Disability Preparedness Innovative Workplace Safety Accommodations for Emergency Response and other Emerging Issues for Hearing-Impaired Workers

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Disability Preparedness Innovative Workplace Safety Accommodations for Emergency Response and other Emerging Issues for Hearing-Impaired Workers Office of Science and Technology Assessment Deborah Gabry, Certified Audiologist 202.693.1983 gabry.deborah@dol.gov

Be Aware and Prepare EXPECT THE UNEXPECTED Disasters and emergencies can strike anyone, anytime, anywhere. Protect yourself, your workers and your business. Be prepared with an action oriented plan to respond quickly and effectively.

During a Workplace Emergency Persons with disabilities may need assistance. Some physical disabilities will be obvious. Some may not be. Mental illness or cognitive disabilities. Every person and every disability is unique. Respecting people with disabilities and treating them with dignity must be part of the response.

Workplace Emergency Plan First Step: Identify people with unique needs and incorporate their specific needs into an emergency action plan. How? Include all employees in emergency planning activities and practice drills. Drills should vary in type and time of day and pose a variety of roadblocks. Proactive efforts will identify the needs and resources to respond calmly when immediate action is necessary.

Real life example of the importance of practiced plans. 8 th Floor WTC 6 Was OSHA s Manhattan Area Office

State of the Union for Americans with Disabilities in 2005 Disability Status: 2000 - Census 2000 Brief 50 million Americans have a disability. 33 million of working age. In case of a terrorist attack, or other crisis at work, have plans been made for safe evacuation? 57% of workers with disabilities say YES 43% of workers with disabilities say NO Harris Interactive Inc., 2005

continued State of the Union for Americans with Disabilities in 2005 Disability Status: 2000 - Census 2000 Brief Disabled workers are still far more anxious and concerned about their personal safety than non-disabled workers. 15% were extremely or very anxious, compared to 8%. 40% were more concerned compared to 33%. Efforts to design and implement disability specific disaster planning does make an impact at work. National Organization on Disability

Remarks at the National Hurricane Conference Dept. of Homeland Security April 14, 2006 45% of people in New Orleans who had to be evacuated to the Astrodome were connected to disability. No access to the vital flow of information for people identified as deaf or hard-of-hearing.

The Federal Response for Individuals with Disabilities in Emergency Preparedness: Established the government s role in support of individuals with disabilities in disasters and acts of terrorism. Created the Interagency Coordinating Council (ICC) on Emergency Preparedness and Individuals with Disabilities to address these critical issues. Presidential Executive Order 13347 (issued July, 2004)

ICC Achievements A Framework of Emergency Preparedness Guidelines Preparing the Workplace for Everyone: Accounting for the Needs of People with Disabilities (July 2005) A tool for emergency planners, managers and employees to assist in developing, implementing and maintaining emergency plans that include employees with disabilities.

ICC Recommendations Key Recommendations include: 1. Increase participation of people with disabilities in emergency planning, preparedness, response and recovery drills and exercises. 2. Provide effective audio, visual and or tactile protocols and technologies related to emergency preparedness, alerting, warning and response for individuals with disabilities.

Unique Workplace Challenges Challenges Include: Receiving emergency notifications Evacuating safely in an emergency Receiving training Receiving communications Responding to workplace safety hazards

What is OSHA s Role? OSHA standards address emergency planning requirements. OSHA publishes Safety and Health Information Bulletins (SHIBs.)

Standards with emergency planning requirements DO YOU NEED an EAP? Emergency Action Plan Standard (EAP) 29 CFR 1910.38 Other OSHA standards that have emergency action planning requirements: OSHA Publication 3088, page 11

Safety and Health Information Bulletins SHIBs: 1. Innovative Workplace Safety Accommodations for Hearing- Impaired Workers July, 2005 2. Hearing Conservation for the Hearing-Impaired Worker January, 2006 Highlights needs of hearing-impaired workers: 28 million Americans have hearing loss Numbers will increase www.osha.gov

Impact of Hearing Loss on Workplace Safety Concerns of Hearing-Impaired Workers Understanding verbal warnings or instructions Hearing emergency notification alarm systems Being able to communicate if they are trapped Following conversation at meetings Localizing sound to detect an approaching forklift Hearing the telephone ring/conversing on the phone Understanding the instructor in training sessions Trying to take notes and listen at the same time

Workplace Accommodations Implementing workplace accommodations for disabled workers will help all workers feel safe. Choose the option or combination that works best for each individual situation with regard to: * Alerting devices * Training/communication accommodations * Safety accommodations

Alerting Device Options Auditory, Visual and/or Tactile Alerting devices include: Flashing exit signs Flashing strobe lights Vibrating smoke alarms Vibrating pagers Amplified telephone ring signalers TTY/TDD telephone for hearing-impaired Flashlight for signaling location Buddy support network Hearing dogs

Training/Communication Options Communication is essential to emergency preparedness and to creating a safe workplace culture. Communication to employees with disabilities must be as effective as those to non-disabled employees. The how to may be a challenge for employers

Critical Questions about Communication Is emergency preparedness information communicated with the same frequency and level of detail to all employees? Are services provided when necessary for communication with deaf or hard of hearing employees? Use of assistive listening devices, CART, sign language interpreters Is information on emergency preparedness easy to locate and available in text version; are there text descriptions for images, graphics and charts? Is information accessible to blind/low vision employees who use screen readers, or those who may use speech recognition technology? Are emergency preparedness training sessions and meetings in accessible locations? Preparing the Workplace for Everyone, July 2005

Training accommodations include: Captioned videos TTY video conferencing Computer assisted notetaking Communication Access Realtime Translation Assisted Listening Devices Sign language interpreter Telecommunications Relay Service

Workplace Safety Issues and Accommodations Issue: not being able to hear approaching powered industrial trucks or other moving equipment. Suggested accommodations: Designate a path with paint, rope, or tape Separate entrances for people and forklifts Require moving equipment to stop at all intersections Install directional warning sensor lights Install mirrors at all intersections Place a vibrating pager in vehicle and on employee Use of high visibility vests in high traffic areas Sensor light Mirror Barrier www.workplacegroup.net

Other Hearing Conservation Issues related to Hearing-Impaired Workers: Issue: Hearing-impaired workers may have difficulty using conventional hearing protectors that are worn by the majority of the workforce because these protectors may reduce the incoming sound below their ability to hear it. Remedy: Sounds may seem distorted and muffled, making communication difficult Specialized hearing protectors exist that help with communication in noisy situations and be able to hear warning signals without overexposure to dangerous noise levels.

Continuation of special hearing conservation issues Issue: Wearing hearing aids in high noise areas: Concern is that since hearing aids amplify both speech and noise, wearing hearing aids alone without additional protection can lead to overexposure. Remedy: On a case-by by-case determination, hearing aids can be worn under an earmuff.

Challenge Protecting hearing-impaired workers from suffering additional hearing loss in noisy work environments is a challenge. They need to: Be able to communicate Hear warning signals Hear approaching moving equipment or trucks Feel safe on the job.

Conclusion Preparedness and a safe workplace culture for all workers including those with disabilities can only be achieved through: Planning Providing information Receiving input from all workers Providing accommodation choices A commitment from management Implementing the preparedness plan Practicing the preparedness plan

Handout Material Supplemental Information

Additional ICC Achievements 1. National Security Emergency Preparedness Telecommunications Service Priority: Ensures restoration of telecommunication services after a disaster for people with hearing and speech disabilities, and enforces the Federal Communications Commission s (FCC) Access to Emergency Information Rules.

ICC Achievements 2. Disability Preparedness Resource Center website (July, 2005) Consolidates information on emergency preparedness and response for individuals with disabilities and emergency planners, first responders and service providers at www.dhs.gov/disabilitypreparedness 3. Enforcement of the ADA Access to Local Community Emergency Preparedness and Response Program: Ensures that local government emergency management programs address needs of persons with disabilities.

ICC Achievements 4. Emergency Preparedness Grant- A model emergency preparedness community education program to serve people who are deaf, hard-of-hearing or blind. 5. Emergency Preparedness NOW: A quarterly newsletter that features effective emergency preparedness practices and spotlights individuals who make an impact on emergency preparedness for individuals with disabilities. (July, 2005)

ICC Recommendations 1. Increase participation of people with disabilities in emergency planning, preparedness, response and recovery drills and exercises. 2. Provide effective audio, visual and or tactile protocols and technologies related to emergency preparedness, alerting, warning and response for individuals with disabilities. 3. Integrate needs of individual with disabilities into the National Response Plan (NRP) and the National Incident Management System. 4. Provide effective audio, visual and or tactile protocols and technologies related to emergency preparedness, alerting, warning and response for individuals with disabilities.

Disaster Preparedness TIPS for Personal Supplies If You Are Deaf or Have a Hearing Loss: Have a small portable battery-operated television set. Emergency broadcasts may give information in American Sign Language (ASL) or open captioning. Keep pads and pencils in your home supply kit and in your car. Have them with you at all times for communication. Keep a flashlight, whistle (or other noisemaker) and pad and pencil by your bed. Keep a card in your disaster supplies kits and with you at all times that indicates that you are deaf. Include any other appropriate communication information such as, "I do (or do not) know American Sign Language (ASL)," or, "My service animal may legally remain with me." (www.prepare.org/disabilities/disastersupplies.htm)

Federal Agency Resources Public Education Websites Department of Labor www.dol.gov ODEP Office of Disability Employment Policy www.dol.gov/odep/programs/emergency.htm Department of Homeland Security www.disabilitypreparedness.gov Department of Justice www.justice.gov Disability Rights Section ADA Information Services www.ada.gov Disability Information: www.disabilityinfo.gov National Institute for Occupational Safety and Health www.cdc.gov/niosh/topics/

Federal Agency Resources Public Education Websites The Access Board www.access-board.gov Independent Federal Agency Department of Commerce www.doc.gov National Oceanic and Atmospheric Administration www.noaa.gov Department of Transportation www.dot.gov Fire Administration www.usfa.gov Department of Education www.ed.gov National Institute on Disability and Rehabilitation Research (NIDRR) Federal Communications Commission www.fcc.gov For information on Telecommunication Relay Services

Other Resources National Organization on Disability, www.nod.org Principal Emergency Response and Preparedness, Requirements and Guidelines, OSHA publication 3122, 2004. How to Plan for Workplace Emergencies and Evacuations, OSHA publication 3088, 2001. Online Emergency Assistance Information- OSHA s Emergency Preparedness and Response Page, at www.osha.gov

Other Reference Material Individuals with Disabilities in Emergency Preparedness, Executive Order 13347 Annual Report, July 2005 Department of Homeland Security A Framework of Emergency Preparedness Guidelines for Federal Agencies, Preparing the Workplace for Everyone, July 2005, ICC Subcommittee on Emergency Preparedness in the Workplace,(www.dol.gov/odep) U.S. Census Bureau, Census 2000 at www.census.gov/hhes/www/disability/disabstat2k/ta ble1.html