Any modification(s) to the Report, or to material contained in this Report, must be clearly
specified. In addition, a description of the modifications must be provided. Notice of the
modification(s) must be displayed prominently and must contain, if applicable, a notice that
the modification(s) may compromise the validity and readability of the information and/or
conclusions in this Report.
An Interagency Seminar of Exchange
for Federal Managers
Summary Report
April 2004
TA B L E O F C O N T E N T S
ACKNOWLEDGEMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .iv
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
SCOPE AND IMPORTANCE OF THE ISSUE . . . . . . . . . . . . . . . . . . . . . . . . . .2
BACKGROUND ON THE SEMINAR . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3
i
PART III: BREAKOUT SESSIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27
A. Communicating with Employees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28
B. Equipment Decisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31
C. On-Site Virtual Tour of Department of Labor’s
Emergency Preparedness Effective Practices . . . . . . . . . . . . . . . . . . . . . . . . .35
D. Egress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .39
E. Support Mechanisms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .44
F. Regional and Field Office Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . .48
G. Individualizing Emergency Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .51
RESOURCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .59
APPENDICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .63
ii
A B O U T T H I S R E P O RT
The document has been compiled using session transcripts, presenter presentations, and
rapporteurs’ notes. It is intended to provide an overview of the themes, ideas, questions,
and practices exchanged during the Seminar rather than a word-for-word or minute-by-
minute account of the event. More importantly, the information and opinions related to
strategies, products, and issues presented should not be regarded as endorsements or
policy statements ODEP or the Department of Labor (DOL).
While the report structure closely reflects the official Seminar agenda, some sections have
been added or modified to enhance both the readability and usability of the document.
Space has been devoted to each Seminar session rather than integrating the information
based on themes or topics. This was done for two reasons: 1) to assist readers in putting
the information in perspective; and 2) to preserve—as much as possible—both the context
in which the information was shared and the flow of the Seminar.
Finally, it is hoped that this report provides readers a better understanding of the common
themes that emerged over the day and a half, as well as practical resources and informa-
tion related to emergency preparedness for people with disabilities.
iii
AC K N O W L E D G E M E N T S
The Department of Labor’s Office of Disability Employment Policy (ODEP) would like to
thank all of the participants of the Seminar of Exchange, whose open sharing and expert-
ise contributed to the event’s overall success. Many federal experts provided critical con-
tributions to shaping the program, including Margaret (Peg) Blechman of the U.S.
Architectural and Transportation Barriers Compliance Board, and Alan Clive of the U.S.
Federal Emergency Management Agency. Invaluable guidance and involvement in the
event was provided by distinguished national experts in the field, including Elizabeth Davis
of the National Organization on Disability, Edwina Julliet of the National Taskforce on
Fire/Life Safety for People with Disabilities, and June Isaacson Kailes with the Center for
Disability Issues and the Health Professions at Western University of Health Sciences.
Finally, special thanks is warranted for the contributions of the following entities, for with-
out their input and involvement, this Seminar of Exchange would not have been possible:
iv
INTRODUCTION
U.S. Department of Labor ■ Office of Disability Employment Policy
“Research and experience in the last decade demonstrate that the needs of
federal and private sector employees with disabilities are often omitted
during the emergency preparedness planning process.”
imminence. Therefore, it is important for their safety during an emergency situation.
Government agencies to assume a position of Similarly, people with disabilities may be reluc-
preparedness for a disaster or threat to human tant to seek employment in certain locations due
life, through specific and established plans of to a fear of being trapped or not being accom-
action. This condition of preparedness can only modated in a dangerous situation.
be achieved through thoughtful planning, collab-
oration, and steadfast commitment by federal As federal agency emergency plans continue to
managers, who have been vested with the evolve, it is important to evaluate all scenarios to
responsibility of the safety of their employees. ensure they include the requirements for people
with disabilities. By anticipating such needs dur-
Research and experience in the last decade ing the emergency preparedness planning
demonstrate that the needs of federal and private process, fear and panic can be mitigated and
sector employees with disabilities are often omit- lives can be saved.
ted during the emergency preparedness planning
process. However, since the tragic events of Like other federal agencies, the Department of
September 11, 2001, the specific needs of peo- Labor has been actively preparing its office
2
Emergency Preparedness for People with Disabilities
spaces and buildings for emergency situations The agenda was divided into five general (plena-
for all employees, including employees with dis- ry) sessions and seven breakout sessions, which
abilities. While much has been done, there repeated over the course of a day and a half.
remains much to do, in the Department of Labor Nationally and locally recognized experts provid-
and throughout the Federal Government, in the ed information and facilitated an exchange of
Washington, DC area and, particularly, in the experiences between federal managers aimed at
regions. The Seminar of Exchange and this promoting consistent and effective emergency
Summary Report are a significant step forward. preparedness practices that afford equal protec-
tion for people with disabilities. As such, the fol-
B AC K G R O U N D O N T H E lowing were specific objectives of the Seminar:
SEMINAR
n December 2-3, 2003 the U.S.
3
PART I:
OPENING AND
KEYNOTE
REMARKS
U.S. Department of Labor ■ Office of Disability Employment Policy
The following are highlights of the Seminar ing employment of people with disabilities in all
Opening and Keynote Remarks. Please see sectors, Dr. Grizzard remarked that the
the Appendices for the full text of the prepared Federal Government “should be a shining
remarks. example for all employers for how to prepare
the workplace for people with disabilities in
OPENING REMARKS BY case [an] emergency does come [about].”
W. R O Y G R I Z Z A R D , J R . ,
E d . D . , A S S I S TA N T KEYNOTE REMARKS BY
S E C R E TA RY, O F F I C E O F S E C R E TA RY
DISABILITY EMPLOYMENT E L A I N E L . C H AO ,
P O L I C Y, U . S . D E PA RT - U . S . D E PA RT M E N T
MENT OF LABOR OF LABOR
ffice of Disability Employment Policy abor Secretary
6
Emergency Preparedness for People with Disabilities
7
PART II:
PLENARY
SESSIONS
U.S. Department of Labor ■ Office of Disability Employment Policy
10
Emergency Preparedness for People with Disabilities
12
Emergency Preparedness for People with Disabilities
employee with a disability in the event of an ■ Rule #8: Practice, practice, practice!
emergency. Roffee emphatically maintained that Roffee regarded practicing as an essential com-
the “buddy system simply does not work” for sev- ponent of emergency preparedness. It is impos-
eral reasons. It can lead to “not-my-job syn- sible to adequately prepare for an emergency sit-
drome.” Or, at the very least, the buddy assigned uation without having practiced. Roffee also
to the employee with a disability may not be in stated that apathy about practicing weakens a
the office the very day, hour, or moment an good emergency preparedness plan. Therefore,
alarm sounds. A better more effective alternative, it is very important to practice regularly, and to
suggested Roffee, is to have the volunteers and ensure that each practice session is taken as
the employees with disabilities convene in a pre- seriously as an actual emergency.
determined area and wait for further instruction.
Mary Ann Wilson’s remarks were based upon
■ Rule #5: Purchase evacuation chairs, and
her experiences on September 11, 2001, while
plan to evacuate any mobility devices (e.g.,
assigned to the HUD office at the World Trade
wheelchairs) that evacuation chair users may
require once they have been removed from Center in New York. She depicted a scene of
the emergency situation. According to Roffee, unwavering uncertainty that was augmented by
many fire departments have ladders that cannot the lack of a comprehensive plan. The deficien-
reach the entire height of a multiple story build- cies were numerous. Wilson told participants
ing. By having evacuation chairs available, peo- that she was unaware of the following issues at
ple with disabilities can, at the very least, be the time: the evacuation policy; the members of
moved to an area or floor where emergency her staff who were in the office; who had a dis-
response personnel can assist them further. ability and the nature of those disabilities; an
Additionally, having a plan in place that provides accessible door designed to accommodate a per-
for the evacuation of mobility devices makes for son with a disability did not work; the communi-
a smoother transition for the employees who use
cation system was inaudible; and the service ele-
these devices. Otherwise, employees will be
“basically helpless” once they have left the emer- vator, used by people unable to take the stairs,
gency situation. was experiencing problems.
■ Rule #6: Plan for communications. This Like Roffee of the Access Board, Wilson provid-
includes not only developing a system of commu- ed participants with a checklist of important items
nication that is accessible to and useable by she considered critical to emergency prepared-
everyone, but also knowing how to utilize the ness. In many respects, they were similar to the
system. eight rules presented by Roffee. For example:
■ Rule #7: Designate an emergency situa- ■ Wilson implored participants to practice.
tion room. This room should have windows However, she added that employees should
that face the street, along with a “HELP HERE” be debriefed after every drill to find out
sign. This room should also be equipped with how the emergency plan succeeds, and,
telephones and other equipment pertinent to more importantly, how it fails.
your communication plan.
13
U.S. Department of Labor ■ Office of Disability Employment Policy
■ She suggested that agencies have a ly addresses its unique circumstances? A univer-
regularly updated continuity of operations sal first-step is to engage in dialogue with other
plan that not only considers the needs of federal agencies to assess some of the processes
people with disabilities, but that also instituted, barriers encountered, and noteworthy
makes them a part of the planning process. resources available. In this session, participants
■ Her next suggestion was to make sure the heard from three federal agencies about the rudi-
evacuation plan is posted and accessible— mentary elements of their emergency prepared-
and strongly encourage all employees to be ness plans, which adequately include people
familiar with it. with disabilities: U.S. Department of Labor
(DOL); U.S. Department of Transportation
■ Another suggestion proffered was to (DOT); U.S. Department of Defense, Defense
establish a policy where employees should Intelligence Agency (DOD/DIA).
take necessary items (e.g., a purse and car
keys) when attending meetings or
Each of these agencies was chosen because of
conducting other business away from their
their specific processes and unique circum-
desk, even if it is in the same building.
stances. For example, DOL is a medium-sized
■ Wilson also urged participants to remain agency with field offices across the United
flexible at all costs. “Don’t count on any States. DOT is a somewhat larger agency, with
thing. Be prepared, because so many a significantly more intricate institutional struc-
things are not going to work. And, you are ture. DOD/DIA is a large office within the
just going to have to be flexible and largest federal agency that employs a significant
prepared to go at it another way.” number of people with disabilities.
14
Emergency Preparedness for People with Disabilities
15
U.S. Department of Labor ■ Office of Disability Employment Policy
16
Emergency Preparedness for People with Disabilities
preparedness guidelines. It will be avail- learned from drills, practices, and other
able to all DOT employees through e-learn- issues that present themselves. Additionally,
ing technology and other means. Under Benison noted that the DOT emergency
this program, the DOT operating adminis- preparedness plan is continually updated;
tration will be required to provide training employees are regularly educated on the
to new DOT employees. Additionally, any- substance of the plan; and the equipment
time the plan is updated training will be is as current as possible.
mandatory for all employees.
Department of Defense,
■ Developing the emergency prepared-
Defense Intelligence
ness guidelines: Benison identified this
as an effective practice in and of itself. Ag e n c y
he last presentation of this plenary ses-
The development of the DOT guidelines
began with the creation of a workgroup,
consisting of representatives for the DOT
operating administrations, employee
T sion came from Pamela Butler, Deaf and
Disabled Persons Program Manager in
the Diversity Management and Equal Opportunity
groups, and specific employees with dis- Office at the Department of Defense, Defense
abilities. The workgroup served as a vehi- Intelligence Agency (DOD/DIA). While DIA’s
cle for obtaining input and feedback on plan proved to be similar in many ways to the
procedures under development. By estab- other plans presented, there were some distinct
lishing a workgroup and utilizing the infor- nuances.
mation generated through their research
and discussion, the guidelines are compre-
According to Butler, the development of DIA’s
hensive and thorough. Some of the
resources that have been explored include emergency plan required the consideration of
information from Federal Government and many factors. First, DIA is a 24-hour worldwide
non-Federal Government entities, such as operation, which requires that the emergency
the Job Accommodations Network (JAN), plan be “conducive to daytime, nighttime, any-
17
U.S. Department of Labor ■ Office of Disability Employment Policy
18
Emergency Preparedness for People with Disabilities
Making employees feel comfortable about their facilitated by Dr. Beth Loy and Linda Batiste,
responsibilities and the established plan is an was designed to promote creative solutions to
integral part of DIA emergency preparedness. unique situations related to the development,
For example, DIA conducts drills where instead implementation, and maintenance of an emer-
of employees physically evacuating from an area gency preparedness plan that involves people
or floor, firemen go to where the employees are with disabilities. In this unconventional session,
located. The firemen talk to employees, either Loy and Batiste, Human Factor Consultants with
as a group or individually, about perceived next the Job Accommodations Network (JAN), pre-
steps and give advice in accordance with the sented participants with various workplace sce-
employees’ specific limitations. DIA’s plan also narios, involving people with an array of disabil-
calls for the provision of counseling by trained ities. They were then asked to brainstorm about
personnel for individuals who may have a debili- the appropriate solution to implement in an
tating emotional or psychiatric reaction to the emergency preparedness plan. Additionally, the
stress of an emergency. participants were afforded an opportunity to
learn about the ODEP-sponsored JAN and the
Through the process of developing and imple- services it offers, which include resources for
menting the DIA emergency preparedness plan, building and maintaining disability-friendly
many lessons have been learned, said Butler. plans.
Foremost of these lessons is that communication
19
U.S. Department of Labor ■ Office of Disability Employment Policy
20
Emergency Preparedness for People with Disabilities
H e a l t h
■ Utilize a series of pictograms to help the P r o fe s s i o n s ,
individual understand that there is an emer-
We s t e r n
gency situation or a drill and describe what
University of
steps must be taken to get to safety.
H e a l t h
■ Make emergency preparedness a part of the Sciences; and
individual’s job coaching experience. Edwina Julliet,
C o - Fo u n d e r,
■ Color code fire doors. National
Elizabeth Davis, Director of NOD’s Taskforce on
PUTTING IT ALL TOGETHER: Emergency Preparedness Initiative Fire/Life Safety
STRENGTHENING YOUR (EPI), listened as other panelists
for People with
addressed plan implementation and
AGENCY’S EMERGENCY maintenance. Disabilities.
PLAN
hroughout the Seminar of Exchange, par-
lines is critical.” Sharing also ensures that final tool and policy under development.
agencies are not relying on the same The point is something can often be bet-
resources or setting protocol that will con- ter than nothing, as long as it is carefully
flict with other plans. This is especially true considered and properly implemented.
in situations where agencies share office
space or are housed in close proximity. Implementation
3. “Planning is a constant, ongoing effort.” The second set of points targeted implementa-
As such, plans and other associated doc- tion of emergency preparedness plans for people
uments should be regarded as living doc- with disabilities. Kailes stressed that the impe-
uments or latest versions, but never as tus for the successful implementation of an emer-
final or complete. Said Davis, “The gency preparedness plan is to ensure that all the
minute [the plan] says it’s the final ver- targeted individuals of an inclusive plan are
sion, is the minute it gathers dust and taken into consideration.
cobwebs.”
1. Make it as comfortable as possible for peo-
4. At all times, strive to exceed the minimum ple to self-identify that they may require
standards set by the plan. For example, assistance during an emergency situation.
if a plan calls for having one drill a year Kailes insisted, “Many people who
on a regular schedule, respond proactive- need assistance will never, ever identi-
ly. Raise the bar to one regularly sched- fy as having a disability or having...a spe-
uled drill and one unannounced drill per cial need.” As such, according to
year. In doing so, Davis said that weak- Kailes, the effectiveness of emergency pre-
nesses in the plan will be revealed. paredness plans can be thwarted by an
individual’s failure to self-identify that he or
5. “Successful plans and efforts come about she has a disability. She surmised that this
when we involve all levels of an organiza- can be primarily attributed to the fact that
tion, both in the planning as well as the “unfortunate-
actual implementation stage.” According ly, many
to Davis, you never know who will find people still
themselves in a position where they need attach a
to respond. b r o a d
amount of
6. Seek out creative solutions, which incor- stigma to
porate tools, equipment, resources and disability
new property in ways well beyond the and do what-
original intended use. Nevertheless, solu- ever they can June Issacson Kailes, Associate
tions do not have to be high-tech or to stay away Director of the Center for Disability
Issues and Health Professions at
expensive. Often low-tech interim proto- f r o m t h a t Western University of Health and
cols can have as much of an impact as the effort.” Sciences.
23
U.S. Department of Labor ■ Office of Disability Employment Policy
24
Emergency Preparedness for People with Disabilities
Elevators. On the issue of elevators, Juillet Juillet expressed the paramount need for an
acknowledged the inconsistent messages active committee or council on these issues relat-
regarding the use of elevators during an emer- ed to evacuation equipment, alarms, and, partic-
gency. Historically, elevator use during an emer- ularly, elevator use for emergency egress in order
gency has been regarded as dangerous, prohibit- to assure these developments will be realized as
ed in virtually all instances. quickly as possible. ■
25
PART III:
BREAKOUT
SESSIONS
U.S. Department of Labor ■ Office of Disability Employment Policy
he Seminar breakout sessions provided consistent with the Rehabilitation Act of 1973,
28
Emergency Preparedness for People with Disabilities
disagreement—particularly within the dis- away from their desks or office. As Heppner
ability community. Involve individuals with noted, an emergency plan is useless unless an
disabilities as trainers. individual understands the type of emergency or
shelter-in-place. She provided the following
■ Provide pro-active information: Make example:
sure information is readily accessible in a
variety of formats (e.g., in a Word docu- A deaf individual had no knowledge of what had
ment, via the Web). Secure and share mate- happened at the Twin Towers or the Pentagon.
rials regarding emergency preparedness for A co-worker hand-signed the word, “war” and
people with disabilities with emergency man- told him to get out. When he was outside the
agement personnel and employees. building, he didn’t see any of his co-workers, so
he went back into the office. One co-worker,
■ Create a special needs list who was still there, again spelled out in sign
alphabet the word “war” and told him to go
Cheryl Heppner, Executive Director of The home. He had no detailed information on what
Northern Virginia Resource Center for Deaf and was going on.
Hard of Hearing Persons, addressed some of the
unique considerations for communicating with This experience was not unique. Reports from
employees who are deaf or hard of hearing. organizations “indicated that widespread difficul-
“Plans need to include ways to relay the same level of detailed information
to all staff at all times.”
Plans need to include ways to relay the same ties were experienced across the nation”
level of detailed information to all staff at all (Heppner, 2003, p. 2).4 A national follow-up
times. This involves determining such consider- survey in Spring 2003 asked what plans or pro-
ations as how information will be conveyed to cedures had been implemented. “This second
deaf or hard of hearing employees when they are survey found that only a few isolated attempts
had been made across the U.S. and that there
was little or no sharing of information or coordi-
nation of efforts” (Heppner, 2003, p. 2).
■ Ensure that the emergency-planning manu- The Rehabilitation Act of 1973, as amended,
al has information specific to people who does not bar agencies or federal contractors
are deaf or hard of hearing; and from gathering pertinent information (e.g., the
type(s) of emergency assistance an individual
■ Advocate for a variety of communication needs and how it relates to the individual’s dis-
methods. ability), or disseminating it to necessary person-
nel; nevertheless, there are some guidelines as to
However, Cameron also pointed out that persons how and when the information can be obtained,
with disabilities must take responsibility for their and the exact nature and with whom the data
own well-being and should play an active (not can be shared. Employers are permitted to get
passive) role in the process. Clarifying roles and employee medical information for use in emer-
responsibilities of both the emergency manage- gency planning. It is important to reassure
ment staff and building occupants, having a plan employees of confidentiality: that the information
of action, and practicing the plan to make sure will be shared only with those responsible for
it is effective are essential elements to emergency safety and emergency evacuation. Rennert
planning. The worst-case scenario must be con- stressed the value of having a dialogue with
sidered when making plans. employees, and clearly sharing the reason for
collecting information.
Additional elements include the psychological
and human factors that impact plans. People There are three key opportunities to obtain infor-
with cognitive disabilities and/or some psychi- mation that may be critical for emergency pur-
atric issues may have difficulty understanding poses:
what is happening or dealing with the need to
alter routines in an emergency situation. Others 1. After the job offer is made but before an
may require assistance, such as someone to help individual begins work, the agency may
during an evacuation or a shelter-in-place. ask the person to complete a questionnaire
Talking directly to individual employees about regarding emergency evacuation needs.
their needs is imperative. Just as one emergency
plan does not fit every agency, one employee 2. An agency may periodically survey the
with a disability does not represent all employees entire workforce.
with disabilities in an agency.
3. If the manager knows that an individual
Agencies can talk to employees about their has a disability, he or she can ask whether
needs and involve people with disabilities in the the individual might need assistance dur-
planning process consistent with the require- ing an emergency. For example, consider
ments of the Rehabilitation Act. Sharon a shelter-in-place: does an employee have
Rennert, Senior Attorney Advisor with the U.S. dietary or medical needs? Also, keep in
Equal Employment Opportunity Commission mind that there may not be an interpreter
(EEOC), explained there are two main issues in the shelter. Determine what accommo-
related to employee information and emergency dations are needed to communicate with a
planning: 1) obtaining information from employ- person who is deaf.
ees and 2) sharing the information with others.
30
Emergency Preparedness for People with Disabilities
With regard to sharing the information with others, size, structure, and location among agencies.
here are several important points to keep in mind: Nevertheless, agencies may be working individu-
ally to strengthen emergency preparedness plans.
1. Designate an individual at your agency who For example, the Federal Communication
knows and clearly understands these Commission (FCC) has an initiative to improve
needs. Ensure that someone is responsible access to technology.
for providing the necessary assistance.
B. Equipment Decisions
2. Share only necessary and appropriate infor-
ne of the most critical aspects of imple-
mation regarding emergency needs—not
irrelevant disability-related information—
with safety and emergency evacuation per-
sonnel.
O menting and maintaining an effective
plan is determining the type of equip-
ment necessary to keep employees safe, whether
it be during a shelter-in-place or an evacuation.
Following the presentations, the discussion and Equipment Decisions provided an overview of
questions centered around the need for employ- emergency preparedness equipment and the var-
ees to take an active role in preparedness efforts ious resources available to assist agencies during
and the steps being taken to improve plans and the selection and procurement decision-making
technology access in the Federal Government. process. Employee needs, architectural realities,
budgetary constraints, and agency characteristics
Although plans may exist, there is often an ele-
undoubtedly impact such decisions. The goal of
ment of the unknown during an emergency.
this session, therefore, was not simply to supply
More importantly, emergency personnel may be
unable to meet every need immediately. attendees with an equipment checklist or identi-
Employees must also take active steps to prepare fy the “best” products, but rather address the fol-
on a personal level. Consideration must be lowing issues:
given to what will happen not only during, but
■ The various types of disability-specific
also following an emergency. For example, how
equipment;
will employees get home if public transportation
■ The resources available to make equipment
is not operating? What happens if an employee
decisions; and
requires medication during a shelter-in-place?
■ Ways to promote appropriate equipment
Effective practices may include keeping extra
supplies and medication at the office. Several use in the event of an emergency.
concerns included storing such items, and
whether or not additional medication would be Dr. Beth Loy and Linda Batiste, the presenters
approved and covered by doctors and insurance for this breakout session, work as Human Factor
companies. Consultants at the Job Accommodation Network
(JAN). As they explained to Seminar partici-
With regard to efforts being made by the Federal pants, the mission of JAN is to provide informa-
Government to ensure plans are inclusive, it was tion to employers and employees with disabilities
noted that no federal agency is tasked with this regarding job accommodations, the 1990
responsibility. Evaluation standards for such Americans with Disabilities Act (ADA), and the
plans would be difficult given the differences in employability of people with disabilities.
31
U.S. Department of Labor ■ Office of Disability Employment Policy
32
Emergency Preparedness for People with Disabilities
Distribute the plan to all employees, staff, and when selecting accommodations. There is no
key personnel. This should include writing the “one-size-fits-all” when it comes to making equip-
plan, familiarizing staff with it through practice ment decisions, and as illustrated below, partici-
drills, and integrating the plan into the agency pants offered differing perspectives on some of
operating procedures. the accommodations discussed.
“Loy and Batiste encouraged talking with other federal agencies, and
working with local emergency response personnel and community organi-
zations to determine the most appropriate solutions.”
their sales representatives. Loy and Batiste
encouraged talking with other federal agencies, ■ Designate “areas of rescue assistance.” Loy
and working with local emergency response per- and Batiste admit this is also a somewhat
sonnel and community organizations to deter- controversial accommodation, but as par-
mine the most appropriate solutions. It is also ticipants themselves pointed out, not every-
imperative to communicate with these entities in one may feel comfortable being assisted by
order to educate new emergency response per- co-workers. Whatever the decision, Loy
sonnel and to keep abreast of new technology or said the important thing is that a plan is in
procedures. place, and that all personnel are aware of
the plan. This topic is specifically
The following accommodations are simply sug- addressed in the Access Board’s ADA
gestions; Loy and Batiste reiterated that talking Accessibility Guidelines (ADAAG).
directly to employees is of the utmost importance
33
U.S. Department of Labor ■ Office of Disability Employment Policy
If these areas do not have escape routes, they weight of such a wheelchair, and an individual’s
should have the following: ability to maintain his or her balance in the
evacuation chair.
■ An operating phone, cell-phone, TTY (tele-
typewriter), and two-way radio so that One participant recommended that manufactur-
emergency services can be contacted; ers put better straps on evacuation chairs.
Using freight elevators to evacuate the building,
■ A closing door; rather than the standard passenger elevators,
was offered as another solution. Wheelchair
■ Supplies that enable individuals to block users often want to remain with their chair or
smoke from entering the room from under obtain it as soon as possible after evacuating,
the door; and since it is their main means of mobility. While
power wheelchairs are often costly, Loy and
■ A window and something to write with Batiste reminded participants that they can be
(e.g., lipstick, marker) or a “help” sign to replaced; getting out of the building safely is
alert rescuers that people are in this loca- more important. Leaving manual wheelchairs
tion, and respirator masks. stationed in various stairwells and in the main
lobby ensures that individuals have at least a
Motor Impairments: temporary means of getting around in the event
of an evacuation in which they cannot take their
Evacuation devices help move people with motor own wheelchairs.
impairments down the stairs or across rough ter-
rain. If evacuation devices are used, both co- Sensory Impairments:
workers and response personnel should be
trained to operate and maintain them. ■ Lighted fire strobes and other alerting
Manufacturer representatives may be willing to devices to supplement audible alarms.
assist with training. Make sure to develop barri- Lighted strobes should not exceed five
er-free paths out of buildings by removing any flashes per second due to risk of triggering
physical barriers (e.g., boxes, supplies, and fur- seizures in some individuals.
niture) from exit routes. Consider keeping heavy
gloves, tire repair kits, and extra batteries on ■ For a participant who asked about alterna-
hand for those who use manual or battery-pow- tives to strobe lights, vibrating pagers were
ered wheelchairs. Gloves may protect individu- recommended. There was concern that
als’ hands from debris when pushing manual such devices do not work, because individ-
wheelchairs. Arrangements should also be made uals may not carry their pagers or receive
to have wheelchairs available after an evacuation. the message in time. Other participants
stressed the value of having multiple
Attendees discussed the issue of evacuating an means to communicate with all employees.
employee and his or her power wheelchair.
Most believed that evacuating the person ■ Alerting devices, vibrating paging devices,
should be the first priority, although plans wireless communicators, or two-way pag-
should be made to get the chair out if at all ing systems to alert individuals who are
possible. Concern centered on the cost and deaf or hard of hearing.
34
Emergency Preparedness for People with Disabilities
■ Braille signage, audible directional signage, rescue assistance until emergency personnel
and pedestrian systems for employees who arrive was also suggested as an option.
are blind or have low vision. These prod-
ucts may also benefit others in navigating Whatever the disability, Loy said it is important
smoke-filled corridors and hallways. for employees, managers, and emergency
response personnel to work together in imple-
■ Alphanumeric pagers or other communica- menting the evacuation plan and prioritizing
tion devices may assist individuals with evacuation options.
speech impairments in communicating with
emergency management personnel.
C . O n - S i t e V i r t u a l To u r
Cognitive/Psychiatric Impairments: of Department of
L a b o r ’s E m e r g e n c y
Find ways of communicating with people who
have cognitive impairments. Some individuals P re p a re d n e s s E ff e c t i ve
may benefit from pictures of buddies, color-cod-
Practices
ing of escape doors and areas of rescue assis-
his forum provided a multi-media and tac-
tance, or listening to the information on tape or
CD-ROM.
35
U.S. Department of Labor ■ Office of Disability Employment Policy
“The intent was, and continues to be, to provide effective and responsive
emergency planning and procedures in order to ensure the safety of all
building occupants.”
36
Emergency Preparedness for People with Disabilities
Basic Principles
approach was not appropriate. Instead, Below are some key principles DOL has kept in
DOL officials determined that it would mind as it continues to implement and upgrade
be more effective to address the specific procedures that are both effective and responsive
situation and develop procedures that to the needs of all its employees at the
considered the needs of all employees, Washington, DC headquarters:
including people with disabilities.
■ Be aware of everyone in the building: Be
■ Shift from a “security manager force” aware of employees’ needs; however,
to a “building occupant force.” remember to consider the needs of others
Previously, the focus had been on the in the building. This may include children
roles and responsibilities of security per- in the daycare center, cafeteria workers,
sonnel in the event of an emergency, contractors, sales representatives, and per-
rather than ensuring employees were sonal visitors.
aware of emergency procedures. So,
greater emphasis was placed on equip- ■ Communicate, Relate, Educate: Fearon
ping employees with appropriate knowl- urged participants, “Train, Train, Train! If
edge. As part of this shift, DOL revised the plan is not practiced, it won’t work!”
its evacuation handbook to include gen- Refining the plan, then practicing it is
eral floor plans of the DOL facility, and essential.
an illustration of collection points for
people evacuating the building. ■ Make a commitment to awareness, improve-
ment, and constantly rethinking safety:
■ Formalized program for Floor Agencies must respond to emerging issues,
Wardens and Zone Monitors. This including new threats. Fearon acknowledged
involved establishing a volunteer pro- Secretary Chao’s commitment to continu-
gram to “recruit, train, and equip” Floor ously rethinking and developing DOL’s
Wardens and Zone Monitors as well as emergency preparedness plan. She
ensuring that every floor had radios, expressed appreciation that Secretary Chao
making it easier to verify the building is understands the plan must be flexible and
clear and all who may need assistance can always be improved upon, especially as
receive it. workplace circumstances or threats change.
37
U.S. Department of Labor ■ Office of Disability Employment Policy
Following each drill, OASAM distributes DOL has implemented two separate procedures
surveys to the employees to gauge the effec- for a shelter-in-place, depending on the nature of
tiveness of the current plan. Based on feed- the emergency. Posture I Advisory requires that
back changes are made. Agency emergency employees remain at their individual workstations
preparedness handbooks and other materi- and wait for further instruction. Posture II
als are revised as emerging issues arise Advisory, used in situations deemed highly criti-
and as additional equipment (i.e., cal, requires that staff move to the nearest desig-
LifeSliders®, evacuation chairs, and emer- nated shelter-in-place. Employees are given lami-
gency packets) are purchased. nated cards that provide written reminders of the
procedures and designated areas. In both cases,
■ Redefine “Disability”: Agencies should pre- no one is allowed to leave or enter the building;
identify staff with disabilities, including those the doors are locked for everyone’s protection.
with specific needs. Fearon suggested that Fearon explained, “If DOL is in lock down,
perhaps agencies should reconsider their def- chances are your spouse’s or children’s facilities
initions of disability, or at least the means of are as well.” Additionally, staff is not free to
identifying who will need assistance during move about the building (e.g., go to the rest-
an emergency. She offered this definition room), except under extenuating circumstances.
with regard to emergency planning: “a debili-
tating condition that causes one not to be Each shelter-in-place area has telephone(s),
able to keep up with the standard flow of traf- food, other emergency supplies that are stored in
fic during an evacuation and/or those who secured cabinets. There is enough food and
may impede the flow of the traffic, thus caus- supplies for both employees and visitors. Floor
ing harm to themselves or others.” Examples Wardens, Zone Monitors, and security personnel
include the elderly, overweight, and persons have key access to these cabinets. Although
with temporary disabilities (e.g., a broken leg, agencies should prepare for their employees and
a sprained ankle) or episodic conditions visitors, she also urged staff to store any specif-
(e.g., panic attacks, asthma, seizures). ic personal supplies (e.g., medications, supplies
for service animals) they may need at their
Seminar participants had a variety of questions desks. Fearon reminded attendees that typically
and comments related to the DOL plan, as well the length of time for a shelter-in-place is relative-
as its implementation and maintenance. The top- ly short. “The need to shelter-in-place [due to an
ics addressed below summarize the discussion: airborne substance] only lasts for 4-6 hours.”
When the need for a shelter-in-place has passed,
Shelter-in-Place authorities explain the reason for it.
38
Emergency Preparedness for People with Disabilities
who will respond in specific situations. were deemed unsafe, Fearon said, “We would use
Sometimes the trained DOL staff (e.g., security our last line of defense [the stairwell and a
personnel) handles issues, while at other times LifeSlider®] to evacuate people with disabilities
local entities are called in. The Department has from the building.” There were questions regard-
also worked with nearby employers and first ing the effectiveness and usability of the
responders to designate assembly areas follow- LifeSlider®. Fearon stressed that the device was
ing an evacuation. Information, resources, and chosen because it met “the global needs” of the
other assistance are provided to regional and Department. She said each agency must make a
field offices. “We dialogue,” said Fearon. determination what works best given its unique
characteristics. Training and practice are also crit-
Medical staff from the Department’s Health Unit ical to ensure the equipment is properly used.
also serve as first responders in certain situa-
tions. Even though their radios are single-chan- Once everyone is out of the building, an account-
nel frequency, they work closely with local emer- ability tree is used to make sure all are safe.
gency response personnel in the event of an Staff determine who is at the assembly area, off
emergency. site, or out sick. Once the “all clear” is given by
security guards and/or emergency response per-
Department of Labor Egress sonnel to the security guards or Floor Wardens
in each of the designated assembly areas via
The Department has an “everyone out” policy, radio, employees are allowed to re-enter the
and does not utilize “areas of refuge.” There are building, but must display their identification
five entrances and twelve stairways for use dur- cards upon doing so.
ing an evacuation. Text messaging conveys infor-
mation to employees who are deaf or hard of
D . E g re s s
hearing, either via pagers or via a desktop com-
gress is defined as “the act of coming in
puter. Currently, the message is sent out manu-
ally, but the Department is working on linking
the system directly to the alarm system. Braille
signage is in place for those who are blind.
E or going out [especially from an
enclosed area]; emergence.” It is also
defined as “a path or opening for going out; an
Extra wheelchairs are kept in the stairwells and exit.” Therefore, it makes sense that developing
in the main lobby for use if necessary. Specific an effective emergency preparedness plan
accommodations are also made on the basis of involves considering specific egress options.
need. “It helps to have a “buddy system” [or This breakout session provided participants the
other type of support system] in place.” chance to explore the pros and cons of various
evacuation procedures, including the use of ele-
The use of elevators depends on the nature of the
vators and the establishment of safe areas. For
emergency. Due to the steel and stone makeup of
example, it has become widely accepted to avoid
the elevators, there is a low incidence of burning.
In the event of an emergency, some elevators using the elevators for evacuation purposes in
return to the first floor. Others are manually oper- the event of a fire, but there are situations in
ated by Emergency Elevator Operators (EEOs) which elevator use is appropriate. Specific dis-
and serve as a means of assisting persons with cussion included determining, evaluating, and
disabilities out of the building. If all the elevators prioritizing evacuation options.
39
U.S. Department of Labor ■ Office of Disability Employment Policy
40
Emergency Preparedness for People with Disabilities
know that in an emergency the elevators ■ Carrying and lifting people with disabilities:
are to be used only by people who have Participants had questions about assisting
mobility impairments. However, if nece- an employee who uses a wheelchair out of
ssary, those with temporary disabilities can a building. Kailes and Juillet recommended
also use the elevators. talking with the individual in order to devel-
op a plan with that person. Some people
■ Designating “areas of refuge” or “areas of have a preference. They said there are sev-
rescue assistance”: Juillet pointed out that eral choices: using an evacuation chair or
(while there is no such requirement in the carrying the person out. Make sure people
ADA), the Access Board’s ADA are trained on the use of evacuation chairs,
Accessibility Guidelines (ADAAG) define and have regular practice sessions.
areas of refuge or areas of rescue assis- Carrying a person can be somewhat cum-
tance as a part of the requirements for bersome and even dangerous. Talk with the
“accessible means of egress.” Such areas individual to determine the best way to
are only necessary in new buildings. move them, and again, make sure to
Structures with an approved sprinkler sys- rehearse the procedure. If there is absolute-
tem are an exception and do not require an ly no one available to assist the individual,
area of refuge. instruct him or her to go to a designated
area and contact emergency personnel.
ADAAG has six configurations, each with
specifications for signage, communication, ■ Selecting appropriate devices: There is no
etc. Juillet stated her bias for only three of one model or piece of equipment that is
these configurations: elevator lobby, exit appropriate for every situation or for every
stair landing, and the horizontal exit (e.g., individual. In fact, with regard to evacuation
where two buildings are connected by a chairs there has been little, if any, research.
fire-rated corridor (or bridge)). If an aeri- Juillet and Kailes underscored the impor-
al evacuation (fire department equipment tance of agencies doing their own research,
with a ladder and/or a “cherry picker”) is talking with other organizations, and work-
utilized, be sure the equipment can reach ing with local fire departments.
the room window. The rule of thumb is
that the equipment can reach up to the sev- One participant, for example, said his
enth story. However, that is only when the agency found that evacuation chairs were
area below the window is perfectly level difficult to use and required extensive train-
and has a solid “footing.” ing. As a result, the agency issues them
only when the person with a disability
■ Developing personal support networks (in agrees and the staff is trained. Another
lieu of the “buddy system”): Substitute accommodation has been the smoke hood.
the buddy system with a personal support This agency has distributed smoke hoods to
system. Encourage employees to build some people with mobility impairments, in
relationships with a number of individu- the event that it takes them longer to evacu-
als, so they will not be without assistance ate the building. Employees have also been
in an emergency. Facilitate this through instructed to evacuate to other buildings,
staff training. since several are connected by passageways.
41
U.S. Department of Labor ■ Office of Disability Employment Policy
Another participant pointed out that egress tance will self-identify. Cast a broad net.
planning is complicated by the fact that fed- Word questions in a manner that encour-
eral agencies often occupy only portions of ages the greatest number of employees to
a building, which are shared by private respond. For example, avoid using the
companies. Coordination can be difficult word disability, since individuals with such
unless you have a strong landlord. It was conditions as asthma, panic attacks, signif-
suggested that agencies encourage land- icant allergies, heart conditions, and age-
lords to use a coordinated emergency evac- related conditions may not consider them-
uation plan as a selling point for lease of selves disabled. However, even the most
space. carefully crafted inquiries will not cause all
“...even the most carefully crafted inquiries will not cause all to self-identify,
so plans should take into account these individuals, as well as visitors.”
Kailes cautioned that planning should not be to self-identify, so plans should take into
seen as a one-time event with beginning, middle, account these individuals, as well as visi-
and end, but rather as an on-going process. An tors.
agency plan should be viewed as a living docu-
ment. If necessary, additional plans should be Participants had questions regarding both
developed for those who work after hours or on individuals who may be reluctant to self-
the night shift. The plan must be continually identify and planning for visitors. There are
revised and updated to reflect changes in tech- individuals who feel strongly about being
nology and procedures. Both research and prac- identified as having a disability or medical
tice drills are essential to continuously strength- condition. There are also those who think
ening a plan. they will not need assistance. Questions
surfaced regarding how to account for
Implementation these individuals. The presenters remind-
ed attendees to be observant and take note
The following aspects are key to the implemen- of who takes more time to exit than his/her
tation phase. Keep in mind that an agency plan peers. Plan for several additional individu-
should be available in a variety of formats. The als, including guests and visitors, when
plan should be reader-friendly (bulleted lists ver- purchasing devices and training employees
sus long paragraphs) and available in languages to assist with egress.
other than English.
With regard to planning for visitors, Juillet
■ Identifying employees who will need assis- and Kailes recommended putting a map
tance during egress: Kailes reminded par- and emergency numbers on the back of
ticipants that no one knows better than Visitor’s badges. But, as one participant
employees with disabilities the type of explained, this could be a problem, espe-
accommodations needed in an emergency cially if there is a high volume of visitors
situation. She stressed it is critical to keep per day. Agencies may not have the funds
in mind that not everyone needing assis- to produce the badges. In addition, visi-
42
Emergency Preparedness for People with Disabilities
tors may forget to return them. However, imbedding “stumbling blocks” is vital to
as another attendee pointed out, the same helping employees prepare for the unex-
could be said of current Visitors’ badges. pected. Both announced and unannounced
Some agencies use paper badges and/or drills should be conducted several times a
ask visitors to temporarily surrender identi- year. Drills should vary (evacuation and
fication. Another recommendation was shelter-in-place) and pose a variety of chal-
that visitors be escorted at all times. In the lenges, such as closed off hallways,
latter scenario, the escort would assist blocked doors, or unconscious individuals,
his/her visitor out of the building in the along designated evacuation routes.
event of an emergency.
Practice also makes a difference. In 1993,
■ Training for both those requiring assistance during the World Trade Center bombing, a
and those providing assistance: Training woman could not figure out how to leave
and cross training is essential. Individuals the building until two co-workers came by
(and their co-workers) needing to use emer- and reminded her about the evacuation
gency evacuation devices, such as evacua- chair under her desk. Human factor stud-
tion chairs, should be trained regarding ies support the idea of practice: people
their proper operation. This will allow tend to come and go from the same place
these employees to better direct others on using the same route. It is important that
the use of the equipment, in the event that employees practice using the stairways,
“trained” personnel are not available. because in many cases, they may not know
Keep in mind that separate training may be the location of the stairs until they are
necessary for those who work after normal required to use them.
business hours.
“...[W]hile conducting standard drills are important, varying the drills and
imbedding ‘stumbling blocks’ is vital to helping employees prepare for the
unexpected.”
Some participants raised the issue of There are three types of drills: walkthrough
embarrassment or self-consciousness on drills, scheduled drills, and unannounced drills.
the part of individuals who need assistance
in egress. For example, there may be indi- ■ Walkthrough drills: These allow personnel
viduals who are uncomfortable practicing to discuss possible difficulties and slowly
evacuation procedures in a group setting. practice evacuation techniques. For exam-
For these employees, consider one-on-one ple, people might practice using an evacu-
training or trying out different evacuation ation chair or carrying someone.
methods and devices.
■ Scheduled Drills: Such drills provide an oppor-
■ Conducting various types of drills: Juillet tunity to practice evacuating people with disabil-
explained that while conducting standard ities in a slow and controlled environment. The
drills are important, varying the drills and procedures are methodically practiced by all.
43
U.S. Department of Labor ■ Office of Disability Employment Policy
■ Unannounced Drills: It is critical that unan- research. The primary technology areas for egress
nounced drills occur only after scheduled are alarms, elevators, and evacuation chairs.
drills. This ensures that the kinks are
worked out and people do not practice Alarms. The National Fire Protection
incorrectly. In addition, do not hold sur- Association (NFPA-72) sets the standards for
prise drills when emotions are high (e.g., alarms.
around the anniversary of September 11th or
the sniper attacks). Juillet recommended Elevators. The protocol regarding elevator use
that emergency response staff (e.g., Floor during emergencies is changing; in fact, Juillet
Wardens) be notified prior to such drills, so made reference to an upcoming conference that
that they can practice their responsibilities. will address elevator issues. Europe is develop-
ing standards that will enable elevator use dur-
There were additional questions related to ing emergency evacuations. These standards
both staff and visitors participating in will address fire ratings and the need for water
drills. Since there are no penalties for not protection (e.g., waterproof components, safety
participating, many employees ignore or brakes, switches).
avoid the drills. Suggestions included
developing creative educational techniques, Evacuation chairs. Kailes stated that there are
such as fun exercises, or making participa- no objective evaluations or ANSI (American
tion in drills part of the annual perform- National Standards Institute) standards regard-
ance evaluations. Additionally, visitors may ing evacuation chairs, leaving emergency man-
not want to be detained during a shelter-in- agers responsible for independently researching
place drill. Those who intended to be in and selecting them.
the building for only a brief time (e.g.,
delivering a document), and have other
E. Support Mechanisms
commitments, may protest about participat-
sing the U.S. Architectural and
■
ing in such drills. Consider establishing a
safe exit route for such exceptions.
44
Emergency Preparedness for People with Disabilities
on cross-training in order to ensure that as many 3. Building characteristics: This includes the
employees as possible can provide assistance stairways, landings, exits, alarms, eleva-
and perform the various roles called for in their tors, etc. This is important in developing
emergency preparedness plan. plans, identifying problems (i.e., trash in
stairways), and establishing methods to
Bruce McFarlane, Director of the USDA’s TAR- address these issues. It is best to do so
GET Center, explained how the USDA prior to an emergency or incident.
embarked on its road to emergency prepared-
ness. The process began after a 1993 fire drill 4. Building management: Talk with the build-
where multiple employees with disabilities were ing management and security staff.
left behind or not able to evacuate. Following Determine the building plan, relationships
that event, a panel consisting of six employees with police and fire departments, location
convened to ensure this would not happen again. of the building command center, etc.
Fortunately, there were key management person-
nel who were personally affected by the issues The Access Board learned that the police and
related to having a disability. They took interest fire department go to the front desk first. This
in the topic and began to listen. In 1994, the gives them an overview of what is happening in
panel prepared Occupant Emergency Plan the building. It is here the Access Board posted
Review for Employees with Disabilities. A key a list of all the people with disabilities and their
recommendation of the report was the call for preferences for evacuation (i.e., staff members
autonomy and independent decision-making who preferred to wait in the office’s safe area for
authority in emergency planning. firemen or police rather than use an evacuation
chair). Briefings were held for local fire depart-
Peg Blechman, Compliance Specialist at the ments regarding Access Board plans.
Access Board, said the events of September 11,
2001 led her agency to re-examine its plan. Staff Additional follow-up action included the pur-
took an inventory of the following, which she chase of appropriate equipment (e.g., evacuation
believes is key to planning and development: chairs, radio walkie-talkies) and the establish-
ment of offices designated as “waiting areas”
1. Who is on-site (i.e., staff, board members, and assembly areas. Emergency equipment is
and visitors): The Access Board relied on stored in the “waiting area” offices when not in
individuals to self-identify, then worked use. Blechman noted the agency consistently
with each person individually to determine practices, revises, and updates its plan. She
their needs, choices, and preferences. The said, “The key is practice, practice, practice.”
office flow pattern, number of staff, and
out-of-office frequency were also studied. McFarlane highlighted several fundamental prin-
ciples to emergency preparedness planning:
2. Location of the building and office: For
example, the offices of the Access Board ■ Timely and accurate information: People
are located on the 10th floor of a building with disabilities need timely and accurate
near the White House. information in order to make decisions.
45
U.S. Department of Labor ■ Office of Disability Employment Policy
46
Emergency Preparedness for People with Disabilities
“In McFarlane’s opinion, plans should not be based on the person being
in their own office at the time of an emergency.”
■ Short-Wave Radios: Floor Monitors and Additional Egress Issues
drivers use these radios.
Many of the participants had additional ques-
■ Emergency Hotline: People off-site are able tions and concerns related to egress. Specific
to call in and obtain more information issues raised during the discussion related to
about the situation. employees who may take longer to evacuate; use
of elevators; equipment selection; and education
■ Web Site Information and training.
■ Buddy System: This system is person and One of the participants asked how to address
location dependent. McFarlane believes the issue of a person who believes he/she does
that such systems generally only have draw- not need assistance, but is in fact impeding oth-
backs when used exclusively. ers during an evacuation. McFarlane said his
47
U.S. Department of Labor ■ Office of Disability Employment Policy
response would depend on if the person were a agencies and federal contractors must understand
permanent or temporary employee. If it were a their responsibilities under the Rehabilitation Act
permanent employee, he would likely discuss the of 1973, as amended. She reiterated the impor-
issue with the person one-on-one. If it were a tance of receiving support from upper manage-
temporary individual, the decision would be up ment. Safety personnel should also be made
to the hall monitor. A solution might be to sug- aware of those who need assistance. To this end,
gest the individual use the elevator, if possible. she encouraged both agencies and individuals to
be proactive when addressing barriers both inside
A question was raised regarding the use of ele- and outside the building. For example, make
vators during fires. Fire codes in some loca- sure that security barricades are not blocking
tions, such as New York, preclude the use of ele- accessible routes away from the building. Finally,
vators during fire emergencies (in high rise build- she encouraged agencies to continue working
ings). The panelist suggested this could be over- together following the Seminar. Both she and
come in situations where there are multiple McFarlane said they would like to see the estab-
banks of elevators. An “enunciator panel” lishment of an interagency working group to
allows on-site safety/security personnel (e.g., the address the issue of emergency preparedness for
fire department) to determine the location of the people with disabilities.
fire. If the elevator is on an independent power
source and not in the vicinity of the emergency,
F. R e g i o n a l a n d F i e l d
people could possibly be directed to another part
of the building. Office Considerations
egional and field offices face unique chal-
Participants suggested two other possible solu-
tions: designating a particular stairwell for use
by people with disabilities or using evacuation
chairs. One of the presenters pointed out that
R lenges when it comes to emergency pre-
paredness planning. Federal agencies
and offices must consider the needs of employ-
ees with disabilities, personnel previously uniden-
the first suggestion presents a problem, especial-
tified as having a disability, and the public. It is
ly if the emergency (i.e., bomb, fire) is in that
area. It is important to prepare for use of all
stairwells in the building. Using an evacuation
chair may present some problems as well.
Blechman pointed out that an individual’s wheel-
chair might need to be left behind, making it dif-
ficult for the person to get around once outside.
In addition, there has been little research regard-
ing the safety of various chairs. One solution at
some agencies has been to leave spare wheel-
chairs in the stairwells or lobbies.
48
Emergency Preparedness for People with Disabilities
vital that federal safety plans do not conflict with Government personnel (e.g., Social
other agencies and/or business tenants sharing Security Administration (SSA) and U.S.
building locations. This session was to examine Citizenship and Immigration Services
the importance of involving all stakeholders in (USCIS)). Such factors should be consid-
planning and implementation as well as identify- ered in evacuation planning.
ing and working with nontraditional planning
■ Hazards: Clive encouraged participants to
partners, such as local emergency professionals,
be prepared for a variety of hazards,
property management, and building safety direc-
including natural and man-made disasters,
tors. There were to be additional references to chemical spills and power outages. He
planning methodology, situational differences cited such events as the September 11th
among agencies, and support materials. attacks and the 2003 power outage in the
Midwest that impacted much of the East
Dr. Alan Clive, Civil Rights Program Manager
Coast. Such events galvanized many,
for the Federal Emergency Management Agency
including the disability community, to con-
(FEMA), began by explaining that agencies have
sider needs they may have in an emergency.
to contend with three main issues when develop-
ing emergency plans.
It was stressed that ultimately each office needs
to customize its plan, determining the most
■ Location/type of building: federal agen- effective practices given location, population,
cies throughout the country have unique financial constraints, and emergency prepared-
characteristics. Some are located in ness needs.
Government-built and owned buildings.
Others are located in skyscrapers, where Rethinking “Special Needs”
the government leases several floors.
Some are sole occupants, while others While accommodations can and should be
share space with other federal agencies or made for those with distinctive needs (e.g., eld-
private employees. Some occupy entire erly, people with disabilities, those with unique
campuses, while others may be isolated medical needs), Elizabeth Davis, Director of
industrial-style facilities, such as warehous- the National Organization on Disability’s
es. (NOD) Emergency Preparedness Initiative
(EPI), explained that there is no consensus on
■ Population: Agencies must take into the best strategy, technology, or tools to assist
account who is in the building. Some fed- people with disabilities in an emergency. There
eral agencies (e.g., Federal Bureau of are complaints that with the quick growth in the
Investigations (FBI) and FEMA) have very market for emergency equipment for people
few non-government personnel in the with disabilities, no standards exist to advise
building. Other offices, especially those purchasers on the effectiveness or safety of spe-
that provide services to the public, have a cific equipment. Until such standards exist, she
constant flow of visitors and non- said, “Buyers beware.”
“Davis urged agencies to plan for a gap in ability during an emergency,
not for disability.”
49
U.S. Department of Labor ■ Office of Disability Employment Policy
She added that in the General Services lishing “areas of refuge” or “areas of rescue
Administration’s (GSA) Occupant Emergency assistance,” re-evaluating policies related to
Plan (OEP), which serves as a framework for elevator use for evacuation, and widening stair-
federal agencies, there are no special emergency- wells in future constructions.
support functions, because special needs fits
into each emergency support function. Every Planning Considerations
Government agency that occupies federally-
owned or leased space must have an OEP. Even the most comprehensive plans will not be
perfect. Davis said agencies should do the bes
Certain aspects of a plan may need to be tai- they can to establish predictable certainty. In the
lored to meet employees’ needs; however, Davis event of legal challenges of discrimination in
and Clive contend that general emergency plan- planning, establishing intent or disparate impact
ning for people with disabilities should be an can be difficult. Remember that an emergency
integral part of the entire process—not a separate crisis is an equal opportunity injury-causing
practice or an afterthought. Davis urged agen- event. Finally, these suggestions were offered for
cies to plan for a gap in ability during an emer- those in regional and field offices:
gency, not for disability.
■ Become advocates with regard to emer-
Such an approach to planning would take into gency preparedness planning. Davis
account those who may suddenly need assis- encouraged managers and decision-makers
tance evacuating a building in the event of an to include those who are not typically
emergency. For example, a pregnant woman involved in the internal agency planning
may have difficulty walking down the stairs. If process (e.g., human resources personnel,
certain exits are blocked, a person who uses a and first responders). Consider the com-
50
Emergency Preparedness for People with Disabilities
a vacuum, then buried. Plans should be of this session were to discuss factors and
reviewed, revised, and practiced on a reg- strategies for customizing emergency prepared-
ular basis. ness for people with disabilities. The session
included strategies for ensuring that people
It is helpful for agencies to develop a tem- with disabilities are involved in emergency pre-
plate and methodology around planning,
paredness; planning, tips and tools for areas of
(regular) testing, and updating plans.
specific consideration; and suggestions on how
This can be as simple as a very general
outline that can then be expanded upon supervisors and employees with disabilities can
by individual regions and field offices. together develop individualized plans that
Keep in mind that even within field incorporate the overall agency emergency plans
offices, plans may need to be further indi- and procedures.
vidualized to accommodate individuals or
situations. Since September 11, 2001 the issue of emer-
gency preparedness has come to the forefront.
■ Share information with other agencies Workplace safety is of special importance,
and employees. Determine effective prac- since it is where we, as a society, spend much
tices, and examine the reasons why some- of our time. And, for people with disabilities
thing did or did not work. Clive and and activity limitations, barrier-free, as well as
Davis explained that in such situations, it barrier-ridden, environments can be difficult to
is acceptable to take ideas from another navigate in an emergency situation.
agency. Nevertheless, a 2001 National Organization
on Disability (NOD) /Harris Poll concluded
Davis said that emergency preparedness plans that 50% of employees with disabilities say no
need to become familiar to all personnel at a plans have been made to safely evacuate their
site from the agency/division director to the workplace, compared to 44% of people without
evening cleaning crew, since an emergency can disabilities. Even more revealing is that 18%
occur at any time. This ensures a cadre of of people with disabilities feel extremely or
people in place who are aware; alert; and able very anxious about their safety in the event of
to take quick, appropriate action. a crisis, compared to 8% of people without dis-
abilities.
51
U.S. Department of Labor ■ Office of Disability Employment Policy
He began by explaining that federal agencies As such, Horne suggested employees consider
and their contractors must comply with the the following situations when determining
Rehabilitation Act of 1973, as amended. The whether or not to request assistance:
1990 Americans with Disabilities Act (ADA)
does not require private employers to develop ■ Limitations that interfere with walking or
emergency preparedness plans for people with using stairs;
disabilities. However, if an emergency prepared- ■ Reduced stamina, fatigue, or tire easily;
ness plan is in place, it must include people with ■ Emotional, cognitive, thinking, or learning
disabilities. Even if difficulties;
an employer choos- ■ Vision or hearing loss;
es not to imple- ■ Temporary limitations (surgery, accidents,
ment an emer- pregnancy); or
gency prepared- ■ Use of technology or medications.
ness plan, they
may still be For those who had questions about employees
required to address who may be reluctant to self-identify, Horne reit-
the issue of devel- erated that the information is confidential. As
oping and imple- Kailes (2000, p. 6) explained in her handbook,
menting an emer- “There is a universal human tendency to avoid
Richard Horne, ODEP Supervisory gency prepared- thinking about possible emergencies. This
Research Analyst, responded to ness plan (as a avoidance has greater consequences for people
Seminar participants’ questions in “reasonable with disabilities than for people without disabili-
the Individualizing Emergency
Preparedness Plans breakout sessions.
accommodation”) ties.” Horne stressed that if employees do not
for a person with a plan, then what they need will not be in place
disability, under Title I of the ADA or other laws when necessary; do not assume anything.
and regulations. People with disabilities must take responsibility
52
Emergency Preparedness for People with Disabilities
for engaging in emergency preparedness and not option would be to have security do routine
get caught up in the avoidance tendency. Some checks.
suggestions for encouraging individuals to make
needs known include avoiding use of the term Participants had questions regarding the
disability and conducting practice drills. DOL’s emergency preparedness plan.
Practice drills can be helpful in determining Horne explained that from the very onset,
whether or not assistance is needed during an the needs of the employees with disabilities
emergency. were considered. Following the events of
September 11, Secretary Chao established
Determining who may require assistance during a working group, of which ODEP was
an emergency is only part of process. Emergency a part.
preparedness planning falls into three phases:
“Horne stressed that if employees do not plan, then what they need will not
be in place when necessary; do not assume anything.”
development, implementation, and maintenance. ■ Implementation: An important part of
At both the agency and the individual level, it is this phase is committing the plan to writ-
important that individuals with disabilities be ing. Include key personnel who will likely
involved in the entire process. Horne highlight- be involved during an emergency in this
ed key tasks in each phase, as discussed below: process. Be sure to conduct mock drills in
order to determine where improvements are
■ Development: This phase involves not needed, and make necessary modifica-
only identifying who needs assistance, but tions. Make sure that all employees take
also the possible hazards and accommoda- part in any training that occurs. While an
tions. Aside from the obvious hazards, be individual may not be able to perform cer-
sure to check for such things as obstructed tain tasks, it is important that he/she be
exit routes, unclear signage, or inaudible able to relay the information to another
alarms. In deciding on specific accommo- individual in the event of emergency. Lastly,
dations, it is best to talk to the individual. be sure to distribute the plan in an acces-
However, it may also be helpful to consult sible format, and integrate the concepts or
other agencies (e.g., Federal Emergency plans into the larger office or agency plan.
Management Agency (FEMA)), communi- Oftentimes, emergency preparedness
ty-based organizations (e.g., the Red accommodations made for employees with
Cross, Centers for Independent Living disabilities can benefit all employees.
(CILs)) or local emergency personnel.
■ Maintenance: A plan—whether for an
Horne reminded participants to make sure individual, office, or agency—should be
the plan addressed after-hours situations. updated regularly. It is beneficial to culti-
Attendees wondered how to ensure the vate relationships with individuals and/or
employee’s safety in such circumstances. It agencies both internally and externally.
was suggested that employees inform secu- This can assist agencies in keeping abreast
rity when they are working late. Another
53
U.S. Department of Labor ■ Office of Disability Employment Policy
of new technology or protocol. For individ- The following additional resources were shared:
uals, building relationships with co-workers
increases the chances of finding/getting Job Accommodation Network:
assistance in the event of an emergency. www.janwvu.edu/media/emergency.html
54
CONCLUSION:
PREVAILING
THEMES
U.S. Department of Labor ■ Office of Disability Employment Policy
56
Emergency Preparedness for People with Disabilities
ing information about specific individual needs direct communications from executive-level offi-
violates civil rights protections afforded by feder- cials, such as the agency Secretary. Since the
al laws (e.g., Rehabilitation Act of 1973, as protocols and forms of communications differ
amended). Thus, agency personnel should be from agency to agency, personnel tasked with
carefully instructed on the legal aspects of gath- creating emergency preparedness plans need to
ering such information (e.g., type of information think creatively about obtaining and communi-
that can be gathered and the manner in which cating the vital managerial buy-in.
this is accomplished). Federal laws do not pre-
vent employers from obtaining and appropriately Flexibility
using information necessary for a comprehensive
emergency evacuation plan. Similarly, with Even the best laid plans for an emergency situa-
respect to attitudes toward disability, it is essen- tion can fall prey to unforeseen circumstances.
tial an agency develop a culture where employees In order to minimize the chaos and disorder
feel comfortable sharing the necessary informa- stemming from an emergency situation, an
tion with appropriate individuals. agency emergency preparedness plan must be as
flexible as possible. Although an agency may
Finally, establishing effective means to impart believe it has identified and accommodated all
emergency preparedness and response proce- employees with disabilities, there is a very real
dures is vital to the success of the agency plan. possibility that not everyone who needs assis-
Communication challenges among federal tance in emergencies has self-identified. Indeed,
employees with disabilities vary widely. there also may be instances where an emergency
Therefore, varied, multiple, and redundant situation exacerbates existing impairments or
means of emergency notification and communi- creates new impairments, affecting an individ-
cation are necessary. ual’s ability to evacuate. Recognizing that situa-
tions like these can arise, effective planning prac-
Agency Budget and Personnel tice includes building flexibility into an agency
Commitment emergency preparedness plan.
An effective emergency preparedness plan For example, during the Seminar, there was sig-
requires support and commitment from senior- nificant discussion about the effectiveness of the
level management within an agency. Seminar buddy system. As defined earlier, a traditional
presenters and participants alike commented “buddy system” entails assigning an able-bodied
that an agency preparedness plan will only be as person to a person with a disability for the pur-
good as the financial and personnel resources pose of assisting the employee with a disability
supporting it. The methods of securing and during an emergency. However, reliance on a
demonstrating managerial commitment to single buddy can put the employee at risk, in the
including people with disabilities in emergency event the buddy is not present, able, or willing to
planning vary from agency to agency. At some assist during an emergency. Therefore, “flexibil-
agencies, this has been accomplished through ity” in an emergency preparedness plan is vital.
57
U.S. Department of Labor ■ Office of Disability Employment Policy
Practice
58
RESOURCES
U.S. Department of Labor ■ Office of Disability Employment Policy
60
Emergency Preparedness for People with Disabilities
61
APPENDICES
E M E R G E N C Y P R E PA R E D N E S S F O R
PEOPLE WITH DISABILITIES
An Interagency Seminar of Exchange for Federal Managers
U.S. Department of Labor
December 2–3, 2003
John Benison
Disability Policy Advisor
Office of Civil Rights
U.S. Department of Transportation (DOT)
65
Pamela A. Butler
Deaf and Disabled Persons Employment Program
Manager
Diversity Management and Equal Opportunity Office
Defense Intelligence Agency (DIA)
U.S. Department of Defense (DOD)
Cheryl Heppner
Executive Director
Northern Virginia Resource Center for
Deaf and Hard of Hearing Persons
66
Breakout Session Topic #2: Equipment
Decisions
Edwina Juillet
Co-Founder
National Taskforce on Fire/Life Safety for People
with Disabilities
67
Breakout Session Topic #5: Support
Mechanisms in the Workplace
68
2:40 p.m. — 4:10 p.m. BREAKOUT SESSIONS REPEATED
(Closed to Media)
69
Emergency Preparedness Initiative (EPI)
National Organization on Disability (NOD)
Edwina Juillet
Co-Founder
National Taskforce on Fire/Life Safety for People
with Disabilities
70
O p e n i n g R e m a r k s P re p a re d f o r D e l i ve r y f o r
A s s i s t a n t S e c ret a r y f o r t h e O ff i c e o f
Disability Employment Policy (ODEP)
W. Roy Grizzard, Jr., Ed.D.
Emergency Preparedness for People with Disabilities
An Interagency Seminar of Exchange for Federal Managers
U.S. Department of Labor
Tuesday, December 2, 2003
Good morning. I am Roy Grizzard, Assistant Secretary for the Office of Disability
Employment Policy (ODEP), in the U.S. Department of Labor. It is my distinct pleasure to
welcome you all here today to the Emergency Preparedness for People with Disabilities
Interagency Seminar of Exchange.
This is an important event for us for several reasons, but before I get into that, I would like
to share with you a little background about ODEP, its mission, and its activities.
ODEP BACKGROUND
■ ODEP is the only agency in the Federal Government led by an Assistant Secretary that
deals solely with disability employment policy.
■ ODEP’s overarching goal is to eliminate employment barriers for people with disabilities.
71
■ To achieve its mission, ODEP funds a variety of initiatives, then measures and analyzes
the results to inform the policy development process & to share promising practices
with employers, providers, and others in the workforce development system.
■ Through its Employer Assistance Referral Network (EARN) and its Job
Accommodation Network (JAN) initiatives, ODEP provides technical assistance to pri-
vate sector employers.
■ ODEP serves as a catalyst to bring together federal agencies that address issues and
policies that impact on the employment of people with disabilities. This seminar is an
example of what we do.
ODEP’s goals rest on several core fundamentals. Key among these is that increased employ-
ment opportunities for people with disabilities can be best achieved through a balanced dis-
tribution of elements:
Imagine if you will a balanced scale, with the elements I just mentioned distributed equally
on both sides of the scale. To remove even one of the elements will throw the balance off
completely, resulting in missed employment opportunities.
This seminar is important because it addresses the element of physical safety for people with
disabilities while they are at work. A 2001 Harris Poll, commissioned by the National
Organization on Disability (NOD) showed that among people with disabilities who are
employed full- or part-time, 50% say no plans have been made to safely evacuate their work-
place! With a statistic like this, is it any wonder that people with disabilities are more anx-
ious about their personal safety post September 11th than the general population, as the sur-
vey also indicated?
72
Did you know that workers with disabilities make up 7.0% or 123,000 of the 1.8 million
employees in the federal workforce? Whether these figures strike you as larger or smaller
than you may have expected, the point is that the Federal Government’s diverse workforce
includes people with disabilities. As such, it is imperative that emergency preparedness
processes and strategies address the unique needs of employees with disabilities.
You are here today because your agency or organization recognizes that emergency prepared-
ness for employees and customers with disabilities is important. Throughout this day and
into tomorrow, you will hear from some of the premier experts on issues ranging from egress
to individualized emergency preparedness plans. While you are hear learn all that you can.
Ask questions. Challenge the responses. Share your agency’s experiences.
On behalf of my colleagues at ODEP and the Department of Labor, I wish you all a suc-
cessful and engaging Seminar.■
73
K e y n o t e R e m a r k s P re p a re d f o r D e l i ve r y f o r
U . S . S e c ret a r y o f L a b o r E l a i n e L . C h a o
Emergency Preparedness for People with Disabilities
An Interagency Seminar of Exchange for Federal Managers
U.S. Department of Labor
Tuesday, December 2, 2003
I would like to recognize the staff of the Office of Disability Employment Policy for planning
this intensive two-day seminar. And I would like to thank Assistant Secretary John Henshaw
and Assistant Secretary Pat Pizzella for their support of this important event.
I would also like to welcome the more than 20 presenters who have agreed to share their
expertise on a number of key preparedness issues—especially Dan Sutherland, from the
Department of Homeland Security’s Office of Civil Rights, who took time from his busy
schedule to be this morning’s keynote speaker.
I would also like to recognize the participation of the National Organization on Disability
and its Director, Elizabeth Davis—thank you for your leadership in this critical area.
Today is truly an important milestone for federal emergency planners. We have 225 repre-
sentatives from more than 90 federal offices and agencies with us today. This is the first
time ever that senior personnel from emergency preparedness, security, office safety and dis-
ability programs have gathered together to address emergency preparedness for federal
employees with disabilities.
At the Labor Department, we are working hard to bring people with disabilities into the fed-
eral workplace. As President George W. Bush said, when he announced his New Freedom
Initiatives for people with disabilities, “We must speed the day when the last barrier has been
removed to full and independent lives for every American with or without disabilities.”
To meet this challenge, the Department is involved in a number of key initiatives for people
with disabilities. We’re developing new training initiatives, offering creative placement serv-
ices and adapting new technologies. We are encouraging flextime and easing transportation
74
challenges. Equally important, we’re making the federal workplace a model workplace by
ensuring a safe and secure environment for employees with disabilities.
We are committed to taking the steps necessary to ensure that all federal employees with dis-
abilities are protected during an emergency.
The events of September 11th set up a new challenge in the workplace for people with dis-
abilities—the ability to quickly evacuate employees with disabilities during terrorist threats,
attacks and other disasters.
At the Department, we have always taken the safety requirements of our over 1,000 employ-
ees with disabilities very seriously. We are constantly revising and fine tuning our emergency
preparedness plans. Even prior to September 11th, the Labor Department had plans in place
for the speedy and effective emergency evacuation of employees with disabilities. Since then,
we have strengthened these plans. I convened a Secretarial-level Task Force to improve the
workplace safety of all Department of Labor employees, and people with disabilities were a
key focus of our action plan.
Let me illustrate the importance of planning for these emergencies with a story involving
some of our OSHA colleagues in New York.
In August 2001, OSHA staff at the Manhattan Area Office completed an uneventful evacu-
ation drill from their offices on the top floor of Building 6 of the World Trade Center com-
plex. Managers felt confident that everyone could escape the building safely in an emer-
gency—including an employee who had recently returned to work in a wheelchair. The evac-
uation plan had specifically been revised to accommodate his needs.
Within weeks, the practice proved more valuable than anyone could have imagined.
On the morning of September 11, 2001, OSHA employees had begun a routine day when
an explosion shook the building. The Assistant Area Director immediately issued the order
to evacuate. As the first plane hit the North Tower of the WTC, debris began falling on
Building 6. OSHA staff rushed into the hallway. Three employees helped their co-worker
in the wheelchair down the corridor and into a freight elevator they had used during the prac-
tice drill. They descended to the basement, into a garage, down some steps, and into anoth-
er garage, where they escaped from the building.
75
The group moved outside just as the second plane hit the South Tower. As the group moved
away from the site, the North Tower collapsed, destroying OSHA’s Manhattan Area Office
as it fell. We are so thankful that no Department of Labor employee was lost during that
tragic day. Thanks, in no small part to OSHA’s careful emergency planning, everyone knew
what to do—even in this unprecedented circumstance.
This is a perfect example of why we must have emergency preparedness plans in place for
people with disabilities and why we must perfect these plans with constant practice. Practice
save lives, prevents injuries and helps create the conditions for a calm and professional evac-
uation should it ever be needed.
Every single day, more than 120,000 employees with disabilities go to work in the national
headquarters buildings, regional offices or field locations that are owned by or leased by the
Federal Government. Their safety—and the safety of all federal workers—is our number one
priority.
That’s why we’re having this conference, to guarantee that no federal worker is left behind
in an emergency. We must ensure that everyone has a safe and secure workplace environ-
ment. As leaders in your field, we’ll be looking to you to come up with creative solutions
to the challenges ahead.
During the next two days you will hear from a number of speakers on a wide variety of sub-
jects—from developing communication plans to applying technologies to help in evacuations.
It is critical that you attend these breakout sessions and general panel discussions. We need
everyone’s participation if we are to create federal emergency preparedness plans that save
lives.
So please take advantage of this wonderful opportunity to learn from your colleagues and
expert consultants.
We hope you will return to your agencies with new insights and practical tools to help cre-
ate an ever better emergency management plan for your agency.
Working together, we can create a safe and secure workplace—ready for any emergency.
76
1
The EEOC has identified nine categories of severe disabilities as targeted disabilities for tracking purpos-
es in an agency’s federal affirmative employment program for individuals with disabilities. These disabili-
ties include: deafness, blindness, missing limbs, partial paralysis, complete paralysis, convulsive disorders,
mental illness, mental retardation, and distortion of limbs or spine.
2
A berm is an architectural security design meant to serve as a barrier or to provide insulation; similar to
a moat.
3
Every federal agency has an Employee Assistance Program (EAP), which has a goal to restore employ-
ees to full productivity. More specifically, the EAP provides free, confidential short-term counseling to iden-
tify the employee’s problem and, when appropriate, make a referral to an outside organization, facility, or
program that can assist the employee in resolving his or her problem. It is the employee’s responsibility to
follow through with this referral, and it is also the employee’s responsibility to make the necessary financial
arrangements for this treatment, as with any other medical condition.
4
Brick, K.N., & Heppner, C.A. (2003). Excerpts from Personal Experiences of Deaf and Hard of Hearing
Persons: September 11, 2001 and Its Aftermath. Deaf and Hard of Hearing Consumer Advocacy
Network & Northern Virginia Resource for Deaf and Hard of Hearing Persons.
77
Office of Disability Employment Policy
U.S. Department of Labor (DOL)
200 Constitution Ave., NW
Washington, DC 20210
Voice: (866) ODEP-DOL (633-7365)
TTY: (877) 889-5627