Developing an evacuation plan for people with disabilities
When I was seven years old, I was hit by a drunk driver, which left me paralyzed from the waist down, forcing me to use a wheelchair. In addition to the normal challenges in life, I’ve had to worry about such things as inaccessible buildings and restrooms, lack of curb cuts, and inoperable elevators.
I’m not alone. Roughly 20 percent of the U.S. population is disabled, including those who have mobility impairments, who are deaf or hard of hearing, who are blind or partially sighted, people of size, the elderly, those who have cognitive or emotional impairments, and those who are vertically challenged.
In 1990, President George Bush signed the Americans with Disabilities Act (ADA), requiring that all newly constructed buildings be accessible to people with disabilities. The law also requires that buildings constructed before the ADA was enacted remove barriers when readily achievable.
Over time, the private sector and the federal government have addressed many of these features, barriers, and obstacles. Such codes as NFPA 101®, Life Safety Code®; NFPA 5000®, Building Construction and Safety Code®; the International Building Code; and ICC/ANSI A117.1, American National Standard for Accessible and Usable Buildings and Facilities, have made the spirit and intent of the ADA legislation a reality.
Just as important as making the stock of new buildings accessible, however, is the need to address the safety of the buildings’ occupants, regardless of disability, during an emergency. Although building owners, managers, and tenants now understand that people with disabilities must be allowed into their facilities, these same people often fail to grasp that, legally, they must modify existing evacuation plans to ensure that people with disabilities can safely get out.
We have all heard stories about people being trapped in buildings during fires, earthquakes, and blackouts. During such emergencies, people with disabilities, particularly those with mobility impairments, are even more at risk.
In one case, a wheelchair user was on the 17th floor of a building when a fire broke out. She went as instructed to an area of rescue, a rather standard protocol, where she waited for more than 45 minutes without any communication. Smelling smoke and fearing for her life, the woman struggled out of her wheelchair onto the floor and crawled down hundreds of steps. When she finally reached safety, she was admonished by fire officials for not following “instructions.”
While many people were able to walk to safety during the September 11 attack on the World Trade Center, one wheelchair user perished while waiting to be rescued below the impact floors. The blackout in New York City in the summer of 2003 also highlighted how ill-prepared building owners are to evacuate people with disabilities.
The disabled community is filled with stories like these, stories of people let down by evacuation plans or, more often, faced with plans that make no provision for them.
And the stories are supported by data. In 2001, the National Organization on Disability released a Harris Poll survey of people who are employed full or part time. Among those surveyed, 55 percent said no plans had been made to evacuate people with disabilities safely from their workplace. And most of the plans of those employers who had them amounted to little more than telling people with disabilities to head to an area of rescue and wait. While this may be appropriate in some situations, waiting can increase the potential for tragedy in others.
It’s the law At the federal level, many ADA concepts are codified in the Americans with Disabilities Act Accessibility Guidelines (ADAAG), which state that “Because people with disabilities may visit, be employed, or be a resident in any building, emergency management plans with specific provisions to ensure their safe evacuation also play an essential role in fire safety and life safety.” Similarly, the Title III Technical Assistance Manual notes that a facility “is obligated to modify its evacuation procedures, if necessary, to provide alternative means for clients with mobility impairments to be safely evacuatedwithout using the elevator. The [facility] should also modify its plan to take into account the needs of its clients with visual, hearing, and other disabilities.” Non-compliance can result in expensive lawsuits by private individuals and the Department of Justice.
During a recent emergency evacuation at a Maryland mall, for example, a wheelchair user shopping in a store on an upper floor was led out of the store into the mall with the non-disabled shoppers and into an elevator. However, power to the elevators was shut off, trapping her inside a car alone. It took 45 minutes before anyone realized she was missing. Fortunately she survived. She sued both the mall owner and anchor store and scored a stunning victory in December when the judge in her case ruled that Title III of the ADA applies to the evacuation policies of all places of public accommodation.
Developing a disability evacuation plan Evacuation plans in general have always been an important operating feature of a building. A sampling of evacuation requirements can be found in Section 4.8.2 of NFPA 101, which states that an evacuation plan should include procedures for reporting emergencies, spell out occupant and staff response, include fire drills, and detail the type and coverage of a building’s fire protection systems and other items required by the authority having jurisdiction. The Life Safety Code also states that an evacuation plan “shall be reviewed and updated as required by the authority having jurisdiction.”
These plans must account for a range of events and be robust enough to take all types of occupants into consideration. They must be encompassing, amenable to change, and applicable to a range of occupants with disabilities.
When I work with clients to develop a disability evacuation plan (DEP), I advise them to include the following five steps:
* Learn your building. Do this by carefully studying its layout, taking particular note of all paths of travel, exits, and potential obstacles. * Know who in your building is disabled, employees and visitors alike. * Review your evacuation equipment and signage. If evacuation signage already exists, make sure it identifies any different paths that people with disabilities will have to travel. * Train your staff. You should continually train everyone in general evacuation procedures. * Coordinate with emergency response personnel. Review your DEP with police, fire, and office of emergency management officials.
Learn your building Learning a building is not as simple as identifying exits. You must also look at the floor plan and identify potential problem areas for people with disabilities. The preferred path of travel to an exit will differ based on the type of disability. For example, someone who is deaf or hard of hearing can follow the same path of travel to an exit as someone who is not disabled, while someone with a mobility impairment may not be able to. Wherever possible, identify secondary paths of travel to an exit, in case the primary travel path is blocked.
Local regulations will also come into play here. In certain locations and circumstances, elevators can be used for emergency evacuation. In others, however, they cannot. You should check with your local emergency response personnel to determine your local rules.
You should also designate areas of rescue, also known as areas of refuge, where people with disabilities can await rescue if they are unable to leave the building. And it’s not enough to send people with disabilities to areas of rescue without a plan for letting rescue workers know their location. You must have a strategy for communicating with emergency response personnel, be it by two-way radio, built-in intercom system, or cell phone. In each area of rescue, you should post a sign with the name of the location so that people will know exactly where they are, even in the excitement of a crisis. Note that areas of rescue are not the same in all jurisdictions, so it’s important to check your local regulations.
You will have to make some decisions about the use of stairways during an evacuation. If a stairway is wide enough, someone who is disabled can evacuate with someone who is not disabled by staying to one side. If not, you can either stop someone who is not disabled to allow a person with a disability to exit or wait until the traffic has thinned out. Once you have decided what works best for your building, be sure to remember to communicate it to your staff when training them.
Know your population with disabilities Knowing the population of people with disabilities in the building and where they may be located is critical for a successful DEP.
One way to get this information is to draft a memo to all employees asking about their needs during an evacuation. Place a copy of the memo in employee orientation packets so that, as your workforce changes, your DEP remains current. You should also approach employees with visible disabilities to discuss evacuation issues. As always, you should be respectful of a person’s privacy rights in soliciting any information.
For individuals with cognitive or emotional disabilities, such as autism or Down Syndrome, emergency evacuation assistance involves keeping them calm by giving clear instructions during the evacuation. It’s likely these individuals will be able to use the same routes as the non-disabled, but may do so at a somewhat slower pace.
And don’t forget that some of the building occupants may be temporarily disabled- with a broken leg, for example. You should develop a policy requesting that employees inform a designated person of such a condition and make supervisors responsible for noting anyone with a visible temporary disability.
Visitors with disabilities, such as guests, clients, and customers, present a difficult challenge since you may not even know they are in the building. For tracking purposes, building or floor sign-in sheets can sometimes help.
Determine appropriate equipment Depending on the type of building and its obstacles, such as stairs, certain equipment and signage may be needed. For example, portable, lightweight evacuating chairs may be needed to help wheelchair users up and down stairs. Ramps can be helpful in negotiating one or two steps.
All primary function and public areas should have evacuation signs showing the means of egress and multiple paths of travel if the path to be taken by someone with a disability is different than the one used by the general public. Signs are for directional purposes and should state as simply as possible, “You are here, exit this way.” Signs that convey too much information, are difficult to read, or are hard to find can confuse people and waste valuable time.
Train your staff A DEP is useless unless employees are trained to execute it, it is reviewed periodically, and, to the extent possible, it is practiced. Ongoing training is imperative, and new employees should receive training as part of their company orientation. By training your entire staff, you allow anyone to help a person with a disability in an unforeseen situation.
I advise my clients to assign non-disabled employees to help specific employees with a disability. You have to give a little thought to this process. The assistant should work near the person with a disability and be physically able to help him or her. Just about anyone can help a person who is partially sighted, but an elderly co-worker might not be a good match for a quadriplegic using a power wheelchair. Work schedules, breaks, vacation and sick days, and travel schedules must also be considered.
Employees should be trained to evacuate people with various types of disabilities. For instance, there are special techniques for assisting people who are blind, and these differ depending on whether the person uses a service animal or not. Similarly, the techniques for assisting wheelchair users depend on whether the wheelchair is a power wheelchair. Employees who have been assigned to assist a specific individual should concentrate on learning how to help that person.
Training is one area where you may need outside assistance. The proper techniques, while not difficult to learn, are not intuitive. In fact, as a wheelchair user, I can tell you that many well-meaning people have almost thrown me out of my wheelchair trying to help me down stairs. The mistake: They push my wheelchair forward and push me right down the stairs. Instead, I train people to tilt my wheelchair back and take each step slowly. Similarly, there are techniques to avoid in helping people who are partially sighted and people who are deaf or hard of hearing.
All employees should be familiar with paths of exit for people with disabilities. It’s easy to forget that a particular path has a step and cannot be used by a power wheelchair user. You should also familiarize your employees with the locations of areas of rescue and specialized evacuation equipment.
The key to it all is practice. You should run frequent evacuation drills, including people with disabilities whenever possible, and all employees assigned to help someone with a disability should practice with that person. If you have bought special equipment, you should have all employees practice setting up the equipment; an emergency is not the time to be reading the owner’s manual.
Finally, people with disabilities and those assisting them should be instructed to check in with a supervisor once they have safely evacuated.
Coordinate with local emergency personnel You need to discuss and review your DEP with fire, police, EMTs, and your office of emergency management. Meet with these officials annually, give them copies of your plan, and discuss local regulations and requirements. Walk them around your building so they are familiar with all areas of rescue, and discuss any concerns about your plan. For example, you will need to coordinate with them regarding the use of elevators during emergency evacuations.
After my accident, I worried about being able to play ball with the other kids. Now I worry about my safety whenever entering a multi-story building because I don’t know how comprehensive the evacuation plan is or how well the staff has been trained. I have to be concerned every time I stay in a hotel and discover the evacuation route mounted on the back of the room door fails to tell me, a wheelchair user, what route to take during an evacuation. I think about whether or not I will be able to inform rescue workers of my location if I’m able to reach an area of rescue during an emergency.
There seems to be a wide public understanding that people with disabilities must be allowed into public venues. However, the law also provides for our safe evacuation when we need to get out of buildings during an emergency.
Fire and building officials and human resource managers should consider it their responsibility, as much as it is mine, to make sure building owners include people with all types of disabilities in their evacuation plans. That way, energy can be spent on training and awareness, rather than fighting the lawsuits that would inevitably come with non-compliance.
i Source: U.S. Census Bureau ii Source: ADA Technical Assistance Manual, III-4.2100 General., Illustration 1
Kevin G. McGuire is Chairman and CEO of McGuire Associates, Inc., an ADA consulting firm, and a member of the NFPA Building Code and the Building Systems technical committees. He is also a member of NFPA’s Disability Access Review and Advisory Committee.