ADA Toolkit

To address the needs of individuals with disabilities in emergency management, President George W. Bush signed Executive Order (EO) 13347, Individuals with Disabilities in Emergency Preparedness (2004), which established the Interagency Coordinating Council on Emergency Preparedness and Individuals with Disabilities (ICC) and directed federal agencies to work together to ensure that emergency preparedness plans incorporate the perspectives and needs of individuals with disabilities. Beginning in 2005, the ICC, other federal agencies, and transportation research organizations began to issue recommendations for better emergency management for people with disabilities. 

Planning for evacuation of community members with disabilities is essential, as demonstrated by devastating effects on people with disabilities during and following Hurricanes Katrina and Rita in 2005. Emergency planning should include outreach and engagement with community members with disabilities. Before, during and after an emergency event, outreach is necessary to educate community members on how to get help. As part of their emergency planning efforts, transit agencies should recognize the needs of people with disabilities. For example, as shared in National RTAP’s October 2019 Transit Disaster Response Twitter Chat, Palm Tran prioritized vulnerable populations throughout Hurricane Dorian. Leading up to the storm, Palm Tran provided over 300 evacuation trips for residents with disabilities and special needs, transporting them to shelters where their specific needs could be met. Palm Tran’s paratransit service continues to provide evacuation services for residents with disabilities when needed, including transporting their life-sustaining medical equipment and other belongings necessary for a three-to-five night stay. See National RTAP’s Transit’s Role in Emergency Response.

Federal Emergency Management Agency’s (FEMA) Comprehensive Preparedness Guide (CPG) 101, Developing and Maintaining Emergency Operations Plans (September 2021, Version 3.0),  provides an overview of information and strategies to ensure resources to strengthen emergency operations plans. ADA requirements, including transportation service needs, are found in Section 1.1.2 - Planning Should Emphasize Caring for People with Disabilities and Individuals with Access and Functional Needs, Infants, Children and Older Adults.



FEMA’s A Whole Community Approach to Emergency Management: Principles, Themes, and Pathways for Action (2011) presents a comprehensive outline of the agency’s Whole Community principles and strategies. These strategies include:

• Identifying barriers to participation in emergency management meetings (e.g., lack of childcare or access to transportation, and time of the meeting) and provide solutions where feasible (e.g., provide childcare, arrange for the meeting to be held in a location accessible by public transportation, and schedule for after-work hours). 
• Considering physical, programmatic, and communication access needs of community members with disabilities when organizing community meetings.
  

• Federal Highway Administration, Evacuating Populations with Special Needs (April 2009) 
• National Council on Disability, Effective Communications for People with Disabilities: Before, During, and After Emergencies (May 2014) 
• National Council on Disability, Effective Emergency Management: Making Improvements for Communities and People with Disabilities (August 2009)
• National Council on Disability, Saving Lives: Including People with Disabilities in Emergency Planning (April 2005)
• Transit Cooperative Research Program Report 150: Communication with Vulnerable Populations: A Transportation and Emergency Management Toolkit (2011)
• U.S. DOT, Departmental Guidelines on Emergency Preparedness and Individuals with Disabilities web page
• National RTAP, Transit’s Role in Emergency Response
• National RTAP, Transit Disaster Response Twitter Chat, October 8, 2019
• Stephenson, Chris, Best Practices: Emergency Response, Mass Transit, November 11, 2019
  

In 2020, the United States experienced a worldwide outbreak and spread of Coronavirus Disease 2019 (COVID-19). For rural and Tribal transit agencies providing service to riders with disabilities, the pandemic raised questions about how to provide U.S. DOT ADA-compliant service while protecting the health and safety of drivers and riders. Many COVID-19 resources were developed for transit agencies. Much of the guidance was specific to ADA compliant service and included best practices for serving riders with disabilities. The guidance and best practices found in the resources below may prove to be helpful to transit agencies preparing a pandemic response plan.

ADA and Face Mask Policies – Transit agencies may want to have a policy on face masks or provide voluntary masks on buses and in waiting areas. The Southeast ADA Center and Burton Blatt Institute (BBI) at Syracuse University maintains a technical assistance web page about face mask policies and the ADA (updated 9/15/2023) which provides examples of people with disabilities who may be unable to wear a face mask. This can include individuals with respiratory disabilities, people with post-traumatic stress disorder (PTSD) and others who may feel afraid when wearing a face mask, people with autism who are sensitive to touch and texture, people with difficulty moving small muscles in the hands, wrists, or fingers, and people who use mouth control devices to operate their assistive equipment.

Technical assistance resources were made available to transit agencies to help them best serve their riders with disabilities during the COVID-19 pandemic. 

• In 2020, the Community Transportation Association of America (CTAA) published a best practices article on wheelchair securement during a pandemic. They recommended asking riders to turn their head towards the window as the driver secures their wheelchair, not having conversations during wheelchair securement, a process for sanitizing securement belts, and offering masks to riders. 
• The National Aging and Disability Transportation Center (NADTC) posted guidance from eight national advocacy agencies representing persons with various types of disabilities on Implementing New COVID-19 Policies for People with Disabilities. 
• CDC published guidance for bus transit operators, paratransit operators, and employers of paratransit operators.

COVID-19 can itself sometimes result in a disability. Guidance from the U.S. Department of Health and Human Services Office for Civil Rights and U.S. Department of Justice Civil Rights Division explains how the symptoms of long-term COVID-19 (“long COVID”) can be a disability under the ADA and other legislation.

Further reading:

• Using Your Safety Management System (SMS) to Mitigate Infectious Disease and Respiratory Hazard Exposure 
• National RTAP's Best Practices Spotlight Article on Coronavirus Disease 2019 (COVID-19)
• National RTAP's Coronavirus Disease 2019 (COVID-19): Information and Resources for Transit Technical Brief
• CTAA's COVID-19 Resources and News web page
• American Public Transportation Association's (APTA) Public Transit Response to Coronavirus or COVID-19 web page
• National Aging and Disability Transportation Center's (NADTC) COVID-19 Resources web page 
• National Aging and Disability Transportation Center's Blog (NADTC) What Have We Learned From the COVID Pandemic? (April 2022)

See the Safety, Security and Emergency Management Section/Lessons Learned from the COVID 19 Pandemic of National RTAP’s Transit Manager’s Toolkit for general information about pandemic planning.

Section Sources