ADA Toolkit

Customer service and sensitivity are very important when serving persons with disabilities. The U.S. DOT ADA regulations include specific training requirements for assisting these riders. From Section 37.173 – Training Requirements: 

“Each public or private entity which operates a fixed route or demand responsive system shall ensure that personnel are trained to proficiency, as appropriate to their duties, so that they operate vehicles and equipment safely and properly assist and treat individuals with disabilities who use the service in a respectful and courteous way, with appropriate attention to the difference among individuals with disabilities.”

For example, drivers need to be able to properly operate wheelchair lifts, ramps, and securement equipment, and know what to do in emergencies when serving riders with disabilities. Some disabilities may be hidden or not easy to see. Personnel also must be trained on how to assist these riders respectfully and with sensitivity to their different abilities and needs. While not intended to be a substitute for training, the Customer Service Guidelines section below includes helpful information and resources related to serving riders with a broad range of disabilities. 

The training requirement applies to all public and private transportation providers. Transit agencies that contract for services need to ensure that the employees of contractors are trained to proficiency. 

Section 2.9.1 of FTA ADA Circular 4710.1 provides examples of personnel training topics appropriate for different responsibilities. The following examples are related to rider assistance and sensitivity:

• Drivers – Properly operating all accessibility equipment and features; providing appropriate assistance to individuals with disabilities with boarding, alighting, and securement; communicating effectively with individuals with different types of disabilities; making stop announcements and route identification announcements; and positioning the bus so that the lift or ramp can be safely deployed and used.
• Customer service agents, designated employees who respond to complaints, and call-takers – Communicating effectively with individuals with different types of disabilities; explaining the complaint-resolution process; and providing service information (e.g., routes, schedules, and fares) with special attention to the needs of individuals with disabilities. This includes use of text telephone (TTY) relay services to communicate with individuals with speech and hearing disabilities. 
• Vehicle dispatchers – Understanding all operating policies and procedures to effectively and properly assign and route vehicles, assisting drivers on issues that arise pertaining to accessible service, and communicating effectively with individuals with different types of disabilities.
• Managers and supervisors – Understanding all operating policies and procedures and supervising employees to ensure they provide proper and consistent levels of service to individuals with disabilities.

As discussed in Section 2.9.2 of FTA ADA Circular 4710.1 and Appendix D to 49 CFR Part 37, FTA encourages transit agencies to collaborate with local disability organizations for assistance with employee training. Involving individuals with disabilities in agency training programs helps to demonstrate appropriate types of assistance and provides a forum for discussion of what does and does not work in practice.

ADA driver training resources with a focus on rider assistance and sensitivity include: 

• The National Aging and Disability Transportation Center (NADTC) Access Matters Video Series was created to train drivers to be more sensitive to the needs of people who are blind, deaf and have other disabilities who rely on public transportation. The series of five videos covers important topics such as communication, service animals, what access means, and tips for serving people with a variety of disabilities. 

• Access Matters: What Does Access Mean?
• Access Matters: Communication
• Access Matters: Various Disabilities
• Access Matters: Service Animals
• Access Matters: Different Types of Assistance



• The Community Transportation Association of America (CTAA) offers Passenger Assistance Safety and Sensitivity (PASS) Training. According to CTAA, “emphasis is on the passenger and ensuring the safety and comfort of the passenger at every step of the boarding and deboarding process.” The Understanding Your Customers and Medical Conditions modules include information and helpful strategies on providing service to riders with “hidden disabilities,” including those with autism and dementia. These modules also provide guidance on what to do to assist (before emergency responders arrive) in the event of a stroke, diabetic emergency, or seizure. 
• National RTAP’s ADA Driver Training and ADA Driver Training Hands-on Evaluation. This training includes a section on Special Considerations (Service Animals, Children, Guests, Challenging Situations) and a form for transit agencies to document training for drivers that provide service to persons with disabilities.
• Easterseals Project Action offers Sensitivity Training for Bus Drivers. This training covers various topics including assisting difficult customers, driver assistance and the ADA, service animals, effective communication, and disability awareness and sensitivity. The Effective Communication section includes a focus on “effective communication in the moment.”  This workshop is appropriate both for fixed-route and demand responsive bus drivers. 
  

Here are some important customer service guidelines for serving riders with disabilities, adapted from the National Aging and Disability Transportation Center’s Transit Operator’s Pocket Guide unless otherwise noted.

• Treat riders with disabilities with courtesy and respect.
• Give riders with disabilities the same information and choices you give other riders.
• Never make assumptions about your riders’ physical or intellectual abilities.
• Ask riders if they need assistance—don’t assume. 
• Do not touch riders without their permission.
• Speak directly to riders, not their companions. 
• Speak clearly with a normal tone and speed, unless the rider requests otherwise. 
• If you are asked to repeat or write what you said, do so calmly and pleasantly.
• Be patient and allow riders to take their time. Respond in a calm, professional manner. 

As stated in the Transit Operator’s Pocket Guide, communication with people with disabilities follows the basic rules of customer service and good manners. 

• Emphasize the person, not the disability. Use person-first language, such as “people with disabilities” instead of “the disabled.” 
• Greet riders and inform them of your bus route and destination. Announcing both the route and destination at stops served by multiple routes assists riders with visual impairments as well as riders unfamiliar with the route, bus stop or general area. 
• Refer to landmarks or other visual cues to help the rider understand direction. 
• Be willing to repeat information and break information down into smaller pieces.
• When riders are disembarking, alert riders to any barriers or obstacles around the bus stop.

Addressing Transportation and Accessibility for All, Invisible Disabilities: Seeing the Unseen, TR News, Number 346. (July-August 2023) describes the challenges of many individuals who have disabilities that are not visible and can pose significant transportation accessibility challenges. Full accessibility requires public transit staff and the traveling public to be aware of invisible disabilities and to understand how to accommodate them. To help achieve this, the following actions are suggested:

• Implement awareness campaigns describing the needs and behavior of people with invisible disabilities.
• Offer transit travel training programs to anyone wishing to increase their confidence when traveling.
• Train all transit personnel to help all riders, regardless of whether they appear to have a disability.
• Provide transit travel assistance cards to help riders request appropriate assistance. 
• Offer information about transportation stops through multiple means, including communication boards, audio, and text displays.
• Provide audio and visual information about the route, final destination, and next stop on all buses and trains.
• Use display signs on all transit, encouraging other riders to offer their seats to people in need and empower people with invisible disabilities to request seats when needed.
• Consult with riders with disabilities to develop street signage around transit stops to improve navigation and accessibility.
• Introduce safe places and use “Help, I’m lost” cards to enable people with invisible disabilities to obtain appropriate support when traveling.
• Include maps with quiet routes for walking through noisy urban areas to assist people who find noise stressful.

The United Spinal Association’s Disability Etiquette Guide: Tips on Interacting Respectfully with People with Disabilities (2023) provides examples and helpful communication tips for riders with a variety of disabilities.

• Physical: People Who Use Wheelchairs or Other Mobility Devices. These conditions impact a person’s ability to move their body. Examples include spinal cord injury, spina bifida, cerebral palsy, stroke, arthritis, and multiple sclerosis. A person may use a cane, crutches, a walker or a wheelchair to get around, while others may not be able to move their arms or legs at all. Take care not to generalize or make assumptions about a person’s ability based on whatever tool they use to access their home and community. 
• Sensory: People who are blind, low vision, deaf, or hard of hearing. This category primarily refers to conditions that impact a person’s ability to see or hear. Some people may be totally blind, while others may be able to read a little bit or see color. Deaf people have created a vibrant culture with its own literature and language. People who lose all or some of their hearing later in life are typically referred to as being hard of hearing or having a hearing impairment. 
• Neurodivergence: People whose brains develop or work differently. This term arises from the Autistic community and includes all the ways some people’s brains may work differently than those who are neurotypical. Attention-deficit hyperactivity disorder, brain injury, Tourette’s Syndrome, dyslexia and mental health conditions all fall under this broad category. 
• People with Intellectual Disabilities. Intellectual disability can be seen as a subset of neurodivergence but deserves its own category as it may require different accommodations than other disability types. Examples include Down syndrome, Fragile X and developmental delay. Although disabilities may seem to fit specific categories, people are not easy to sort.

The following Top Ten Disability Etiquette Tips   are adapted from the United Spinal Association’s Disability Etiquette (2023) web site to be of use to transit staff. 

1. Ask before you help. Don’t assume that because a person has a disability, they need help. Usually, they will ask if they need assistance. If you offer and they accept, follow their instructions. They know their capabilities. 
2. Do not touch, pat or grab. No one wants to be touched without consent, including people with disabilities. Do not touch, grab, or guide them or their wheelchair, scooter or cane without permission. Remember that people with disabilities consider their equipment part of their personal space. 
3. Speak directly to the person with a disability. Also, while striking up a conversation is great, remember that most people, including those with disabilities, would rather not discuss their bodies or medical history with people they just met. 
4. Avoid making assumptions. People with disabilities are the best judge of what they can or cannot do. Remember, it could violate the ADA in many situations to exclude people from an activity because of their disability. 
5. Be open to requests for access or accommodation. Ensuring accessibility and committing to reasonable accommodations upon request not only complies with anti-discrimination laws but also showcases excellent customer service and dedication to all members of the community. 
6. Use respectful, person-first language. Avoid saying handicapped or wheelchair bound. Instead, say person with a disability or wheelchair user.
7. Provide a clear path of travel. Ensure there are no obstacles that could hinder or trip people with physical disabilities or visual impairments.
8. Welcome service animals. By law, service or support animals can accompany their handlers anywhere they go. If the animals are not well-behaved and harnessed, leashed, or tethered, you may ask the owner to remove them.
9. Remember, some disabilities are invisible. People with autism or intellectual disabilities may process information differently than others, so be patient and understanding when communicating with them.
10. Be respectful. People with disabilities are individuals with families, jobs, hobbies, likes and dislikes, and problems and joys. While their disability is integral to their identity, it does not define them. 

There are also specific guidelines that personnel should be trained on for assisting individuals with different types of disabilities. Here are some tips for staff to keep in mind when serving the following populations, adapted from the Transit Operator’s Pocket Guide except where otherwise noted. 

• Face riders when speaking to them, and don’t let objects obstruct their view. 
• Do not raise your voice – doing so distorts your lip movement and makes lip reading difficult. 
• Be sure to notify the rider of schedule changes or audible announcements.

Easterseals Project Action’s Sensitivity Training for Bus Drivers (see Personnel Training Requirements Section above) also includes the following communication tips for serving riders whose speech is difficult to understand.

• Display empathy
• Do not interrupt, hurry the person, or finish their sentences
• Have pen and paper available
• Ask yes/no questions
• Ask the person to repeat and/or spell words
• Just because you don’t understand them, that doesn’t mean they don’t understand you
• BE PATIENT!

See Effective Communications with Travelers who are Deafblind, a 26-minute training video for frontline transit personnel, on effective communications with riders who are deafblind from Sound Transit from Seattle, WA. 

• Identify yourself and ask how you may be of assistance
• Respond verbally when customers give you information so they will know that you have heard them.
• Remember to announce the rider’s stop.
• When handling a monetary transaction, count the rider’s change out loud.
  

• Ask riders how you can assist them.
• Wheelchairs, walkers, canes, and other mobility devices are part of the rider’s personal space. Do not hold or lean on them without the rider’s permission.
• Make no assumptions on how to operate mobility aids.



For more information, see the Accommodating Riders Who Use Mobility Devices page of this Toolkit .

• If drivers are unsure that an animal is a service animal, they may inquire if the animal is a pet or a service animal required because of a disability. If the rider responds that the animal is a service animal, drivers may ask what work or task the animal has been trained to perform. Drivers cannot require special identification for a service animal, inquire about a rider’s disability, or ask for a demonstration of the tasks that a service animal has been trained to perform.
• Never touch or talk to a service animal—the animal is working!



For more information, see the Service Animals section of this Toolkit.

The following communication tips are adapted from the Job Accommodation Network’s Communication Tips for Working with Individuals with Intellectual Disabilities:



• Consider the environment and what is going on around you. There may be multiple background noises and voices that can be a distraction to the person with whom you are talking. 
• Speak slowly and pause while talking to allow more time for the information to be absorbed. 
• Speak directly to the individual and make eye contact to ensure you have their attention.
• Speak in clear short sentences, avoiding words or terms that are complicated, technical, and difficult to understand. 
• Don’t raise your voice. Sometimes when people are making a special effort to ensure the other person in a conversation understands what they are saying, they tend to speak louder. 
• Ask the individual you are speaking with if they have any questions. Questioning is an effective way to monitor comprehension. 
• Allow individuals plenty of time to formulate a question in their mind before verbalizing it. You may need them to repeat the question or ask them to clarify what they are asking. 
• Ask only one question at a time and allow plenty of time for a response. Expressive language skills are often limited. 
• Be patient. You want to make sure that the person understands you, and that you understand them in return. 
• Allow plenty of time for the conversation to take place and for the individual to hear and process what you are saying and then to respond. 
• Ask the individual to repeat back the information you have given.
  

The Job Accommodation Network’s web page on autism spectrum disorder (ASD) describes ASD as a neurodevelopmental disorder that is characterized by persistent deficits in social communication and social interaction across multiple contexts, including deficits in social reciprocity, nonverbal communicative behaviors used for social interaction, and skills in developing, maintaining, and understanding relationships. This site also contains communication tips that may be adapted for specific use with to public transportation customers with autism.

The United Spinal Association’s Disability Etiquette Guide: Tips on Interacting Respectfully with People with Disabilities (2023) includes ways to be present for people with neurodivergent brains: People Whose Brains Develop or Work Differently. This list offers tips for communicating with a broad category of neurodivergence that includes autism, ADHD, brain injury, mental health, Tourette’s syndrome and similar disabilities or conditions. The adapted list follows: 

1. Be patient. People with neurodivergent brains may process information differently than you do, so be patient and understanding when communicating with them. They may need more time to process what you’re saying, or they may ask questions that seem obvious to you. 
2. Be open-minded. Don’t assume that someone with a neurodivergent brain understands what you’re saying or that they’re thinking the same thing as you. Ask questions and clarify things if you’re not sure. 
3. Be respectful of their boundaries. People with neurodivergent brains may be sensitive to noise, light, or touch. Respect their boundaries and ask them what they need to feel comfortable. 
4. Be clear and direct. People with neurodivergent brains may not pick up on social cues as easily as neurotypical people. Be clear and direct in your communication and avoid sarcasm or humor. 
5. Be supportive. Some people with neurodivergent brains stim or engage in repetitive movements or behaviors. This can be a way for them to self-regulate and cope with stress. It’s perfectly normal and helpful for them to do so. 
6. Be calm. Some with neurodivergent brains can be overwhelmed by too much sensory stimulation. Avoid making loud noises or sudden movements and respect their need for personal space. When planning an event, set aside a quiet, welcoming space for those who need a break. 
7. Be flexible. Let people with dyslexia take their time when reading or writing. Offer them accommodations, such as reading aloud or using a computer with a text-to-speech function. 
8. Be understanding. Act natural and ignore tics if you are talking to someone with Tourette’s Syndrome. They’re involuntary and drawing attention to them is unkind. 
9. Be aware. Brain injuries can affect mood and behavior, so it’s important to be patient and understanding if the person has outbursts or seems emotional. 
10. Be responsible. Do not interfere with a person who seems to be experiencing a mental health crisis unless you are trained to do so. They may be acting in ways that are strange to you but normal to them. Sometimes more harm can be caused by trying to help than by letting them be. 

Additional transportation related resources and training to consider:



The National Center for Mobility Management (NCMM), FTA, and U.S. DOT’s webinar, Transportation and Mobility Options to Support Postschool Transition for Youth with Autism. This webinar focuses on transportation and mobility services for youth with autism transitioning out of high school.

As discussed in the introduction to Rider Assistance and Customer Service section above, riders with invisible disabilities, like epilepsy, may not be readily identifiable. Transit staff should be trained to recognize the signs of a seizure and be prepared to assist, as appropriate. The following resources will help transit staff understand epilepsy and how persons with epilepsy are covered under the ADA. 



• Epilepsy Education Everywhere (EEE) contains information on its Resources and Downloadables web page that may be useful in training staff on epilepsy basics and first aid. This site also includes a paper, Americans with Disabilities Act: An Overview, that details the transportation services available to persons with epilepsy through the ADA.
• The Epilepsy Foundation is a resource for Seizure Recognition and First Aid certification training. Seizure First Aid and Seizure Recognition Flyers are also available from the website. 
  

The Job Accommodation Network offers the following considerations for interacting with individuals with psychiatric disabilities:



• Avoid stereotypes and assumptions about the individual and how they may interact with others. In most cases, it will not be obvious that someone has a psychiatric impairment.
• Recognize and respect the differences in people. People with psychiatric impairments may behave differently than other individuals, may have trouble interpreting social cues, or may have different ways of coping with their impairment.
• Respect personal space and do not touch the individual or his personal belongings.
• Provide support and assistance, as appropriate.
• Be patient. Allow the individual time to think and answer questions independently.

The Social Security Administration considers Post Traumatic Stress Disorder (PTSD) a disability.  PTSD is a mental disorder that can develop after a person of any age directly experiences or witnesses a traumatic event, such as exposure to war, threatened or actual physical assault, threatened or actual sexual violence, a violent crime or serious accident, or a natural disaster.  Transit personnel should treat persons with PTSD with sensitivity.

While not specific to homeless populations with disabilities, TCRP Research Report 242, Homelessness: A Guide for Public Transportation (2024), is a good starting place for learning more about the issue of homelessness and how the transit industry has come to see this challenge as one that they must partner with other community services such as law enforcement, non-profit organizations, and social service providers to resolve. The focus of the guide is to relay information on how public transportation agencies and stakeholders can work collaboratively to support homeless individuals and mitigate impacts on public transportation services and facilities. It uses a U.S. Department of Housing and Urban Development (HUD) and the U.S. Department of Education (ED) definition of “chronically homeless” which includes people with disabling conditions (mental illness, substance use disorders, and physical disabilities). Chapter Six: Supporting People Experiencing Homelessness includes interviews with staff at nine transit agencies to highlight specific outreach and supportive services programs aimed at lessening the impacts of homelessness while supporting efforts to aid people experiencing homelessness. The detailed descriptions of current approaches and best practices from the agencies interviewed include providing information, building relationships with people experiencing homelessness, connecting people to services, employing outreach services, providing services on-site, adopting alternative policing and emergency responses, and de-emphasizing minor infractions. This report also updates TCRP Synthesis 121: Transit Agency Practices in Interacting with People Who Are Homeless (2016). 

APTA’s Public Transit and Social Responsibility: Homelessness (2018) report includes summarizations of interviews with transit leaders and social service personnel as well as transit security officers, police officers, crisis intervention officers, and staff at social service agencies and volunteer organizations. 

The TRB Webinar: Respectful Response to People Experiencing Homelessness in Transit (March 25, 2024) presents TCRP Research Report 242, Homelessness: A Guide for Public Transportation (2024) and highlights efforts by the Southeastern Pennsylvania Transportation Authority (SEPTA) and the National Transit & Vulnerable Populations workgroup (an informal workgroup created in 2021 by individuals at more than a dozen transit agencies across the United States who meet to discuss issues of safety and homelessness at their transit systems. SEPTA has been an active partner with local and regional homeless service providers in addressing homelessness. SEPTA, the City of Philadelphia’s Office of Homeless Services, the Department of Behavioral Health and Intellectual Disabilities, and the Philadelphia Police Department work together to coordinate homeless outreach, services, and enforcement. 

An article on ECHO, Austin/Travis County’s Homelessness Response System (HRS) website, Free bus rides: How to get your permanent free fare card from CapMetro (November 2023) describes how local bus service, Capital Metro, in Austin and Travis County, Texas, is free for anyone experiencing homelessness with a new fare card. Plastic cards provide no-cost rides to people who’ve engaged in some way with HRS.

There are rider scenarios that may be challenging for drivers. FTA encourages transit agencies to make reasonable attempts to resolve issues with riders or, if appropriate, personal care assistants (PCAs), caregivers, or guardians, before refusing service to an individual with a disability. For tips for helping riders in challenging situations, see National RTAP’s Problem Passengers: Managing Difficult Passengers & Situations Learner's Guide. Some specific scenarios are described below along with the applicable ADA requirement(s).

Transportation providers are not required to provide service to an individual with a disability if that individual engages in violent, seriously disruptive or illegal conduct, or who represents a direct threat to the health or safety of others [Section 37.5(h) of 49 CFR Part 37]. Transit agencies should have policies and procedures in place to address disruptive riders and enforce the procedures consistently among all riders. 

A transit agency cannot require that an individual with a disability be accompanied by a personal care attendant (PCA) [Section 37.5(e)]. However, the transit agency is not required to provide attendant services and may refuse service to someone who engages in violent, seriously disruptive, or illegal conduct. If a PCA would be able to stop such conduct, the transit agency could require an attendant as a condition of providing service it otherwise had the right to refuse [Discussion of Section 37.5(e) in Appendix D to Part 37]. Make sure there is a real issue here based on actual experience. If there is (and it is beyond the normal transit-related duties of a bus driver), the transit agency can speak to the rider and explain that they cannot continue to ride unless there is a PCA available. The PCA must ride for free when accompanying the eligible rider. If not accompanying the ADA eligible rider, the PCA must pay a fare [Section 37.131(c)(3)].

Service cannot be refused solely because the individual's disability results in appearance or involuntary behavior that may offend, annoy, or inconvenience others. Transit agencies should consider having a policy about hygiene that is simple to implement by bus drivers, applies to all riders, and reflects the overarching nondiscrimination regulatory language [Section 37.5(h) of 49 CFR Part 37]. For example: 

• A rider has body odor due to a soap allergy. It would not be appropriate to refuse service if the hygiene situation were merely unpleasant to other riders or drivers (Section 2.2.7 of FTA ADA Circular 4710.1). However, if the situation disrupts the provision of service, grounds for refusing service may exist.
• A rider appears to present a biohazard. If there is a direct threat to the health and safety of others, the driver can deny the trip to the rider. However, drivers should make sure that this is a real, direct biohazard threat (for example, blood, urine, or fecal matter) rather than a perceived concern. National RTAP’s 2 The Point: Bloodborne Pathogens training states that workplace transmission of bloodborne pathogens can include when a rider has an open wound, like from skinning their knee. Transit agencies should have policies and procedures in place to address the suspension of riding privileges due to health and safety concerns. Such a policy must also include guidance on how a rider can get those riding privileges returned, including an appeals process to dispute the suspension.
  

The U.S. Access Board’s webinar, Enhancing Accessibility Through Customer Experience, held on September, 24, 2024, explains and demonstrates how customer experience (CX) can improve accessibility. The webinar described the key aspects of the federal government’s Federal Customer Experience (CX) initiative, including its relationship to Section 508 of the Rehabilitation Act of 1973. The presentation and accompanying handouts will be of value to rural and Tribal transit agencies who want to learn more about moving beyond ADA accessibility compliance regulations moving beyond ADA accessibility compliance regulations and toward a more accessible design. According to the webinar, a CX approach is to enhance customer experience by:

• Developing accessible Information Communication Technology (ICT)
• Implementing usability best practices
• Integrating user experience guidelines such as using plain language

Also related is Executive Order 14058: Transforming Federal Customer Experience and Service Delivery to Rebuild Trust in Government (December 13, 2021).