mat for use by shelter residents. However, some people have disability-related needs for cots to be modified or may need to sleep on cots or beds instead of on mats placed on the floor. For example, a person with muscular dystrophy may require a cot with a very firm mattress to provide the physical support needed to facilitate breathing. Similarly, many people with mobility disabilities will be unable to use a sleeping mat placed on the floor. For example, many people using wheelchairs or scooters will be unable to safely transfer on and off a cot or bed unless it is firmly anchored so it does not move and has a firm sleeping surface that is 17 - 19 inches above the floor. Shelter operators need to establish procedures that people with disabilities can use to request reasonable modifications to sleeping arrangements.

E. Effective Communication

From the moment people begin to arrive at a shelter, good communication between staff, volunteers, and residents is essential. Many shelter residents and volunteers might have communication-related disabilities, including those who are deaf or hard of hearing and those who are blind or who have low vision. People with mental retardation or psychiatric disabilities might also have communication difficulties in certain circumstances, such as registering, filling out applications for benefits, or trying to understand what benefits and services are available.

Under the ADA, shelter operators must provide “effective communication” to people with disabilities unless doing so would result in a fundamental alteration or would impose undue financial and administrative burdens.¹¹ Shelters that are part of a state or local government sheltering program must give “primary consideration” to the type of auxiliary aid or service preferred by the person with a disability;¹² they must defer to that choice unless another equally effective method of communication is available or the preferred method would impose an undue financial and administrative burden or fundamental alteration.¹³ This requirement applies even if a third party operates the shelter under an arrangement with the state or local government.

Advance planning is critical to ensuring effective communication during an emergency. Without such planning, it may be difficult or impossible to locate auxiliary aids and services and have them ready for use at the shelter. Advance planning will also alleviate the expense and burdens associated with providing auxiliary aids.

• Provide alternate format materials for people who are blind or who have low vision. People who are blind or have low vision may request documents and brochures in alternate formats (Braille, large print, or audio recording). Generally, shelter supplies should include alternate format versions of documents that are routinely made available to shelter residents. Having alternate formats available for distribution during an emergency requires advance planning. 
  
  When documents are prepared on the spot and alternate formats cannot be prepared in advance or produced as needed, shelter operators are still required to provide effective communication through alternate means.¹⁴ Often, the most effective solution in an emergency is to provide a person to read printed documents and, where applicable, someone to help fill out forms. People who serve as readers or provide assistance filling out forms must be “qualified” – in the context of an emergency shelter, this means being capable of and willing to read materials and complete forms as instructed by the person with a disability. 

• Ensure that audible information is made accessible to people who are deaf or hard of hearing. In emergency shelters, most information is conveyed through oral announcements. Shelter operators must ensure that people who are deaf or hard of hearing have access to this information in a timely and accurate manner. In some circumstances, qualified sign language or oral interpreters may be required by the ADA. In others, posting messages and announcements in written format on a centrally located bulletin board, or writing notes back and forth with residents who are deaf or hard of hearing, may suffice.
  
  The type of auxiliary aid or service required in a specific situation depends on several factors, including the length, complexity, and importance of the communication and the person’s language skills and history. For example, handwritten notes will not communicate information effectively to a person who cannot read. Similarly, providing a sign language interpreter will not be effective for a person who is hard of hearing and does not understand sign language. If it becomes an undue financial and administrative burden to obtain qualified sign language or oral interpreters at a shelter, then the ADA does not require them. However, advance planning can significantly reduce the costs and administrative burdens of making interpreters available.

• Provide a TTY for the use of people who are deaf or hard of hearing. Many people in shelters use telephones to apply for disaster relief benefits, arrange for transitional housing, and speak to family and friends. People who can use standard voice telephones typically make use of shelter telephones or cellular phones for this purpose. But without access to a teletypewriter (TTY), people who are deaf or hard of hearing and those who have speech disabilities are unable to communicate with others over the telephone.

F. Shelter Environment

• Offer orientation and wayfinding assistance to people who are blind or have low vision. Until they become familiar with the shelter layout, blind people and those with low vision may have difficulty locating different areas of the shelter. Even after they are oriented to the shelter environment, changes in furniture layout or the addition or removal of cots may be disorienting to people who rely on these landmarks to find their way around. When they arrive at a shelter, people who are blind and those with low vision might need assistance orienting themselves to the shelter layout and locating pathways to sleeping areas, toilet rooms, and other areas of the shelter they may wish to use. Offer, but do not insist, on providing orientation and wayfinding assistance. Some people who are blind or have low vision need such assistance. Others can, and prefer to, find their own way. 

• Maintain accessible routes. Cots and other furniture need to be placed to ensure that accessible routes – routes that people who use wheelchairs, crutches, or walkers can navigate – connect all features of the shelter. For instance, accessible routes need to connect the sleeping quarters to the food distribution and dining quarters, to the toilet rooms and bathing facilities, activity areas, etc. Generally, an accessible route is 36 inches wide, except at doors and for short distances, when it can be narrower, and where it turns, when it must be wider. More guidance on accessible routes is provided in the “ADA Checklist for Emergency Shelters” at www.ada.gov/pcatoolkit/chap7shelterchk.htm. 

• Eliminate protruding objects in areas where people can walk. Furniture and other items should be positioned to direct pedestrians who are blind or have low vision safely away from overhead or protruding objects. This requirement extends beyond the “accessible route” and applies throughout the shelter environment to any place where a person can walk. Hazards posed by protruding and overhead objects can typically be eliminated by placing a cane-detectable barrier on the floor beneath or next to them. But care should be taken so cane-detectable barriers do not block accessible routes or the clear floor space that people using mobility devices need to access common protruding objects such as drinking fountains. For more guidance on protruding objects, please see please see the “ADA Checklist for Emergency Shelters” at www.ada.gov/pcatoolkit/chap7shelterchk.htm. 

• Consider low-stimulation “stress-relief zones.” The stress from the noise and crowded conditions of a shelter – combined with the stress of the underlying emergency – may aggravate some disability-related conditions, such as autism, anxiety disorders, or migraine headaches. Without periodic access to a “quiet room” or quiet space within a larger room, some people with disabilities will be unable to function in a shelter environment. In locations where a school gym serves as the emergency shelter, a nearby classroom can provide the necessary relief from noise and interaction that some shelter residents and volunteers with disabilities will need. Other shelter residents and volunteers may want a break from the noise and crowds. But quiet spaces are limited, they should be made available on a priority basis to people whose disabilities are aggravated by stress or noise. 

• Consult residents with disabilities regarding placement of their cots. Some individuals will have disability-related needs that require accommodation when assigning the location of their cot. For instance, a person who uses a wheelchair, crutches, or a walker may need a cot located close to an accessible toilet room. Since an assigned cot may not be identifiable by touch, a blind person may need a cot placed in a location that she can easily find. A person with low vision may need his bed located close to light so he can see or away from bright light that aggravates his eyes. Likewise, someone who is deaf or hard of hearing may need a cot placed away from visual distractions that would prevent him from sleeping.

G. Supplies

• Provide an effective way for people to request and receive durable medical equipment and medication.Despite advance planning, some people with disabilities will find themselves in shelters without a supply of the medications or medical equipment they need. For example, some medical insurance plans prohibit people from purchasing medication until their existing supply is almost gone. Other people may be required to evacuate without medication or medical equipment or be inadvertently separated from medication or medical equipment during evacuation. Emergency managers and shelter operators need to plan and make arrangements in advance so persons with disabilities can obtain emergency supplies of medications and equipment.

• Whenever possible, provide refrigeration for certain types of medication. Many people with disabilities need medication that must be refrigerated. Shelters need to have a safe and secure refrigerated location where medications can be stored and accessed when needed.

• If electricity is available, give priority to people with disabilities who use ventilators, suctioning devices, and other life-sustaining equipment. Some people with disabilities require ventilators, suctioning devices, or other life-sustaining equipment powered by electricity. Without electrical power, many of these individuals cannot survive. When electrical power is available, access should be given to people who depend on electrically powered equipment to survive. 
  
  Many people with disabilities depend on battery-powered wheelchairs and scooters for mobility. The batteries in these mobility aids must frequently be recharged, or they will stop functioning. Without these mobility aids, many people with disabilities will lose their ability to move about, they may be unable to participate in some services offered by the shelter, and they may need to depend more heavily on assistance from others. When possible, provide these individuals the opportunity to charge the batteries that power the equipment they use for mobility and independence. 

• Provide food options that allow people with dietary restrictions to eat. Because of disabilities, some people are unable to eat certain types of food. For example, people with diabetes must restrict their intake of carbohydrates. Other people have severe allergies to common food ingredients, such as peanut oil and byproducts. In planning food supplies for shelters, emergency managers and shelter operators need to consider foods and beverages for people with common dietary restrictions. 

• Provide emergency supplies that enable people with disabilities to care for their service animals. Many people with disabilities rely on service animals to do things they cannot do themselves. But when evacuating during an emergency, some individuals will be unable to transport enough food and water for their service animals. Shelter operators need to make food and water available so individuals can feed and care for their service animals. Shelter operators should also make reasonable modifications to security screening procedures so that people with disabilities are not repeatedly subjected to long waits at security checkpoints simply because they have taken their security animals outside for relief.

H. Transitions Back to the Community

• Provide people with disabilities a reasonable amount of time and assistance to locate appropriate housing.Shelters provide temporary refuge during and after an emergency until people can return home or arrange an alternative place to live. In some instances, shelter operators have required individuals with disabilities to move to hospitals, nursing homes, or other institutions when these individuals could not locate accessible housing or the supportive services they needed to live in their own home as quickly as other individuals. As a result, some people with disabilities who once lived independently in their own homes found themselves institutionalized soon after a disaster occurred. 
  
  The ADA generally requires people with disabilities to receive services in the most integrated setting appropriate to their needs unless doing so would result in a fundamental alteration in the nature of services or impose undue financial and administrative burdens.¹⁵ To comply with this requirement and assist people with disabilities in avoiding unnecessary institutionalization, emergency managers and shelter operators may need to modify policies to give some people with disabilities the time and assistance they need to locate new homes.

I. Other Resources

As discussed above, the ADA requires that people with disabilities have equal access to shelters and the benefits they provide. Providing equal access to people with different disabilities can involve very different issues. This document discusses a few of the most common issues and how they can be addressed. Other issues are addressed in Chapter 7 of the “ADA Best Practices Tool Kit for State and Local Governments,” “The ADA Guide for State and Local Governments: Making Emergency Preparedness and Response Programs Accessible to People with Disabilities, ” the “ADA Checklist for Emergency Shelters,” and other technical assistance materials that are available on the Department of Justice’s ADA Home Page at www.ada.gov.

Chapter 7, Addendum 3: ADA Checklist for Emergency Shelters