[Front Cover] Federal Communications Commission Section 504 Programs & Activities Accessibility Handbook Federal Communications Commission Consumer & Governmental Affairs Bureau 445 12th St. S.W. Washington, DC 20554 1-888-CALL-FCC (1-888-225-5322) TTY: 1-888-TELL-FCC (1-888-835-5322) www.fcc.gov/cgb/ [Page i] TABLE OF CONTENTS I. INTRODUCTION 1. SECTION 504 HANDBOOK 2 2. BASIC PRINCIPLES OF ACCESS 3 3. SECTION 504 OF THE REHABILITATION ACT 4 4. DISABILITY RIGHTS MOVEMENT 5 II. ACCESSIBILITY AND THE FCC 1. TYPES OF ACCESS REQUESTED 8 ACCESS FOR PEOPLE WITH MOBILITY IMPAIRMENTS 8 ACCESS FOR PEOPLE WHO ARE BLIND OR HAVE LOW VISION 8 ACCESS FOR PEOPLE WHO ARE DEAF OR HARD OF HEARING 9 ACCESS FOR PEOPLE WITH SPEECH DISABILITIES 10 ACCESS FOR PEOPLE WITH OTHER DISABILITIES 11 2. CONSIDERATIONS FOR PHYSICAL ACCESS 12 BUILDINGS / ROOMS / HALLWAYS 12 3. CONSIDERATIONS FOR INFORMATION ACCESS 13 FORMS / PUBLIC INFORMATION / COMPLAINTS / MEDIA, ETC. 13 4. CONSIDERATIONS FOR STAFF ACTIVITIES 15 OFFICE PARTIES / HOLIDAY CELEBRATIONS / FEDERALLY RECOGNIZED EMPLOYEE ORGANIZATIONS / ETC. 15 5. CONSIDERATIONS FOR SAFETY 16 BUILDING EVACUATION 16 SECURITY ISSUES 16 6. CONSIDERATIONS FOR CONTRACTING AND ACQUISITIONS 18 CONTRACTING / ACQUISITIONS / SERVICES / EQUIPMENT, ETC. 18 [Page ii] III. MEETINGS / DOCUMENTS / TRAINING 1. INTERNAL FCC MEETINGS 21 IF YOUR MEETING IS OPEN TO ALL FCC STAFF 21 AND is scheduled in the Commission Meeting Room 21 IF YOUR MEETING IS OPEN TO ALL FCC STAFF 22 AND is scheduled for a location other than the Commission Meeting Room 22 IF YOUR MEETING IS FOR A LIMITED FCC AUDIENCE (DIVISION MEETING, INTERNAL TASK FORCE, COMMITTEE, ETC.) 23 AND you know the attendees 23 AND you DON'T know the attendees 23 IF YOUR MEETING REQUIRES PRE-REGISTRATION 24 2. MEETINGS WITH NON-FCC ATTENDEES 25 IF YOUR MEETING IS A COMMISSION OPEN MEETING 25 IF YOUR MEETING IS A PUBLIC MEETING WITH NO PRE-REGISTRATION REQUIRED 26 IF YOUR MEETING IS OPEN TO A LIMITED PUBLIC AUDIENCE 27 AND you know the attendees 27 AND you DON'T know the attendees 27 IF YOUR MEETING FOCUSES ON ISSUES YOU EXPECT TO BE OF INTEREST TO PEOPLE WITH DISABILITIES 28 IF YOUR MEETING REQUIRES PRE-REGISTRATION 30 3. DISSEMINATING NEWS RELEASES, PUBLIC NOTICES, TEXTS, AND OTHER DOCUMENTS 32 4. HOSTING ACCESSIBLE MEETINGS AND EVENTS 33 OPENING ANNOUNCEMENTS 33 MEETING MODERATORS 33 AUDIO AND VISUAL MEDIA 36 Presenters with printed handouts or audio/visual media 36 AND people with disabilities are expected 36 Presenters with printed handouts or audio/visual media 37 AND it is unknown if people with disabilities will attend 37 IF YOU ARE INVITED TO SPEAK AT A NON-FCC EVENT 38 AND have handouts or audio/visual presentations 38 If the hosts HAVE MADE ARRANGEMENTS for accommodations 38 If the hosts HAVE NOT MADE ARRANGEMENTS for accommodations or do not know if people with disabilities plan to attend 38 5. AUDIO-VISUAL MEDIA PRODUCED OR OWNED BY THE COMMISSION 40 VIDEO FORMATS (VIDEOTAPE, CD, DVD, ETC.) 40 Captioning 40 Video description 40 AUDIO RECORDINGS 40 TO ARRANGE FOR CAPTIONING OR VIDEO DESCRIPTION OR TO DISCUSS YOUR MEDIA OPTIONS 40 6. TRAINING 41 FCC TRAINING 41 FCC UNIVERSITY 41 FCC CONTRACTED TRAINING 42 EXTERNAL TRAINING 42 [Page iii] IV. REASONABLE ACCOMMODATION PROCEDURES 1. REASONABLE ACCOMMODATION REQUESTS 45 IF YOU RECEIVE A REQUEST FOR REASONABLE ACCOMMODATIONS 45 2. FCC504@FCC.GOV 47 PURPOSE 47 WHO CHECKS THIS MAILBOX? 47 3. TTY ACCESS 48 DISTRIBUTION OF TTYS WITHIN THE COMMISSION - MINIMUM STANDARDS 48 TTY TELEPHONE NUMBERS 48 TTY ASSISTANCE 48 TELECOMMUNICATIONS RELAY SERVICE (TRS) 49 TTY calls 49 VCO (Voice Carry Over) 49 HCO (Hearing Carry Over) 50 STS (Speech to Speech) 50 IP Relay 50 VRS (Video Relay Service) 50 Spanish Relay Service 51 4. DOCUMENTS SUBMITTED IN ALTERNATE FORMATS 52 WHERE SHOULD THEY BE SENT? 52 5. CREATING IN-HOUSE TRANSCRIPTS FROM AUDIO RECORDINGS 53 WHY TRANSCRIBE AUDIO RECORDINGS? 53 WHO COORDINATES THE TRANSCRIPTION PROCESS? 53 WHAT TYPES OF AUDIO RECORDINGS ARE ACCEPTED FOR TRANSCRIPTION? 53 WHO SHOULD CREATE THE TRANSCRIPTS? 54 TRANSCRIPTION PROCESS 54 TRANSCRIPT REVIEW 55 TRANSCRIPT FORMAT 55 FINAL DISPOSITION 55 6. CREATING IN-HOUSE WRITTEN TRANSCRIPTS FROM BRAILLE 56 WHY TRANSCRIBE BRAILLE? 56 WHO COORDINATES THE TRANSCRIPTION PROCESS? 56 WHAT TYPES OF BRAILLE ARE ACCEPTED FOR TRANSCRIPTION? 56 WHO SHOULD CREATE THE TRANSCRIPTS? 56 TRANSCRIPTION PROCESS 57 TRANSCRIPT REVIEW 57 TRANSCRIPT FORMAT 57 FINAL DISPOSITION 58 [Page iv] 7. CREATING IN-HOUSE TRANSCRIPTS FROM SIGN LANGUAGE VIDEO-RECORDINGS 59 WHY TRANSCRIBE SIGN LANGUAGE VIDEO RECORDINGS? 59 WHO COORDINATES THE TRANSLATION / TRANSCRIPTION PROCESS? 59 WHAT VISUAL PRESENTATIONS WILL BE ACCEPTED FOR TRANSLATION? 59 WHO SHOULD CREATE THE TRANSCRIPTS? 59 TRANSCRIPTION PROCESS 60 TRANSLATION PROCESS 60 TRANSLATION REVIEW 62 TRANSLATION FORMAT 62 FINAL DISPOSITION 62 V. DISABILITY PRIMER 1. DISABILITY RIGHTS LAWS 64 REHABILITATION ACT, SECTION 504 64 REHABILITATION ACT 66 Section 501 66 Section 503 66 Section 508 66 AMERICANS WITH DISABILITIES ACT (ADA) 67 ADA Title I: Employment 67 ADA Title II: State and Local Government Activities 67 ADA Title II: Public Transportation 68 ADA Title III: Public Accommodations 69 ADA Title IV: Telecommunications Relay Services 69 ARCHITECTURAL BARRIERS ACT 70 TELECOMMUNICATIONS ACT 70 Sections 255 and 251 70 Section 713 71 TELEVISION DECODER CIRCUITRY ACT 71 HEARING AID COMPATIBILITY ACT 71 2. DISABILITY STATISTICS 73 3. DISABILITY TERMINOLOGY 74 4. DISABILITY ETIQUETTE 76 GENERAL ETIQUETTE 76 SENSITIVITY TO BLINDNESS AND VISUAL IMPAIRMENTS 78 INTERACTING WITH PEOPLE WHO HAVE SPEECH DISABILITIES 80 5. SIGN LANGUAGE INTERPRETERS 82 WHEN USING AN INTERPRETER 82 Study of fatigue confirms need for working in teams 83 Code of Ethics (Registry of Interpreters for the Deaf) 84 6. ASSISTIVE LISTENING DEVICES 86 INFRARED SYSTEMS 86 FM SYSTEMS 86 INDUCTIVE OR AUDIO LOOP SYSTEMS 87 [Page v] 7. CART (COMMUNICATION ACCESS REALTIME TRANSLATION) 88 WHAT IS IT? 88 HOW IT'S DONE 88 CERTIFICATION 88 8. CAPTIONING 89 WHAT IS CAPTIONING? 89 CAPTION STYLES 90 HOW ARE REALTIME [LIVE] CAPTIONS GENERATED? 90 METHODS OF CAPTIONING 91 9. BRAILLE 93 WHAT IS BRAILLE? 93 WHAT DOES BRAILLE LOOK LIKE? 93 HOW WAS BRAILLE INVENTED? 93 HOW IS BRAILLE WRITTEN? 93 10. VIDEO DESCRIPTION 96 11. DISABILITY ACCESS SYMBOLS 98 ACCESS TO LOW VISION 98 ACCESSIBILITY SYMBOL 98 ACCESSIBLE PRINT 98 ASSISTIVE LISTENING SYSTEMS 98 AUDIO DESCRIPTION (VIDEO DESCRIPTION) 99 BRAILLE SYMBOL 99 CLOSED CAPTIONING 99 SIGN LANGUAGE INTERPRETATION 100 TTY (TELETYPEWRITER) 100 VOLUME CONTROL TELEPHONE 100 APPENDIX A 103 AMENDMENT OF PART 1, SUBPART N OF THE COMMISSION'S RULES CONCERNING NON-DISCRIMINATION ON THE BASIS OF DISABILITY IN THE COMMISSION'S PROGRAMS AND ACTIVITIES 103 APPENDIX B 119 BRAILLE SAMPLE PAGE 119 INDEX 122 The Rehabilitation Act of 1973, (Pub.L. 93-112, 87 Stat. 394, 29 U.S.C. 794, as amended by the Rehabilitation Act Amandments of 1974, Pub.L. 93-516, 88 Stat. 1617, and the Rehabilitation, Comprehensive Services, and Developmental Disabilities Amendments of 1978, Pub.L. 95-602, 92 Stat. 2955, and the Rehabilitation Act Amendments of 1986, sec. 103(d), Pub.L. 99-506, 100 Stat. 1810) creates specific causes of action for persons who are aggrieved by discriminatory treatment as defined in the Act. This Handbook is intended to guide implementation of the Federal Communications Commission's responsibilities under Section 504 of the Rehabilitation Act. It is for internal staff use and public information only, and is not intended to create any rights, responsibilities, or independent cause of action against the Federal Government. [Page 1] I. INTRODUCTION [Page 2] 1. SECTION 504 HANDBOOK The Federal Communications Commission Section 504 Programs & Activities Accessibility Handbook (Section 504 Handbook) is a collection of guidelines, information, and procedures to ensure that the Commission is accessible to individuals with disabilities. The content of this handbook is designed to assist Commission personnel in their efforts to provide such accessbility. The FCC is committed to fostering an attitude of inclusion and a commitment to access that will permeate all Commission programs and activities. While certain aspects of providing access for people with disabilities can be clearly visible (sign language interpreters, ramps, and braille documents), other aspects may easily pass unnoticed (descriptions of humorous decorations on birthday cakes to colleagues who are blind so they can join in the fun, or remembering to stand facing co-workers who are hard of hearing so that they can speechread/lipread *1 more easily). It would be impossible to list all the aspects of the Commission's work that may require reasonable accommodation to assure access, but the following sections can provide general guidance and reminders to help keep accessibility in the forefront of our awareness so that the Commission's programs and activities will be accessible to everyone. [Page 3] 2. BASIC PRINCIPLES OF ACCESS The starting point for providing access is simple courtesy and common sense. If an overarching goal of the Commission is to ensure that all interested individuals with disabilities have access to the Commission's programs and activities, then the means for providing access is only a matter of mechanics--matching the solution to the need. It is when people with disabilities are overlooked as potential or actual consumers that barriers are raised. And, ironically, it is these, often unconscious, barriers that can be the hardest to overcome. Remembering the following principles when planning and implementing Commission activities and programs can help keep access in our consciousness: * The Commission, its programs, and activities MUST be accessible. This is mandated by statute and by FCC rules. *2 * When meetings or events are scheduled, the event planner, or person calling the meeting, is responsible for assuring accessibility. The Commission's Section 504 Officer is available for consultation and can assist in determining accessibility needs. * Individuals attending events or meetings who need reasonable accommodations must inform the meeting/event planner of their needs. However, it is the meeting/event planner's obligation to announce events with sufficient lead time to give attendees an opportunity to ask for such accommodations. * Individuals with disabilities are the best sources of information regarding the accommodations they will need. If you are unsure of what to do, ask the person with a disability about his or her preferences. [Page 4] 3. Section 504 of the Rehabilitation Act *3 Section 504 of the Rehabilitation Act of 1973 as amended is the legislation that prohibits federal agencies, and other program and activities receiving federal financial assistance, from discriminating against individuals with disabilities. *4 It is therefore this legislation that most directly affects the FCC. The Rehabilitation Act is sometimes confused with the Americans with Disabilities Act (ADA) *5 which was passed in 1990. While there are many parallels between the Rehabilitation Act and the ADA, there are some fundamental differences. Both laws are designed to prohibit discrimination against individuals with disabilities. Both share many of the same definitions and provisions. However, where the Rehabilitation Act pertains to federal agencies and entities receiving federal funding, the ADA applies to State and local governments, public accommodations, commercial facilities, transportation, telecommunications, and the U.S. Congress. *6, *7 [Page 5] 4. DISABILITY RIGHTS MOVEMENT Disability The American disability rights movement was a catalyzing factor in the emergence of current disability rights legislation. The Smithsonian Institution's National Museum of American History maintains a Virtual Exhibition featuring the history of the disability rights movement in the United States. The following text comes from their display, "Disability Rights Movement" *8 and provides a concise summary of the movement and issues that led to present day legislation. The Disability Rights Movement The ongoing struggle by people with disabilities to gain full citizenship is an important part of our American heritage. The disability rights movement shares many similarities with other 20th-century civil rights struggles by those who have been denied equality, independence, autonomy, and full access to society. Self Definition and Autonomy Historically, disabled people have been forced into dependency. Others would speak for them, label them, and take care of them -- often with the best intentions. As a result of 20th-century developments in biotechnical medicine, by the 1950s, more and more people survived formerly fatal injuries and diseases. Efforts by this growing population of military veterans and young adults to participate fully in society gained momentum. They were energized by the struggles of African Americans. Both groups have confronted numerous stereotypes in their quest for equality, inclusion in public affairs, and sometimes the right simply to live. Parents Organize By the 1940s and 1950s, parent activists had organized to fight for education and services for children with disabilities. When these children grew up, they demanded to be treated as adults, with all the rights and responsibilities granted to other citizens. Their new disability rights movement has sought to overcome discrimination and, sometimes, their own parents' fears and overly protective attitudes. [Page 6] DISABILITY AND DISABILITY LAWS -- "Disability Rights Movement" (continued) The Role of Technology Like efforts organized to break [other] barriers...the disability rights movement has resulted from people coming together in ways that allow them to compare experiences and forge relationships. For the community with disabilities, this has taken place primarily in centers for independent living, which started in the 1970s, and via the Internet since the 1990s. Crucial to the movement's success is access to information and communication through technologies such as telecaptioners, TTY devices for telephones, voice-recognition systems, voice synthesizers, screen readers, and computers. Mobility The disability civil rights movement had to not only overcome prejudice, but also physical barriers that limit access to employment and inclusion in other aspects of daily life. Activists successfully lobbied for laws that required curb-cuts, ramps, and buses with wheelchair lifts. This in turn increased the possibility of economic and social mobility. In the 1970s and 1980s, a growing population of consumers with mobility impairments fueled demand for wheelchairs and scooters to match their active lives. At the same time, barrier-free designs have brought a new aesthetic to public spaces. [Page 7] II. ACCESSIBILITY AND THE FCC [Page 8] 1. TYPES OF ACCESS REQUESTED For purposes of the Section 504 Handbook, accessibility refers to the ability of people with disabilities to "participate in, and enjoy the benefits of, programs or activities conducted by the Commission." *9 For general information on disabilities and access, contact the Commission's Section 504 Officer. *10 The accessibility requests we receive, from both the public and FCC staff, tend to fall into the following categories: Access for people with mobility impairments Since the Portals II building is accessible, people with mobility impairments are generally able to move throughout the building as they wish. When planning meetings, however, if you are expecting participants who use wheelchairs, scooters, canes, crutches, or other mobility aids, make sure that the aisles between chairs and/or tables are wide enough to allow comfortable passage. If your meeting is to take place at a table, make sure that there is room for a wheelchair or scooter to pull up. This can be easily accomplished by removing one or two chairs and leaving the space open. Access for people who are blind or have low vision People who are blind or have low vision may request a variety of accommodations. The type of accommodation requested depends upon the nature of the material requested, the type and severity of the visual impairment, and personal preferences. In-house, the Commission is able to produce text documents in large print, *11 electronic formats, *12 braille, *13 and some audio formats. *14 Requests for other formats, such as conversion of graphics into tactilely accessible media or for video description, *15 are often sent to outside contractors. [Page 9] ACCESSIBILITY DEFINED - Types of Access Requested - Access for people who are deaf or hard of hearing (continued) Access for people who are deaf or hard of hearing Generally, people who are deaf or hard of hearing request assistive listening devices, *16 captioning, *17 CART *18 (Communication Access Realtime Translation--similar to captioning but confined to a laptop or projection screen), or sign language interpreters. *19 The Commission is equipped with fixed FM assistive listening systems in the Commission Meeting Room and in Conference Room 1 on the 8th floor. In addition, there are 2 portable FM systems that can be used throughout the building and at remote locations. The systems are outfitted with microphones, earphones, and neckloops. *20 Captioning, CART, and sign language interpreters are services that are frequently contracted from outside vendors. In the DC area, such services are widely used with demand often out-stripping supply. As much advance notice as possible is needed to assure that appropriate services can be acquired. The Commission also has several sign language interpreters on staff who assist in making Commission events accessible. People who are deaf or hard of hearing may use other accommodations such as oral interpreters, *21 cued speech transliterators, *22 tactile interpreters, *23 and notetakers, *24 but these services are rarely requested at the Commission. [Page 10] ACCESSIBILITY DEFINED - Types of Access Requested (continued) Access for people with speech disabilities Speech disabilities can be genetically linked or can result from accident, injury, or illness. The severity and type of speech disability can vary dramatically as can the communication modes individuals choose to use. Some people with speech disabilities choose to speak for themselves while others opt for using a re-voicer, *25 communication board, *26 artificial larynx, *27 speech output device, *28 or other assistive technology to help them be understood. Regardless of the severity of disability or the method of communication, patience and careful listening are of paramount importance. When talking with people who have speech disabilities, do not pretend to understand what they are saying. Allow people to complete their thoughts; do not presume to end sentences for them. If you [Page 11] ACCESSIBILITY DEFINED - Types of Access Requested - Access for people with speech disabilities (continued) do not understand what has been said, admit it and ask for a repetition. If you are unsure, but think you understand part of what has been said, repeat what you thought you heard and ask for confirmation. Access for people with other disabilities Most of the disabilities encountered at the FCC fall into the four categories discussed above. However people may have other disabilities or combinations of disabilities. When encountering people with any type of disability, but particularly when it is a form of disability new to you, remember to focus on the person first, not his or her disability. Use courtesy and common sense and ask the person with a disability for his or her advice on how to proceed. [Page 12] 2. CONSIDERATIONS FOR PHYSICAL ACCESS Buildings / Rooms / Hallways In most cases, federal buildings adhere to the UFAS (Uniform Federal Accessibility Standards) guidelines established by the Architectural and Transportation Barriers Compliance Board (Access Board). *29 The UFAS "sets standards for facility accessibility by physically handicapped persons for Federal and federally-funded facilities. These standards are to be applied during the design, construction, and alteration of buildings and facilities to the extent required by the Architectural Barriers Act of 1968, as amended." *30 Beyond the structural design elements of access, there are practical, everyday decisions that Commission staff can make to assure optimal physical access to FCC programs and activities. Among the considerations that should be kept in mind are the following: * Keep aisles and doorways clear. Do not block pathways with boxes, furniture or other obstacles. * When arranging meeting rooms or seating areas, be sure to allow aisles between tables and/or chairs that are wide enough to permit easy passage for wheelchairs, scooters, and people using other mobility aids. * When placing chairs in pre-arranged seating arrangements, include gaps in the seating plan to allow space for people who use wheelchairs or scooters. * If accommodations that require user activation are installed in the building --for example, chair lifts that require keys to operate them--make sure that the key or other means of activation is easily available for users with disabilities. It does little good to have a lift installed if the key that is required to operate it is in an office on the other side of the lift! Keep in mind that lifts and other similar aids must be easily accessible in both directions, i.e., "coming" and "going." * Do not assume that all people with similar disabilities will want identical accommodations. If you are unsure of what to do, ask the person with a disability for guidance. [Page 13] 3. CONSIDERATIONS FOR INFORMATION ACCESS Forms / Public information / Complaints / Media, etc. When developing forms, publications, press releases, solicitations for consumer input, or other information gathering or disseminating tools and processes, be sure to consider the accessibility of both the content and the medium you elect to use. * Choose a font style and size that is easy to read. *31 There are no hard and fast rules guiding the selection of font styles and sizes. In fact, publication manuals and guidelines vary dramatically in their rules and preferences. There is, however, some general agreement on the following principles: * For print documents, serif fonts are easier to read. Serif fonts have little "feet" attached to each letter; Times New Roman is an example of a serif font. *32 * For electronic displays, sans serif fonts are easier to read. Sans serif fonts lack the little "feet" attached to each letter; Arial is an example of a sans serif font. *33 * For large print, the size of type required will vary with the needs of the reader. For generically produced large print, a font size of 16 to 18 is preferred. *34 * Use high contrast colors when possible. It may be difficult for people with low vision to see information that is presented in colors that do not contrast strongly. [Page 14] CONSIDERATIONS FOR INFORMATION ACCESS (continued) * Remember that approximately 7% of all males have some form of red-green colorblindness; this condition only affects .4% of women. For many people with this disorder, red and green look essentially alike. *35 Keep this in mind when designing color documents. *36 * Remember to include an accessibility statement in any documents you disseminate. For further guidance, see the "Disseminating News Releases, Public Notices, Texts, and Other Documents" section of this Handbook beginning on page 32. * Existing documents that are not in accessible format for either the public (e.g., those mentioned above) or staff (e.g., personnel records, Federal forms), must be made accessible for people with disabilities upon request. If a person with a disability contacts you asking for assistance with Commission information or resources, help them to the best of your ability. If you find that you are unable to satisfy their need, and the request is not related to web access, ask them to send an e-mail to: fcc504@fcc.gov or contact the Commission's Section 504 Officer. *37 For further guidance on web accessibility and information disseminated via the internet, contact the Commission's Section 508 Officer. *38 [Page 15] 4. CONSIDERATIONS FOR STAFF ACTIVITIES Office parties / Holiday celebrations / Federally recognized employee organizations *39 / etc. Remember that people with disabilities are also members of the FCC staff. *40 All programs or activities should be planned with an eye to ensuring access for anyone who would like to attend. * When disseminating FCC generated notices, distributing flyers, or making posters, be sure to include an accessibility statement. Remember that the "host" of the event assumes responsibility for arranging for accommodations for people with disabilities. For further guidance, see the "Meetings, Documents, Training" section of this Handbook on pages 21-39. * When broadcast messages are sent via voice mail system, make sure the information is shared with staff members who are deaf or hard of hearing. [Page 16] 5. CONSIDERATIONS FOR SAFETY Building Evacuation * Remember that people who are deaf or hard of hearing may not be able to hear broadcasts over the public address system or verbal instructions from building monitors or security officers. Rumors or instructions passed by word of mouth are also likely to be missed by a person who is deaf or hard of hearing. If you know of someone in your area who is deaf or hard of hearing, make sure that you pass along information about emergency situations. * Remember that people who are blind cannot see you. Before attempting to help people who are blind, introduce yourself and ask them if they would like assistance. If they accept your offer of help, allow them to take your arm; do not push or drag them along with you. If you are uncertain about what to do, ask the person how they would like to proceed. * People who have low vision have varying levels of sight -- some may be able to discern shapes, others may only be able to identify areas that are light or dark, still others may have tunnel vision, or may be able to see only in areas with bright lighting. Before helping someone who appears to have vision problems, ask if they would like help. If they accept your offer of assistance, ask the person how they would like to proceed. * There are established procedures for evacuating people who have significant mobility impairments. Evacuation chairs and trained personnel are strategically located throughout the building. During an emergency, contact one of the safety monitors stationed in the elevator lobbies if such services are needed. Consult the Emergency Evacuation Procedures document on the FCC intranet (http://intranet.fcc.gov/) for more detailed instructions. Security Issues * When giving directions in emergency or high stress situations, do not assume that people who are non-responsive are being uncooperative. * People who are deaf or hard of hearing may be unable to hear spoken instructions. Even people who have substantial residual hearing may have difficulty hearing instructions coming from behind them or orders given in areas with background noise such as fire alarms or the chatter from crowds of people. [Page 17] CONSIDERATIONS FOR SAFETY-- Security issues (continued) * People who are blind or have low vision may not see gestures or other visual cues indicating where they should go or what they should do. * When going through standard security screening procedures in the Portals II building, it is helpful to inform people who are blind of the process they are about to experience. Give verbal cues as to where to place items for inspection and how to pass through the metal detectors. * Remember that some people with disabilities have assistive devices that are not easily removed. Some devices, such as cochlear implants to improve hearing or metal rods to strengthen bones, are surgically implanted and cannot be taken off or detached . Be aware that such devices may set off metal detectors and be prepared to use courtesy and good judgment in dealing with such situations. [Page 18] 6. CONSIDERATIONS FOR CONTRACTING AND ACQUISITIONS Contracting / Acquisitions / Services / Equipment, etc. All of the Commission's programs and activities must be accessible to people with disabilities. This includes programs and activities offered by the Commission through contracts or other arrangements. *41 Agreements between the Commission and other entities for the provision of programs or activities should be carefully written to ensure that access for people with disabilities is explicitly required in the statement of work. [Page 19] This page is intentionally blank. [Page 20] III. MEETINGS / DOCUMENTS / TRAINING [Page 21] 1. INTERNAL FCC MEETINGS If your meeting is open to all FCC staff... AND is scheduled in the Commission Meeting Room... * Be sure that you arrange for captioning. Meetings intended for all Commission staff, scheduled in the Commission Meeting Room, should be captioned. Contact the Commission Audio Visual Center, *42 Office of Media Relations, to arrange for captioning services. Be sure to allow as much lead time as possible. Captioning services are in high demand and may not be available without sufficient notice. *43 * Include a reasonable accommodation statement in all announcements and publicity, including all invitations, flyers, posters, e-mails, advertisements, etc. Model statement: Reasonable Accommodations Open captioning will be provided for this event. Other reasonable accommodations for people with disabilities are available upon request. Include a description of the accommodation you will need including as much detail as you can. Also include a way we can contact you if we need more information. Make your request as early as possible; please allow at least 5 days advance notice. Last minute requests will be accepted, but may be impossible to fill. Send an e-mail to fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau: For sign language interpreters, CART, and other reasonable accommodations: 202-418-0530 (voice), 202-418-0432 (tty) For accessible format materials (braille, large print, electronic files, and audio format): 202-418-0531 (voice), 202-418-7365 (tty) * Make sure that your first public announcement is released at least one full week in advance. [Page 22] INTERNAL FCC MEETINGS (continued) If your meeting is open to all FCC staff... AND is scheduled for a location other than the Commission Meeting Room * Include a reasonable accommodation statement in all announcements and publicity, including all invitations, flyers, posters, e-mails, advertisements, etc. Model statement: Reasonable Accommodations Reasonable accommodations for people with disabilities are available upon request. Include a description of the accommodation you will need including as much detail as you can. Also include a way we can contact you if we need more information. Please allow at least 5 days advance notice; last minute requests will be accepted, but may be impossible to fill. Send an e-mail to fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau: For sign language interpreters, CART, and other reasonable accommodations: 202-418-0530 (voice), 202-418-0432 (tty) For accessible format materials (braille, large print, electronic files, and audio format): 202-418-0531 (voice), 202-418-7365 (tty) * Make sure that your first public announcement is released at least one full week in advance. [Page 23] INTERNAL FCC MEETINGS (continued) If your meeting is for a limited FCC audience... (division meeting, internal task force, committee, etc.) AND you know the attendees Be sure to request accommodations *44 (e.g., captioning, accessible formats, sign language interpreters, etc.) you know will be needed as far in advance as possible. AND you DON'T know the attendees * Include a reasonable accommodation statement in your invitation or announcement. Model statement: Reasonable Accommodations Reasonable accommodations for people with disabilities are available upon request. Include a description of the accommodation you will need including as much detail as you can. Also include a way we can contact you if we need more information. Make your request as early as possible; please allow at least 5 days advance notice. Last minute requests will be accepted, but may be impossible to fill. Send an e-mail to fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau: For sign language interpreters, CART, and other reasonable accommodations: 202-418-0530 (voice), 202-418-0432 (tty) For accessible format materials (braille, large print, electronic files, and audio format): 202-418-0531 (voice), 202-418-7365 (tty) * Make sure that your first public announcement is released at least one full week in advance. [Page 24] INTERNAL FCC MEETINGS (continued) If your meeting requires pre-registration... * Be sure your registration form includes an option for requesting accommodations. Model accommodation request section: Reasonable Accommodations I need the following reasonable accommodation: Accessible Format (Please specify below) __ Audiocassette (analog) __ Braille __ Large Print __ Digital Audio Recording Please circle one: 3.5" Floppy Disk, CD, E-mail attachment Please circle one: MP3, RealAudio __ Digital Text Please circle one: 3.5" Floppy Disk, CD, E-mail attachment Please circle one: ASCII, MSWord __ Other (Please specify) Sign Language Interpreter CART (Communication Access Realtime Translation) Assistive Listening Device Other (please specify) * As soon as a request for accommodation is received, consult the chart on page 45 of this Handbook and forward the request to the appropriate person. * Make sure that your first public announcement is released at least one full week in advance. [Page 25] 2. MEETINGS WITH NON-FCC ATTENDEES If your meeting is a Commission Open Meeting... * Display open captioning on both screens in the Commission Meeting Room, the hallway monitors, the internet webcast, and the Commission's closed circuit television broadcast. *45 Contact the Commission Audio Visual Center, *46 Office of Media Relations, to arrange for captioning services. * Provide Sign language interpreters. *47 The interpreters will be expected to interpret for the duration of the proceedings regardless of whether deaf attendees are readily identified. Interpreters are not required to interpret for the Press Conference following the Open Meeting UNLESS they are requested to do so by a deaf consumer or by Commission staff. * Supply agendas in both braille and large print. *48 * Note in the Sunshine Notice that the above accommodations will be provided and indicate how other accommodations can be acquired. Model notice: Reasonable Accommodations The meeting site is fully accessible to people using wheelchairs or other mobility aids. Meeting agendas and handouts will be provided in accessible formats; sign language interpreters, open captioning, and assistive listening devices will be provided on site. The meeting will be webcast with open captioning [note web address]. Request other reasonable accommodations for people with disabilities as early as possible; please allow at least 5 days advance notice. Include a description of the accommodation you will need including as much detail as you can. Also include a way we can contact you if we need more information. Last minute requests will be accepted, but may be impossible to fill. Send an e-mail to: fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty). * Make sure that your first public announcement is released at least one full week in advance. [Page 26] MEETINGS WITH NON-FCC ATTENDEES (continued) If your meeting is a public meeting with no pre-registration required... * Be sure that you arrange for captioning. Meetings open to the general public, scheduled in the Commission Meeting Room, should be captioned. Meeting planners should contact the Audio Visual Center, *49 Office of Media Relations, to arrange for captioning services. Be sure to allow as much lead time as possible. Captioning services are in high demand and may not be available without sufficient notice. *50 * Include a reasonable accommodation statement in all announcements and publicity, including all invitations, flyers, posters, e-mails, advertisements, etc. Model statement: Reasonable Accommodations Open captioning will be provided for this event. Other reasonable accommodations for people with disabilities are available upon request. Include a description of the accommodation you will need including as much detail as you can. Also include a way we can contact you if we need more information. Make your request as early as possible; please allow at least 5 days advance notice. Last minute requests will be accepted, but may be impossible to fill. Send an e-mail to fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau: For sign language interpreters, CART, and other reasonable accommodations: 202-418-0530 (voice), 202-418-0432 (tty) For accessible format materials (braille, large print, electronic files, and audio format): 202-418-0531 (voice), 202-418-7365 (tty) * Make sure that your first public announcement is released at least one full week in advance. * Notify the Security Operations Center *51 if you expect visitors with disabilities. Advance notice allows the Operations Center to assign sufficient security staff to screen visitors. It also allows security officers to prepare themselves for alternative communication modes and reminds them to expect visitors with assistive devices that may require special handling when going through metal detectors. [Page 27] MEETINGS WITH NON-FCC ATTENDEES (continued) If your meeting is open to a limited public audience... AND you know the attendees Be sure to request accommodations *52 (e.g., captioning, accessible formats, sign language interpreters, etc.) you know will be needed as far in advance as possible. AND you DON'T know the attendees * Include a reasonable accommodation statement in your invitation or announcement. Model statement: Reasonable Accommodations Reasonable accommodations for people with disabilities are available upon request. Include a description of the accommodation you will need including as much detail as you can. Also include a way we can contact you if we need more information. Make your request as early as possible; please allow at least 5 days advance notice. Last minute requests will be accepted, but may be impossible to fill. Send an e-mail to fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau: For sign language interpreters, CART, and other reasonable accommodations: 202-418-0530 (voice), 202-418-0432 (tty) For accessible format materials (braille, large print, electronic files, and audio format): 202-418-0531 (voice), 202-418-7365 (tty) * Make sure that your first public announcement is released at least one full week in advance. * Notify the Security Operations Center *53 if you expect visitors with disabilities. Advance notice allows the Operations Center to assign sufficient security staff to screen visitors. It also allows security officers to prepare themselves for alternative communication modes and reminds them to expect visitors with assistive devices that may require special handling when going through metal detectors. [Page 28] MEETINGS WITH NON-FCC ATTENDEES (continued) If your meeting focuses on issues you expect to be of interest to people with disabilities... * Display open captioning on both screens in the Commission Meeting Room, the hallway monitors, the internet webcast, and the Commission's closed circuit television broadcast. *54 Contact the Commission Audio Visual Center, *55 Office of Media Relations, to arrange for captioning services. * Supply agendas and handouts produced in braille and large print. *56 * Sign language interpreters. *57 At the beginning of the event, if you are unsure whether deaf consumers are in attendance, consult with the interpreters to see if they are aware of any deaf attendees. If they are also unsure, make an announcement from the podium noting that interpreters are available and inquiring if there are any attendees who wish to use their services. Naturally, the interpreter will be expected to interpret this announcement. If no consumers indicate a need, the interpreter may retire to an agreed upon location to await any subsequent request. If a registration desk is used, it is an ideal place for the interpreters to sit, identified with a sign reading: Sign Language Interpreters. Late arrivers will then have the opportunity to note the availability of interpreters while they are signing in. If there is no registration desk, then position the interpreters near the entrance to the meeting room or in some other highly visible area. Sample wording for announcement of interpreter availability: Sign language interpreters are available for this meeting. Although we have had no requests for interpreting services, we would like to make sure that we are meeting the needs of all attendees. If there is anyone currently in attendance who needs the services of an interpreter, please so indicate to the interpreter. [pause for response] Thank you. [continue with meeting content] * The Public Notice should note that the above accommodations will be provided and should indicate how other accommodations can be acquired. [Page 29] MEETINGS WITH NON-FCC ATTENDEES -- If Your Meeting Focuses on Issues You Expect to be of Interest to People With Disabilities (continued) Model notice: Reasonable Accommodations The meeting site is fully accessible to people using wheelchairs or other mobility aids. Meeting agendas and handouts will be provided in accessible formats; sign language interpreters, open captioning, and assistive listening devices will be provided on site. The meeting will be webcast with open captioning [note web address]. Request other reasonable accommodations for people with disabilities as early as possible; please allow at least 5 days advance notice. Include a description of the accommodation you will need including as much detail as you can. Also include a way we can contact you if we need more information. Last minute requests will be accepted, but may be impossible to fill. Send an e-mail to: fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty). * Make sure that your first public announcement is released at least one full week in advance. * Notify the Security Operations Center *58 if you expect visitors with disabilities Advance notice allows the Operations Center to assign sufficient security staff to screen visitors. It also allows security officers to prepare themselves for alternative communication modes and reminds them to expect visitors with assistive devices that may require special handling when going through metal detectors. Don't know if your issues are of interest to people with disabilities? If you are unsure whether your meeting topic is of interest to the disability community, consult the Chief of the Disability Rights Office. *59 [Page 30] MEETINGS WITH NON-FCC ATTENDEES (continued) If your meeting requires pre-registration... * Be sure your registration form includes an option for requesting accommodations. Model accommodation request section: Reasonable Accommodations I need the following reasonable accommodation: Accessible Format (Please specify below) __ Audiocassette (analog) __ Braille __ Large Print __ Digital Audio Recording Please circle one: 3.5" Floppy Disk, CD, E-mail attachment Please circle one: MP3, RealAudio __ Digital Text Please circle one: 3.5" Floppy Disk, CD, E-mail attachment Please circle one: ASCII, MSWord __ Other (Please specify) Sign Language Interpreter CART (Communication Access Realtime Translation) Assistive Listening Device Other (please specify) * As soon as a request for accommodation is received, consult the chart on page 45 of this Handbook and forward the request to the appropriate person. * Make sure that your first public announcement is released at least one full week in advance. [Page 31] MEETINGS WITH NON-FCC ATTENDEES -- If your meeting requires pre-registration (continued) * Notify the Security Operations Center *60 if you expect visitors with disabilities. Advance notice allows the Operations Center to assign sufficient security staff to screen visitors. It also allows security officers to prepare themselves for alternative communication modes and reminds them to expect visitors with assistive devices that may require special handling when going through metal detectors. [Page 32] 3. DISSEMINATING NEWS RELEASES, PUBLIC NOTICES, TEXTS, AND OTHER DOCUMENTS * Include an accessible format statement in your releases. Model statement: Accessible Formats To request materials in accessible formats for people with disabilities (braille, large print, electronic files, audio format), send an e-mail to fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau at 202-418- 0531 (voice), 202-418-7365 (tty). * Make sure that you indicate the web address consumers can use to get an electronic copy. Follow the Commission's Section 508 Guidelines to assure appropriate web formats for your information. For more details on Section 508, contact the Commission's Section 508 Officer. *61 [Page 33] 4. HOSTING ACCESSIBLE MEETINGS AND EVENTS Hosting successful meetings or events *62 requires cooperation between event planners, chairpersons, emcees, moderators, coordinators, and attendees. The following hosting responsibilities and guidelines can help produce accessible events that comply with Section 504 requirements. Opening announcements * Announce the availability of any accommodations that are in place. Example: "For the [event name] today, we have the following accessibility services available [mention those actually in place for the event, e.g., sign language interpreters, assistive listening devices (ALDs), CART and/or captioning.] Also, agendas and handouts are available in large print, electronic format, and braille. If anyone needs assistance in locating where these services are being provided please let [identify any Commission staff who can assist in getting attendees the appropriate service(s) or products-ask the Commission staff identified to stand] know." * Provide verbal directions to accessible restroom facilities. For example, if the meeting is being held in the Commission Meeting Room, give directions similar to the following: "Accessible restrooms are located on the 12th Street level (this floor) at the following location: When exiting the Commission Meeting Room use the exit on the far right (or on the left, depending on where the speaker is located). Continue straight forward from the exit door for about 40 feet, then turn at the first corridor to the left. Restrooms are located immediately on your left, first the Men's then the Women's restrooms." * Provide verbal directions to any other amenities attendees may need to know about; e.g., area delis/restaurants, payphones, TTYs, ATMs. Meeting moderators * Introduce all speakers and panelists verbally by name. An alternative method is to ask the speakers/panelists to take turns introducing themselves. * Make it a practice to recognize individuals who would like to take the floor. * This will avoid situations where several people attempt to speak at the same time. This is both good meeting practice and an aid to interpreters, CART writers, and captioners who are only able to render the comments of one speaker at a time. [Page 34] HOSTING ACCESSIBLE MEETINGS AND EVENTS - Meeting Moderators: Recognizing individuals who would like to take the floor (continued) * This will identify the speaker for attendees who are blind or have low vision as well as for CART writers, captioners, and sign language interpreters. * A variation that is often used, particularly for events with attendees who are blind or have low vision, is to ask speakers to identify themselves each time they make a comment. This also is of benefit to captioners, CART writers, sign language interpreters, and members of the audience using these accommodations. * Since there is always a time lag between the time captioners, interpreters, and CART writers hear a message and are able to translate it, people who depend upon their services receive such information at a point slightly behind hearing participants. This frequently puts people who are deaf and hard of hearing at a disadvantage when trying to make a point or to respond to a question. By the time the question or issue is conveyed to them, others have already begun answering. By controlling access to the floor, the moderator can provide more equitable opportunities for comment and response. * Verbally acknowledge any speakers/panelists joining the meeting while in progress, or leaving the meeting before it ends. [For example: "We've just been joined by Alex Bell from FCC Corp....glad to have you with us!" (Give Alex a chance to respond briefly. This will orient people who are blind or have low vision to his location and to his voice.) Then return to the discussion at hand.] * If the public address system is not working properly, interrupt the speaker, reminding them to wait until the microphone is working correctly and repeat their comments using the working public address system. Participants relying on ALDs, sign language interpreters, captioning, and CART text will miss the information if it does not come through the PA system. * Remember to be patient. It will take extra time for individuals with speech disabilities or individuals using sign language interpreters, captioning, or CART to fully participate in discussions. Participants with speech disabilities may require additional time to complete their comments. And, individuals using sign language interpreters, captions, and CART, experience delays in receiving information as well as expressing comments. On average, there is a 1-10 second delay between the time a comment is uttered and the time the complete sign language interpretation is presented. Similarly, there is a 1-15 second delay for the complete captioned or CART text to appear. There is a similar delay when a response is expressed in sign language and interpreted into speech. Thus, asking a question or soliciting comments and then quickly selecting the first person to raise a hand or shout out a response, does not allow those experiencing time delays an opportunity to participate. It also discriminates against those who require more time to express themselves. [Page 35] HOSTING ACCESSIBLE MEETINGS AND EVENTS - Meeting Moderators (continued) * If the text of any handout or A/V presentation is not available in accessible formats (i.e., Braille, electronic text file, audio recording), announce to the audience how to obtain a copy in an accessible format. Example: "We regret that the [document, PowerPoint presentation, agenda, etc.] is not available in braille, large print, or electronic text. However, anyone in the audience can contact the Commission's Accessible Format Specialist, Consumer & Governmental Affairs Bureau, to obtain a copy in the format you prefer. You can call 202-418-0531 or 202-418-7365 (tty) or you can send an e- mail to fcc504@fcc.gov." * Be aware of any changes to the physical environment. If at any time before, during, or after the meeting, pathways or aisles become blocked for wheelchair access, move the barrier or designate someone to do so as soon as possible. Also, if the layout of the meeting room is changed during the meeting (for example, tables/chairs moved in a different configuration, additional equipment brought in, etc.), announce the changes or additions to the audience and warn them of hazards associated with the change(s)/addition(s), (e.g., power cords, cables, etc.) This will be especially helpful for attendees who are blind or have low vision. Example: "Just so that everyone is aware, we'll need to change the location of some of the tables during the break in order to accommodate the equipment coming in for the next session. Also, please be aware that in order for the equipment to operate, there will be a power cord/cable that will be taped to the carpet that will run across the aisle. So please exercise caution when walking in the aisle area or close to the equipment when it is set up." * Always describe any changes to preprinted agendas, handouts, or other materials. * When an acronym that is not commonly known to the general public is first used, be sure to pause the discussion momentarily, giving the spelling and/or meaning of the acronym. Not only will this be helpful to the audience, but will also be of invaluable assistance in providing accurate information to sign language interpreters, captioners, and CART writers. Example: "Excuse me. Just to help clarify what 'Nancy' is - it's the acronym for the North American Numbering Council, N-A-N-C, which is often pronounced, 'Nancy." It is ... [provide explanation]." [Page 36] HOSTING ACCESSIBLE MEETINGS AND EVENTS (continued) Audio and visual media Organizers and planners of Commission meetings must make sure that all attendees, including individuals with disabilities, are not "excluded from participation in," or "denied the benefits of" meetings and events. *63 In order to ensure that everyone can participate in and benefit from the meeting or event, it is vital that the organizer know, to the extent possible, what audio/visual presentations *64 will be used. Presenters with printed handouts or audio/visual media... AND people with disabilities are expected * Inform the presenters of the Commission's obligation to provide access to people with disabilities. Ask the presenters whether printed handouts or audio/visual elements will be included in their respective presentations. If such materials will be in use, then... In advance of the meeting, request a copy of the media that presenters plan to use -- printed handouts, audio/visual elements, etc. If available, an electronic version is preferred. * For conversion of print and other textual media to braille, large print, electronic text, or audio format, contact the Commission's Accessible Format Specialist, Consumer & Governmental Affairs Bureau, 202-418-0531 (voice), 202- 418-7365 (tty), fcc504@fcc.gov. - When using slides or other graphic displays that do not include textual content (for example pictures, drawings, unlabeled charts, etc.), please provide a description of the key visual elements; include an explanation of any special significance implied by the manner of presentation. For example, if a parody of a company logo is displayed, note that it is a satirical depiction of Company X's logo. Then proceed to describe what the image looks like. - If possible, submit materials at least 5 business days prior to the date they are needed so that the conversion to accessible format can be completed by the day of the event. [Page 37] HOSTING ACCESSIBLE MEETINGS AND EVENTS - Audio and visual media - Presenters with printed handouts...AND people with disabilities expected (continued) * For consultation regarding video or other non-text media that is not captioned, contact the Commission's Section 504 Officer, Consumer & Governmental Affairs Bureau, 202-418-0530 (voice), 202-418-0432 (tty), fcc504@fcc.gov to determine the arrangements needed to assure access. Please allow as much lead time as possible. * Remind presenters and event moderators that information contained in working documents, flipcharts, posters, and visual aids must be read or described in order for the information to be accessible to the entire audience. * If, as a group, you are editing or revising a document, be sure to re-read any sections or contextual material necessary to convey to the group the full impact of the change(s) to be made. * If you are exhibiting a diagram or model, be sure to describe the individual parts as well as any interactions or changes that are being shown. If animation or special effects are being used, be sure to describe those as well. Presenters with printed handouts or audio/visual media... AND it is unknown if people with disabilities will attend... * Inform the presenters of the Commission's obligation to provide access to people with disabilities. Ask the presenters whether printed handouts or audio/visual elements will be included in their presentations. If such materials will be in use, then.... * Request that presenters have copies of the media they plan to use readily available in the event that people with disabilities should request accommodations. Inform the presenter that if a request for accommodation is received, they will be asked to forward a copy of their presentation materials to the Commission immediately so that we may convert them into accessible format. [Page 38] HOSTING ACCESSIBLE MEETINGS AND EVENTS (continued) If you are invited to speak at a non-FCC event... AND have handouts or audio/visual presentations... Check with the event planner to find out whether the sponsoring organization has made arrangements for accessibility for individuals with disabilities. If the hosts HAVE MADE ARRANGEMENTS for accommodations... * Have copies of handouts and audio/visual media ready for your hosts so that they can have them produced in accessible format. * If interpreters are being provided and you would like some guidelines on how to work with them, see the section on sign language interpreters beginning on page 82. If the hosts HAVE NOT MADE ARRANGEMENTS for accommodations or do not know if people with disabilities plan to attend... * Be prepared to read or describe any document or A/V presentation you will be sharing. * If the group is editing or revising a document, be sure to re-read any sections or contextual material necessary to convey to the group the full impact of the change(s) to be made. * If you are exhibiting a diagram or model, be sure to describe the individual parts as well as any interactions or changes that are being shown. If animation or special effects are being used, be sure to describe those as well. * If you would like to have copies of your materials in accessible format (braille, large print, electronic text, or audio formats) to take with you to your presentation, send the document (preferably in electronic format) to the Commission's Accessible Format Specialist, Consumer & Governmental Affairs Bureau, 202-418-0531 (voice), 202-418-7365 (tty), fcc504@fcc.gov, at least 5 business days prior to your departure date. When submitting slides or other graphic displays that do not include textual content (for example pictures, drawings, unlabeled charts, etc.) for conversion to accessible format, please provide a description of the key visual elements; include an explanation of any special significance implied by the manner of presentation. For example, if a parody of a company logo is displayed, note that it is a satirical depiction of Company X's logo. Then proceed to describe what the image looks like. [Page 39] HOSTING ACCESSIBLE MEETINGS AND EVENTS - IF YOU ARE INVITED TO SPEAK AT A NON- FCC EVENT AND HAVE HANDOUTS OR AUDIO/VISUAL PRESENTATIONS - If the hosts have NOT made arrangements for accommodations (continued) * If you do not have accessible copies of your materials with you, state at the beginning of your presentation that your materials can be provided in accessible format upon request. Ask audience members who need such formats to supply you with the following information: * Name, address, telephone number, e-mail address * Specific materials they would like converted to accessible format * Type of accessible format they are requesting Forward the consumer's information along with copies of the document(s) they are requesting (preferably in electronic format) to the Commission's Accessible Format Specialist, Consumer & Governmental Affairs Bureau, 202-418- 0531 (voice), 202-418-7365 (tty), fcc504@fcc.gov. [Page 40] 5. AUDIO-VISUAL MEDIA PRODUCED OR OWNED BY THE COMMISSION Video formats (Videotape, CD, DVD, etc.) Captioning * Video media owned or produced by the Commission that is intended for use by either staff or the public must be captioned. The captioning may be either open or closed. * When video is offered for sale with captions, the Commission must purchase the captioned version. * For items that are not available for purchase with captions, or for items given to the Commission without captions, the Commission must assure that captioning will be added at the earliest opportunity. * Comments for the record on video that are accompanied by a transcript need not be captioned. Video description * Video description is encouraged for visual media held or produced by the Commission and will be provided upon request. Retention and maintenance of video described versions of recordings should parallel that of non-video described versions. Audio recordings Audio recordings that are owned by the Commission and that are intended for use by either staff or the public must have written transcripts available upon request. Transcripts may be produced when requested and need not be prepared in advance. Once produced, however, the retention and maintenance of transcripts should parallel that of the audio recording. To arrange for captioning or video description or to discuss your media options... Contact fcc504@fcc.gov or call: Accessible Format Specialist, Consumer & Governmental Affairs Bureau 202-418-0531 (voice), 202-418-7365 (tty) Section 504 Officer, Consumer & Governmental Affairs Bureau 202-418-0530 (voice), 202-418-0432 (tty) [Page 41] 6. TRAINING FCC Training All FCC sponsored training must be accessible to people with disabilities. Training announcements should include an accessibility statement. Model statement: Reasonable accommodations for people with disabilities are available upon request. Include a description of the accommodation you will need including as much detail as you can. Also include a way we can contact you if we need more information. Please allow at least 5 days advance notice; last minute requests will be accepted, but may be impossible to fill. Send an e-mail to fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau: For sign language interpreters, CART, and other reasonable accommodations: 202-418-0530 (voice), 202-418-0432 (tty) For accessible format materials (braille, large print, electronic files, and audio format): 202-418-0531 (voice), 202-418-7365 (tty) FCC University To request reasonable accommodations for FCC University courses, contact the Chief of the Learning and Development Service Center. *65 [Page 42] TRAINING (continued) FCC Contracted training Entities contracting with the FCC to provide training are obliged to comply with the requirements of the Rehabilitation Act *66 and the FCC Section 504 Rules. *67 It is expected that trainers will: * Use only captioned video media whenever possible. * Comply with reasonable accommodation requests from students including, but not limited to: * Providing print materials in braille, large print, or electronic format (Materials can be submitted to the Commission's Accessible Format Specialist for transcription.) * Reading or describing visual objects, displays, or projections used in class * Adjusting the classroom to allow appropriate lines of sight and/or physical access. * Provide transcripts of any audio media used in connection with the class. * Distribute any oral quizzes or tests in print format. * Provide print quizzes or tests in audio format. External training Commission employees participating in external training are expected to complete FCC Training Form 182e. Box 9 allows applicants to indicate the accommodations needed. Generally speaking, it is the responsibility of the entity offering the training to provide the accommodations. It is the employee's responsibility to make their reasonable accommodation needs known. [Page 43] This page is intentionally blank. [Page 44] IV. REASONABLE ACCOMMODATION PROCEDURES [Page 45] 1. REASONABLE ACCOMMODATION REQUESTS If you receive a request for reasonable accommodations... That is, a request for services that will allow someone with a disability to access the programs and activities of the Commission, IMMEDIATELY forward that information to one of the following people. Be sure to note contact information for the requestor (name, telephone number, and/or e-mail address) as well as a description of their request. If you have questions about--Contact: Legal Aspects of Disability--Thomas Chandler, Chief, Disability Rights Office, Consumer & Governmental Affairs Bureau, 202-418-1475 / 202-418-0597 tty, tchandle@fcc.gov Reasonable Accommodations (Sign Language Interpreters, CART (Communication Access Realtime Translation), Physical Access), Transcribing sign language submitted in video format into English--Helen Chang, Section 504 Officer, Consumer & Governmental Affairs Bureau, 202-418-0424 / 202-418-0432 tty, hchang@fcc.gov Captioning, Assistive Listening Devices (ALDs)--Daniel Oliver, Audio Visual Production Manager, Office of Media Relations, 202-418-0460, doliver@fcc.gov Accessible Format (Braille / Large Print / Electronic Files / Audio Format), Transcribing documents submitted in accessible format into print--Brian Millin, Accessible Format Specialist, Consumer & Governmental Affairs Bureau, 202-418-7426 / 202-418-7365 tty, bmillin@fcc.gov Section 508 Issues (Access to electronic data, resources, and equipment)-- Rosalind Singleton, Section 508 Officer, Office of Managing Director, 202-418-2850, rlsingle@fcc.gov Section 501 Issues (Workplace accommodations for FCC staff who have temporary or permanent disabilities)--Barbara Douglas, Director, Office of Workplace Diversity, 202-418-7589, bjdougla@fcc.gov [Page 46] REASONABLE ACCOMMODATION REQUESTS (continued) If you have questions about--Contact: Security Issues--Eric Botker, Manager, Security Operations Center, 202-418-7884, ebotker@fcc.gov (when sending e-mail, please cc: Mary Long, mlong@fcc.gov and Richard Blackmon, rblackmo@fcc.gov) FCC University--Jerry Liebes, Chief, Learning and Development Service Center, Office of Managing Director, 202-418-1582, jliebes@fcc.gov Other Disability Issues--Helen Chang, Section 504 Officer, Consumer & Governmental Affairs Bureau, 202-418-0424 / 202-418-0432 tty, hchang@fcc.gov [Page 47] 2. FCC504@FCC.GOV Purpose This is the primary e-mail address for non-FCC staff who would like to request accommodations or who would like to direct disability related inquiries to the FCC. Who checks this mailbox? Responsibility for checking the mailbox is as follows: Primary: Section 504 Officer Secondary: Accessible Format Specialist Tertiary: Disability Rights Office Sign Language Interpreter [Page 48] 3. TTY ACCESS TTY was originally an acronym for TeleTYpewriter. Today, these devices are sometimes also called TDDs (Telecommunications Devices for the Deaf) or TTs (Text Telephones), though the preferred term is still TTY. TTYs include a keyboard, text display, and sometimes a printer. TTYs allow individuals to make and receive telephone calls in realtime using typed, 2-way communication. Distribution of TTYs within the Commission--Minimum standards * Each Division/Office within the Commission should have a working TTY with staff trained and available to answer calls. * TTY answering machines should be programmed with messages similar to those used on voice mail systems. * TTYs should be checked regularly for messages with responses generated promptly. Specific individuals should be charged with this task and appropriate back-ups designated. * The frequency with which TTY answering machines are checked should be comparable to checks of the voice mail system. TTY Telephone numbers * When contact telephone numbers for the FCC are disseminated, both voice and TTY telephone numbers should be included. * If an individual, branch, or division designated as the Commission's point of contact does not have a TTY number, then the TTY number of their office or division must be used. DO NOT use the general 1-800-TELL-FCC TTY number. *68 TTY Assistance * For technical assistance, contact: CRC Help Desk, 202-418-1200 (press 2), 202-418-0124 tty, crchelp@fcc.gov * For help in understanding/translating messages received via TTY, *69 contact The Commission's Section 504 Officer. *70 [Page 49] TTY ACCESS (continued) Telecommunications Relay Service (TRS) *71 TRS service (also called Relay, Relay Service, or Relay Center) is mandated by Title IV of the Americans with Disabilities Act (ADA) *72 and allows people who are deaf, hard of hearing, or who have speech disabilities to use the telephone. TRS service is available 24 hours a day. It provides the link between callers who use assistive devices such as TTYs, and callers who do not have such equipment. It also serves as an interface between people who have speech disabilities and those who have difficulty understanding them. To contact TRS, dial 711 anywhere in the United States. *73 The call will be connected to an operator (also called a Communications Assistant or CA). The Relay Service will ask for the destination phone number. Once this information has been provided, the call will be placed. When the connection is completed, the CA will relay information between the caller and the call recipient. TRS calls can be of several types: TTY calls TTY users can contact the Relay Center to make calls to people who do not have a TTY. Likewise, callers who use standard telephones can contact the Relay Center to make calls to TTY users. When using the Relay, the TTY user types a message to the CA who then reads it to the person using a standard telephone. When the person using a standard telephone responds, the CA types the message to the TTY user. VCO (Voice Carry Over) With VCO, a caller who can speak intelligibly but who cannot hear conversation on the telephone (as is often the case, for example, with hard of hearing people), is able to speak directly with the person using a standard telephone on the other end of the line. The CA then types the standard telephone user's comments back to the VCO user via TTY. Either VCO users or standard telephone users can initiate and receive VCO calls. [Page 50] TTY ACCESS -- Telecommunications Relay Service (continued) HCO (Hearing Carry Over) HCO allows people who can hear but who cannot speak clearly (for example, people who have had severe strokes) to use their hearing via a standard telephone while using a TTY to type their comments. HCO users type their comments to the CA who reads them to the person using a standard telephone on the other end of the line. The standard telephone user then speaks directly to the HCO user. Either HCO users or standard telephone users can initiate and receive HCO. STS (Speech to Speech) STS services are used by people who have speech disabilities and are neither deaf nor hard of hearing (for example, people who have cerebral palsy). With STS, CAs who are trained to understand people who have speech disabilities, listen to the caller and then repeat the message clearly to the person being called. The person with the speech disability can be either the initiator or the recipient of an STS call. IP Relay IP (Internet Protocol) Relay calls are initiated over the internet. To locate a list of IP Relay providers, use a standard internet search engine and search for "IP Relay." To make an IP Relay call, follow the directions on the internet site you select. At this time, IP Relay can only be used to make calls from an internet connection to a standard telephone. Calls cannot be made in reverse -- voice callers using a standard telephone or callers using VCO, HCO or STS cannot initiate an IP Relay call. IP Relay is currently an optional service. VRS (Video Relay Service) VRS allows sign language users to send and receive messages in American Sign Language (ASL). Currently, VRS calls must be initiated by the sign language user who must also have the appropriate video equipment and high speed connectivity, e.g., cable modem, DSL (Digital Subscriber Line), or ISDN (Integrated Services Digital Network). The sign language user signs to a CA who is also a qualified sign language interpreter. The CA interprets the message into spoken English for the standard telephone user who then responds in spoken English. The CA listens to the spoken message and interprets it into sign language for the originating caller. At this time VRS is an optional service. [Page 51] TTY ACCESS -- Telecommunications Relay Service (continued) Spanish Relay Service Relay services must be provided in Spanish for all interstate calls. Calls made within states are not required to offer their services in Spanish though many TRS Centers voluntarily do so. Spanish Relay offers services via TTY, VCO, HCO, and IP Relay. At this time, Spanish Relay is not available for STS or Video Relay Service users. Spanish Relay is only required to provide relay services from Spanish-to-Spanish; it is not a translation service. Either Spanish Relay users or standard telephone users can initiate and receive Spanish Relay calls. [Page 52] 4. DOCUMENTS SUBMITTED IN ALTERNATE FORMATS Where should they be sent? Documents that are submitted in alternate formats; i.e., video recording, audio recording, braille and the like, should be forwarded immediately to the appropriate contact person listed on the chart below. For each format below, consult the Consumer & Governmental Affairs Bureau contact listed: Audio recording: Send to Accessible Format Specialist, 202-418-0531, 202-418- 7365 tty Braille: Send to Accessible Format Specialist, 202-418-0531, 202-418-7365 tty Electronic documents: Send to Accessible Format Specialist, 202-418-0531, 202- 418-7365 tty Sign language: Send to Section 504 Officer, 202-418-0530, 202-418-0432 tty Other media or formats: Send to Section 504 Officer, 202-418-0530, 202-418- 0432 tty If you cannot determine what type of media you have received, send it to the Section 504 Officer. [Page 53] 5. CREATING IN-HOUSE TRANSCRIPTS FROM AUDIO RECORDINGS Why transcribe audio recordings? Transcription of audio recordings into other formats may be necessary to allow access to the information contained in the recording. Situations that may require such transcription include, but are not limited to, the following: * Blind consumers who do not know braille and who do not type or use computers may make submissions to the Commission in audio format . These must be transcribed into written form in order to be placed in the record. (The Commission's rules concerning non-discrimination on the basis of disability in the Commission's programs and activities *74 state that complaints may be submitted in "audio, braille, electronic, and/or video format." *75) * FCC staff or members of the public who are deaf may need written transcripts of audio recordings in order to benefit from the recording's content. * FCC staff or members of the public who are deaf-blind may need to have audio recordings transcribed into braille in order to benefit from the recording's content. Who coordinates the transcription process? The Accessible Format Specialist *76 is the coordinator and contact person for transcription of audio recordings. What types of audio recordings are accepted for transcription? * Audio recordings that are submitted to the Commission by consumers * Commission audio recordings * Audio recordings used in Commission sponsored or approved programs and activities. [Page 54] CREATING IN-HOUSE TRANSCRIPTS FROM AUDIO RECORDINGS (continued) Who should create the transcripts? Transcripts should be created by qualified individuals. The Accessible Format Specialist, or someone the Accessible Format Specialist has evaluated and deemed qualified, are appropriate choices. Transcription process * Note the date you receive the audio recording. There are often deadlines for submission of comments, complaints, or information; therefore, the actual submittal date can be crucial. If you are the first point of contact, rather than the office that is the official point of receipt, make sure you inform the proper office that you have received information in audio format that must be transcribed for the record. Also make sure that you have the full name, address, telephone number (or other contact information) for the submitter. * Find out if there are specific timelines/deadlines that affect the submission in question. If so, make every effort to complete the transcript as quickly as possible so that the entire process will not be unduly delayed. Make sure that the administrator of the procedure in question is aware of your role in the process and is aware that some flexibility in timing may be necessary. * Create at least 2 backup copies of the submission in its original format. Contact the Audio Visual Center, Office of Media Relations, to schedule this service. Copies must be dubbed, so allow ample time for this process. * Preserve the original as the master. During the transcription process, retain the original submission as the master since making copies of copies produces poorer and poorer results. Use a copy as your working document. * Assure that one copy is filed with the appropriate office for the record (if applicable) while you are working on the transcript. Again, be sure that you retain the master (original submission) so that copies can be made if your working copy breaks or if additional copies are needed. [Page 55] CREATING IN-HOUSE TRANSCRIPTS FROM AUDIO RECORDINGS (continued) Transcript review Whenever possible, the completed transcript should be reviewed by another qualified person to assure accuracy and completeness. Transcript format * The completed document should be in MS Word using a font style and size that is generally acceptable to the Commission. * The transcriber's name, the reviewer's name, and the date of completion should be noted on the transcript. Final disposition * If this is a document submitted for the record... When the completed document is ready for filing, submit the transcript (with the proper number of copies) including the original audio recording to the appropriate office. * If this document was a request from a person with a disability... Deliver the transcript to the requestor using standard Commission methods, i.e., U.S. Postal Service, e-mail, etc. [Page 56] 6. CREATING IN-HOUSE WRITTEN TRANSCRIPTS FROM BRAILLE Why transcribe braille? The Commission rules concerning non-discrimination on the basis of disability in the Commission's programs and activities *77 state that complaints may be submitted in "audio, braille, electronic, and/or video format." *78 For submissions in braille, transcription is necessary to allow access for people who cannot read braille. Who coordinates the transcription process? The Accessible Format Specialist *79 is the coordinator and contact person for transcription of braille. What types of braille are accepted for transcription? * English Braille, Grades 1 and 2 *80 Who should create the transcripts? Braille transcripts should be created by certified braille transcribers. *81 The Accessible Format Specialist is a certified braille transcriber and the primary Commission source for braille transcription. The Accessible Format Specialist may also designate other qualified individuals or organizations to provide braille transcription services. [Page 57] CREATING IN-HOUSE WRITTEN TRANSCRIPTS FROM BRAILLE (continued) Transcription process * Note the date you receive the braille document. There are often deadlines for submission of comments, complaints, or information; therefore, the actual submittal date can be crucial. If you are the first point of contact rather than the office that is the official point of receipt, make sure you inform the proper office that you have received information in braille that must be transcribed for the record. Also make sure that you have the full name, address, telephone number (or other contact information) for the submitter. * Find out if there are specific timelines/deadlines that affect the submission in question. If so, make every effort to complete the transcript as quickly as possible so that the entire process will not be unduly delayed. Make sure that the administrator of the procedure in question is aware of your role in the process and is aware that some flexibility in timing may be necessary. * Create at least 2 backup copies of the submission in ink-print format. * Preserve the original as the master. During the transcription process, retain the original submission as the master. For transcribers reading braille visually rather than by touch, use an ink-print copy as your working document. For transcribers who are reading braille by touch, produce a braille copy for your use if possible. Otherwise, use extreme care in handling the document since it will be the original of record. * Assure that one copy is filed with the appropriate office for the record while you are working on the transcript. Again, be sure that you retain the original (master). This will assure that a master copy is available should your working copy be destroyed or if additional copies are needed. Transcript review Whenever possible, the completed transcript should be reviewed by another qualified person to assure accuracy and completeness. Transcript format * The completed document should be in MS Word using a font style and size that is generally acceptable to the Commission. * The transcriber's name, the reviewer's name, and the date of completion should be noted on the transcript. [Page 58] CREATING IN-HOUSE WRITTEN TRANSCRIPTS FROM BRAILLE (continued) Final disposition When the completed document is ready for filing, submit the transcript (with the proper number of copies) including the original braille document to the appropriate office. [Page 59] 7. CREATING IN-HOUSE TRANSCRIPTS FROM SIGN LANGUAGE VIDEO-RECORDINGS Why transcribe sign language video recordings? The Commission rules concerning non-discrimination on the basis of disability in the Commission's programs and activities *82 state that complaints may be submitted in "audio, braille, electronic, and/or video format." *83 For submissions that take the form of American Sign Language recorded in video format, a translation and transcription into written English is necessary to allow access for people who do not understand American Sign Language. Who coordinates the translation / transcription process? The Section 504 Officer *84 is the contact person and coordinator for sign language translation / transcription. What visual presentations will be accepted for translation? American Sign Language (ASL) and its cognates will be accepted for translation. *85 The Commission will not attempt to transcribe foreign sign languages, International Sign, and other visual, gestural modes of presentation. Who should create the transcripts? Translation of ASL to English should be handled by qualified individuals, preferably fully certified sign language interpreters. *86 When possible, consultation with qualified Deaf sign language users is highly desirable. [Page 60] CREATING IN-HOUSE TRANSCRIPTS FROM SIGN LANGUAGE VIDEO RECORDINGS (continued) Transcription process * Note the date you receive the video recording. There are often deadlines for submission of comments, complaints, or information; therefore, the actual submittal date can be crucial. If you are the first point of contact rather than the office that is the official point of receipt, make sure you inform the proper office that you have received information in audio format that must be transcribed for the record. Also make sure that you have the full name, address, telephone number (or other contact information) for the submitter. * Find out if there are specific timelines/deadlines that affect the submission in question. If so, make every effort to complete the transcript as quickly as possible so that the entire process will not be unduly delayed. Make sure that the administrator of the procedure in question is aware of your role in the process and is aware that some flexibility in timing may be necessary. * Create at least 2 backup copies of the submission in its original format. Contact the Audio Visual Center to schedule this service. Copies are run in "real time" so allow ample time for this process. * Preserve the original as the master. During the transcription process, retain the original submission as the master since making copies of copies produces poorer and poorer results. Use a copy as your working document. * Assure that one copy is filed with the appropriate office for the record while you are working on the translation. Always retain the original submission as the master since making copies of copies produces poorer and poorer results. Use a copy as your working document. Translation process * Strike as much balance as possible between: * Being accurate and complete - Remember that this is a transcript. - Include false starts if signs are actually formed. Pauses or handshapes that begin but never finish need not be recorded. - Ellipses (...) can be used to indicate abrupt changes and pauses like those in false starts. [Page 61] CREATING IN-HOUSE TRANSCRIPTS FROM SIGN LANGUAGE VIDEO RECORDINGS (continued) and * Trying to convey the message as the person who is deaf intends it without undue embellishment. If there is an obvious slip on the part of the speaker, a word mis-spoken, left out, etc., an editorial comment in brackets may be used. For example: My reason for coming to the [Federal] Communications Commission is to let you know about my experiences with TRS. * Use judgment when dealing with fingerspelling. Fingerspelling that is incidentally incorrect [equivalent to typos] need not be noted, but fingerspelling that is intentionally presented but does not clearly match the context of the statement should be noted. Possible interpretations should be noted in [brackets]. If fingerspelling is completely unreadable, note in the document, [unintelligible]. * Try to match register and language level as much as possible while still retaining meaning. EXAMPLE: - RECENT. FCC GROUP CHANGE. SWITCH-SWITCH-SWITCH. OFFICE MOVE 4th FLOOR ME. Possible renderings: - Recently, the FCC's organizational structure was revamped. One of the many changes included the relocation of my office to the 4th floor. - With the recent change in FCC structure, my office moved to the 4th floor. - FCC just reorganized. My office is now on the 4th floor. - FCC's changed a lot. I'm on the 4th floor now. * Note unrecognizable signs that interrupt the flow of discourse. Use the notation, [unknown sign], in the document to clearly differentiate it from the actual text. If signs are recognizable, but meaning is not discernable, gloss as much of the comment as possible enclosing the glosses in {curly braces}. At the beginning of the transcript include a note explaining the use of [braces] and {curly braces} as well as any other conventions employed in the document. [Page 62] CREATING IN-HOUSE TRANSCRIPTS FROM SIGN LANGUAGE VIDEO RECORDINGS (continued) Translation review Whenever possible, the completed translation should be reviewed by another qualified person to assure accuracy and completeness. Translation format * The completed document should be in MS Word using a font that is generally acceptable to the Commission. * The translator's name, the reviewer's name, and the date of completion should be noted on the transcript. Final disposition When the completed document is ready for filing, submit the translation (with the number of copies required) along with the original video recording to the appropriate office. [Page 63] V. DISABILITY PRIMER [Page 64] 1. DISABILITY RIGHTS LAWS Rehabilitation Act, Section 504 The Rehabilitation Act of 1973 (PL 93-112, September 26, 1973) *87 and its subsequent amendments are precursors to the more well-known Americans with Disabilities Act that was passed in 1990. Originally, Section 504 of the Rehabilitation Act was intended to eliminate discrimination against people with disabilities in programs or activities receiving Federal funding. Section 504 provided the following: Sec. 504. No otherwise qualified handicapped individual in the United States, as defined in Section 7 (6), shall, solely by reason of his handicap, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance. In 1978, the "Rehabilitation, Comprehensive Services, and Developmental Disabilities Amendments of 1978" (PL 95-602, November 6, 1978) *88 was passed broadening the scope of Section 504 to include the Executive Branch Agencies of the Federal Government. As amended, Section 504 reads as follows (the language added in the amendment is underlined): Sec. 504. No otherwise qualified handicapped individual in the United States, as defined in Section 7 (6), shall, solely by reason of his handicap, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance or under any program or activity conducted by any Executive agency or by the United States Postal Service. The head of each such agency shall promulgate such regulations as may be necessary to carry out the amendments to this section made by the Rehabilitation, Comprehensive Services, and Developmental Disabilities Act of 1978. Copies of any proposed regulation shall be submitted to appropriate authorizing committees of Congress, and such regulation may take effect no earlier than the thirtieth day after the date on which such regulation is so submitted to such committees. [Page 65] DISABILITY RIGHTS LAWS - Rehabilitation Act, Section 504 (continued) As a result, each Federal agency has its own set of section 504 regulations that apply to its own programs and activities. Agencies that provide Federal financial assistance also have Section 504 regulations covering entities that receive such funding. Requirements common to Federal agency Section 504 regulations include reasonable accommodation for employees with disabilities; program accessibility; effective communication with people who have hearing or vision disabilities; and accessible new construction and alterations. Each agency is responsible for enforcing its own regulations. Section 504 may also be enforced through private lawsuits. *89 On April 15, 1987 the Federal Communications Commission released its Report and Order *90 (R&O), Amendment of Part 1 of the Commission's Rules to Implement Section 504 of the Rehabilitation Act of 1973, as Amended, 29 U.S.C. Sec. 794. In the R&O, the Commission adopted with minor modifications the Department of Justice's prototype regulations for implementing and enforcing Section 504. In 2003, the Commission released an Order amending its Section 504 regulations. *91 The amendment updated the language in the Commission's rules and added the Section 504 Handbook to its implementation of the Section 504 requirements. In addition to Section 504 of the Rehabilitation Act, there are other Federal laws that address disability issues. The following is a brief description of some of the laws that are frequently mentioned in connection with topics of interest to the FCC. [Page 66] DISABILITY RIGHTS LAWS (continued) Rehabilitation Act Section 501 *92 "Section 501 requires affirmative action and nondiscrimination in employment by Federal agencies of the executive branch." *93 Section 503 *94 "Section 503 requires affirmative action and prohibits employment discrimination by Federal government contractors and subcontractors with contracts of more than $10,000." *95 Section 508 *96 "Section 508 establishes requirements for electronic and information technology developed, maintained, procured, or used by the Federal government. Section 508 requires Federal electronic and information technology to be accessible to people with disabilities, including employees and members of the public. An accessible information technology system is one that can be operated in a variety of ways and does not rely on a single sense or ability of the user. For example, a system that provides output only in visual format may not be accessible to people with visual impairments, and a system that provides output only in audio format may not be accessible to people who are deaf or hard of hearing. Some individuals with disabilities may need accessibility- related software or peripheral devices in order to use systems that comply with Section 508." *97 [Page 67] DISABILITY RIGHTS LAWS (continued) Americans with Disabilities Act (ADA) *98 "The ADA prohibits discrimination on the basis of disability in employment, State and local government, public accommodations, commercial facilities, transportation, and telecommunications. It also applies to the United States Congress. To be protected by the ADA, one must have a disability or have a relationship or association with an individual with a disability. An individual with a disability is defined by the ADA as a person who has a physical or mental impairment that substantially limits one or more major life activities, a person who has a history or record of such an impairment, or a person who is perceived by others as having such an impairment. The ADA does not specifically name all of the impairments that are covered." *99 ADA Title I: Employment *100 "Title I requires employers with 15 or more employees to provide qualified individuals with disabilities an equal opportunity to benefit from the full range of employment-related opportunities available to others. For example, it prohibits discrimination in recruitment, hiring, promotions, training, pay, social activities, and other privileges of employment. It restricts questions that can be asked about an applicant's disability before a job offer is made, and it requires that employers make reasonable accommodation to the known physical or mental limitations of otherwise qualified individuals with disabilities, unless it results in undue hardship." *101 ADA Title II: State and Local Government Activities *102 "Title II covers all activities of State and local governments regardless of the government entity's size or receipt of Federal funding. Title II requires that State and local governments give people with disabilities an equal opportunity to benefit from all of their programs, services, and activities (e.g. public education, [Page 68] DISABILITY RIGHTS LAWS- ADA Title II: State & Local Government Activities (continued) employment, transportation, recreation, health care, social services, courts, voting, and town meetings). State and local governments are required to follow specific architectural standards in the new construction and alteration of their buildings. They also must relocate programs or otherwise provide access in inaccessible older buildings, and communicate effectively with people who have hearing, vision, or speech disabilities. Public entities are not required to take actions that would result in undue financial and administrative burdens. They are required to make reasonable modifications to policies, practices, and procedures where necessary to avoid discrimination, unless they can demonstrate that doing so would fundamentally alter the nature of the service, program, or activity being provided." *103 ADA Title II: Public Transportation *104 "The transportation provisions of title II cover public transportation services, such as city buses and public rail transit (e.g. subways, commuter rails, Amtrak). Public transportation authorities may not discriminate against people with disabilities in the provision of their services. They must comply with requirements for accessibility in newly purchased vehicles, make good faith efforts to purchase or lease accessible used buses, remanufacture buses in an accessible manner, and, unless it would result in an undue burden, provide paratransit where they operate fixed-route bus or rail systems. Paratransit is a service where individuals who are unable to use the regular transit system independently (because of a physical or mental impairment) are picked up and dropped off at their destinations." *105 [Page 69] DISABILITY RIGHTS LAWS- ADA (continued) ADA Title III: Public Accommodations *106 "Title III covers businesses and nonprofit service providers that are public accommodations, privately operated entities offering certain types of courses and examinations, privately operated transportation, and commercial facilities. Public accommodations are private entities who own, lease, lease to, or operate facilities such as restaurants, retail stores, hotels, movie theaters, private schools, convention centers, doctors' offices, homeless shelters, transportation depots, zoos, funeral homes, day care centers, and recreation facilities including sports stadiums and fitness clubs. Transportation services provided by private entities are also covered by [T]itle III. Public accommodations must comply with basic nondiscrimination requirements that prohibit exclusion, segregation, and unequal treatment. They also must comply with specific requirements related to architectural standards for new and altered buildings; reasonable modifications to policies, practices, and procedures; effective communication with people with hearing, vision, or speech disabilities; and other access requirements. Additionally, public accommodations must remove barriers in existing buildings where it is easy to do so without much difficulty or expense, given the public accommodation's resources. Courses and examinations related to professional, educational, or trade- related applications, licensing, certifications, or credentialing must be provided in a place and manner accessible to people with disabilities, or alternative accessible arrangements must be offered. Commercial facilities, such as factories and warehouses, must comply with the ADA's architectural standards for new construction and alterations." *107 ADA Title IV: Telecommunications Relay Services *108 "Title IV addresses telephone and television access for people with hearing and speech disabilities. It requires common carriers (telephone companies) to establish interstate and intrastate telecommunications relay services (TRS) 24 hours a day, 7 days a week. TRS enables callers with hearing and speech disabilities who use telecommunications devices for the deaf (TDDs), which are [Page 70] DISABILITY RIGHTS LAWS- ADA Title IV: Telecommunications Relay Service (continued) also known as teletypewriters (TTYs), and callers who use voice telephones to communicate with each other through a third party communications assistant. The Federal Communications Commission (FCC) has set minimum standards for TRS services. Title IV also requires closed captioning of Federally funded public service announcements." *109, *110 Architectural Barriers Act *111 "The Architectural Barriers Act (ABA) requires that buildings and facilities that are designed, constructed, or altered with Federal funds, or leased by a Federal agency, comply with Federal standards for physical accessibility. ABA requirements are limited to architectural standards in new and altered buildings and in newly leased facilities. They do not address the activities conducted in those buildings and facilities. Facilities of the U.S. Postal Service are covered by the ABA." *112 Telecommunications Act Sections 255 and 251 *113 "Section 255 and Section 251(a)(2) of the Communications Act of 1934, as amended by the Telecommunications Act of 1996, require manufacturers of telecommunications equipment and providers of telecommunications services to ensure that such equipment and services are accessible to and usable by persons with disabilities, if readily achievable. These amendments ensure that people with disabilities will have access to a broad range of products and services such as telephones, cell phones, pagers, call-waiting, and operator services, that were often inaccessible to many users with disabilities." *114, *115 [Page 71] DISABILITY RIGHTS LAWS -- Telecommunications Act (continued) Section 713 *116 Section 713 empowered the FCC to develop rules that would regulate the provision of television closed captioning services. It also charged the Commission to examine issues surrounding the provision of television video description services so as to "ensure the accessibility of video programming to persons with visual impairments, and to report to Congress on its findings." *117 As a result, the Commission issued rules requiring captioning of television programs *118 as well as rules requiring that certain major broadcast and cable television stations provide video description for 50 hours of programming per calendar quarter. *119 However, in a decision released November 8, 2002, the U.S. Court of Appeals for the District of Columbia held that Section 713 did not give the FCC authority to enact video description rules. In its conclusion, the Court decided to "reverse and vacate the Commission's Order insofar as it requires broadcasters to implement video description." *120 Television Decoder Circuitry Act *121 The Television Decoder Circuitry Act of 1990 requires that beginning July 1, 1993, all television sets with screens 13 inches or larger, either made or imported for use in the United States, have built-in decoder circuitry that allows it to display closed captioning. Hearing Aid Compatibility Act *122 The Hearing Aid Compatibility Act requires that all telephones, including cordless telephones, manufactured or imported for use in the U.S. be hearing aid compatible. Secure telephones are exempt, as are telephones used with public mobile services or private radio services. A telephone is hearing aid compatible if it provides internal [Page 72] DISABILITY RIGHTS LAWS -- Hearing Aid Compatibility Act (continued) means (i.e., without the use of external devices) for effective use with hearing aids that are designed to be compatible with telephones that meet established technical standards for hearing aid compatibility. *123 [Page 73] 2. Disability Statistics The following chart, based on U.S. Census statistics from 1997, indicates the prevalence of selected disabilities in the United States among individuals age 15 and older. The information reflected in this chart is based on the Census Bureau's SIPP (Survey of Income and Program Participation). "The [SIPP] survey design is a continuous series of national panels, with sample size ranging from approximately 14,000 to 36,700 interviewed households. The duration of each panel ranges from 2 1/2 years to 4 years. The SIPP sample is a multistage-stratified sample of the U.S. civilian noninstitutionalized population. For the 1984-1993 panels, a panel of households was introduced each year in February. A 4-year panel was introduced in April 1996. A 2000 panel was introduced in February 2000 for 2 waves. A 3- year 2001 panel was introduced in February 2001." *124 Categories of individuals # in thousands % distribution Individuals with a disability 47,935 23.0 Individuals with: Difficulty seeing words/letters 7,673 3.7 Difficulty hearing conversation 7,966 3.8 Difficulty with speech 2,270 1.1 Difficulty walking/using stairs 25,138 12.1 Used a wheelchair 2,155 1.0 Used a cane/crutches/walker 6,372 3.1 Mental disability 14,267 6.9 Learning disability 3,451 1.7 Mental retardation 1,366 0.7 Alzheimer's/senility/dementia 1,873 0.9 Other mental/emotional condition 3,418 1.6 Source: August-November 1997 data from the Survey of Income and Program Participation *125 [Page 74] 3. Disability Terminology *126 The disability community generally emphasizes the individuality of people with disabilities, not their disability. The term "handicapped" has fallen into disuse and should be avoided. The terms "able-bodied," "physically challenged" and "differently abled" are also discouraged. The following are some recommendations: Never use the article "THE" with an adjective to describe people with disabilities. The preferred usage, "people with disabilities," stresses the essential humanity of individuals and avoids objectification. Alternatively, the term "disabled people" is acceptable, but still defines individuals as disabled, first, and people second." The term "hearing impaired" should also be used with caution as it is perceived by many to be a term that implies that the individual is in some way "broken" and needs to be "fixed." Instead, the term, "deaf or hard of hearing," can be used. Use: People who are deaf, People who are hard of hearing, People who are deaf or hard of hearing Not: the deaf, deaf-mutes, deaf and dumb Use: People who are blind, People with low vision, People who are visually impaired Not: the visually impaired Use: People with disabilities Not: the disabled To refer to a person's disability, choose the correct terminology for the specific disability. The following terms are examples of appropriate terms to describe people with disabilities. People who are: blind, visually impaired, deaf, hard of hearing, mentally retarded. People with, or who have: Cerebral Palsy, Down's Syndrome, mental illness, paraplegia, quadriplegia, partial hearing loss, seizure disorder, specific learning disability, speech impairment, speech disability. [Page 75] DISABILITY TERMINOLOGY (continued) Be careful not to imply that people with disabilities are to be pitied, feared or ignored, or that they are somehow more heroic, courageous, patient, or "special" than others. Never use the term "normal" in contrast. Use: Trina qualified for her "Swimmer" certificate. Not: Trina held her own while swimming with normal children. A person in a wheelchair is a "wheelchair user" or "uses a wheelchair." Avoid terms that define the disability as a limitation such as "confined to a wheelchair" or "wheelchair-bound." A wheelchair liberates; it doesn't confine. Never use the terms "victim" or "sufferer" to refer to a person who has had a disease or disability. This term dehumanizes the person and emphasizes powerlessness. Use: person with HIV/AIDS Not: victim of AIDS or AIDS sufferer. Use: had polio Not: polio victim [Page 76] 4. DISABILITY ETIQUETTE *127 General etiquette * When talking with a person with a disability, speak directly to that person rather than to a companion or sign language interpreter who may be present. * When introduced to a person with a disability, it is appropriate to offer to shake hands. People with limited hand use or who wear an artificial limb can usually shake hands. Shaking hands with the left hand is an acceptable greeting. * When meeting a person with a visual impairment, always identify yourself and others who may be with you. When conversing in a group, remember to identify the person to whom you are speaking. * If you offer assistance, wait until the offer is accepted. Then listen to or ask for instructions. * Treat adults as adults. Address people who have disabilities by their first names only when extending that same familiarity to all others present. Never patronize people who use wheelchairs by patting them on the head or shoulder. * Leaning or hanging on a person's wheelchair is similar to leaning or hanging on a person and is generally considered annoying. The chair is part of the personal body space of the person who uses it. * Listen attentively when you're talking with a person who has difficulty speaking. Be patient and wait for the person to finish, rather than correcting or speaking for that person. If necessary, ask short questions that require short answers, a nod, or a shake of the head. Never pretend to understand if you are having difficulty doing so. Instead, repeat what you have understood and allow the person to respond. The response will clue you in and guide your understanding. * When speaking with a person in a wheelchair or a person who uses crutches, place yourself at eye level in front of the person to facilitate the conversation. * To get the attention of a person who is deaf or hard of hearing, tap the person on the shoulder or wave your hand. Look directly at the person and speak clearly. Not all [Page 77] DISABILITY ETIQUETTE -- General etiquette (continued) people who are deaf or hard of hearing can speechread. For those who do speechread, be sensitive to their needs by placing yourself facing the light source and keeping hands, cigarettes, and food away from your mouth when speaking. * Relax. It's okay if you happen to use accepted, common expressions, such as "See you later" or "Did you hear about this," that seem to relate to the person's disability. [Page 78] DISABILITY ETIQUETTE (continued) Sensitivity to Blindness and Visual Impairments *128 The following points of etiquette are helpful to keep in mind when interacting with a person who is blind or visually impaired. * Introduce yourself to people who are blind or visually impaired using your name and/or position, especially if you are wearing a name badge containing this information. * Speak directly to people who are blind or visually impaired, not through a companion, guide, or other individual. * Speak to people who are blind or visually impaired using a natural conversational tone and speed. * Address people who are totally blind or severely visually impaired by name when possible. This is especially important in crowded areas. * Immediately greet people who are blind or visually impaired when they enter a room or a service area. This allows you to let them know you are present and ready to assist. It also eliminates uncomfortable silences. * Indicate the end of a conversation with a person who is totally blind or severely visually impaired to avoid the embarrassment of having them continue speaking when no one is actually there. * Feel free to use words that refer to vision during the course of conversations with people who are blind or visually impaired. Vision-oriented words such as look, see, and watching TV are a part of everyday verbal communication. The words blind and visually impaired are also acceptable in conversation. * Be precise and thorough when you describe individuals, places, or things to people who are totally blind. Don't leave things out or change a description because you think it is unimportant or unpleasant. It is also important to refer to specific people or items by name or title instead of general terms like "you", or "they" or "this." [Page 79] DISABILITY ETIQUETTE (continued) -- Sensitivity to Blindness and Visual Impairments (continued) * Feel free to use visually descriptive language. Making reference to colors, patterns, designs, and shapes is perfectly acceptable. * Speak about a person with a disability by first referring to the person and then to the disability. Refer to "people who are blind" rather than to "blind people." * Offer to guide people who are blind or visually impaired by asking if they would like assistance. Offer them your arm. It is not always necessary to provide guided assistance; in some instances it can be disorienting and disruptive. Respect the desires of the person you are with. * Guide people who request assistance by allowing them to take your arm just above the elbow when your arm is bent. Walk ahead of the person you are guiding. Never grab a person who is blind or visually impaired by the arm and push him/her forward. * Guide dogs are working mobility tools. Do not pet them, feed them, or distract them while they are working. * Do not leave a person who is blind or visually impaired standing in "free space" when you serve as a guide. Always be sure that the person you guide has a firm grasp on your arm, or is leaning against a chair or a wall if you have to be separated momentarily. * Be calm and clear about what to do if you see a person who is blind or visually impaired about to encounter a dangerous situation. For example, if a person who is blind is about to bump into a stanchion in a hotel lobby, calmly and firmly call out, "Wait there for a moment; there is a pole in front of you." [Page 80] DISABILITY ETIQUETTE (continued) Interacting with people who have speech disabilities *129 There are a variety of disabilities, such as stroke, cerebral palsy, and deafness that may involve speech impairments. People with speech disabilities communicate in many different ways. * People who have speech disabilities may use a variety of ways to communicate. The individual may choose to use American Sign Language, write, speak, use a communication device, or a combination of methods. Find out the person's preferred method and use it. * Be appropriate when speaking with a person with a speech disability. Never assume that the person has a cognitive disability just because he or she has difficulty speaking. * Move away from a noisy source and try to find a quiet environment for communicating with the person. * If the person with a speech disability has a companion or attendant, talk directly to the person. Do not ask the companion about the person. * Listen attentively when you are talking with a person who has difficulty speaking. Be patient and wait for the person to finish, rather than correcting or speaking for the person. If necessary, ask short questions that require short answers, a nod, or shake of the head. * If you do not understand what the person has said, do not pretend that you did. Ask the person to repeat it. Smiling and nodding when you have no idea what the person said is embarrassing to both parties. Instead, repeat what you have understood and allow the person to respond. * When you have difficulty conversing on the telephone with the person, suggest the use of a speech-to-speech relay service so that a trained professional can help you communicate with the person. Either you or the person can initiate the call free of charge via the relay service. [Page 81] DISABILITY ETIQUETTE -- Interacting with people who have speech disabilities (continued) * If the person uses a communication device, make sure it is within his or her reach. If there are instructions visible for communicating with the person, take a moment to read them. * Do not make assumptions about what a person can or cannot do based on his disability. All people with disabilities are different and have a wide variety of skills and personalities. [Page 82] 5. SIGN LANGUAGE INTERPRETERS When using an interpreter... * Speak clearly in a normal tone and at a natural pace; do not exaggerate lip movements (if the person who is deaf or hard of hearing has speechreading skills, exaggerated mouth movements will distort rather than enhance understanding). * Make sure there is adequate lighting. Avoid lighting that places a shadow on the interpreter or that makes it difficult to see the interpreter's hands and face - for example, in front of a window or with bright or glaring light placed behind the interpreter. * If possible, position the interpreter so that the person who is deaf or hard of hearing can see both the interpreter and the speaker. * If speakers during your event are likely to use acronyms, jargon, or vocabulary peculiar to your field, it is helpful to provide the interpreter with a list of such terms and their definitions. * Speak directly to the person who is deaf or hard of hearing and avoid phrases like, "tell him" or "ask her." * Maintain eye contact with the person who is deaf or hard of hearing, not with the interpreter. It may help to remind yourself that your conversation is with the person who is deaf or hard of hearing, not with the interpreter. This may seem difficult at first because you will hear the interpreter's voice and will see the person who is deaf or hard of hearing shifting his gaze between you and the interpreter. Keep in mind that the person who is deaf or hard of hearing must look at the interpreter in order to understand what you are saying. * Realize that the interpreter is speaking for the person who is deaf or hard of hearing. When the interpreter says, "I" or "me," she is speaking as the person who is deaf or hard of hearing, not as herself. * Do not attempt to have private conversations with a working interpreter. It is the job of the interpreter to convey everything that is said or heard, including your efforts at engaging her attention. [Page 83] SIGN LANGUAGE INTERPRETERS-- When using an interpreter (continued) * In large gatherings where microphones are used, make sure that the interpreters providing sign to voice interpretation have a microphone and are placed with a clear line of sight, in front of the speaker who is deaf or hard of hearing. * Situations requiring one or more hours of interpreting may call for more than one interpreter. A team of two interpreters helps reduce the possibility of errors and lessens the likelihood of injury due to the stressful repetitive motions required by interpreting. When interpreters work as a team, they will generally switch roles every twenty to thirty minutes. * If you are in doubt as to the best arrangements for your situation, ask the interpreters and the people who are deaf and hard of hearing. They are the experts on what will work best for them. Study of fatigue confirms need for working in teams *130 "[M]ost people do not realize that an interpreter uses at least 22 cognitive skills when interpreting,' states Patricia Michelsen in an article published in The Court Management and Administration Report. Other studies of simultaneous interpretation have shown that fatigue is exacerbated by environmental factors that interfere with various aspects of the cognitive process... While these studies make an important contribution to the body of scientific data needed for a better understanding of the interpreting process and its complexities, they merely corroborate what practicing interpreters have known and argued all along: that work quality - i.e., accuracy and coherence - begins to deteriorate after approximately 30 minutes of sustained simultaneous interpreting, and that the only way to ensure a faithful rendition of legal proceedings is to provide interpreters with adequate relief at approximately half-hour intervals. Conscientious administrators in several federal courts, the United Nations and the U.S. State Department recognized the need for tandem interpreting adopted the practice early on. Team interpreting, in fact, dates back to the Nuremberg trials. At the State Department, which according to Harry Obst, Director of the Office of Language Services, handles 200 to 300 interpreting missions in 100 different locations per day, it is considered an inviolable policy. In response to a request from Ed Baca of the [Page 84] SIGN LANGUAGE INTERPRETERS-- Study of fatigue confirms need for working in teams (continued) Administrative Office of the U.S. Courts, Obst pointed out that 'The policy on simultaneous interpreters is simple and corresponds to that of all other responsible interpreting services in the entire world (United Nations, European Commission, International Red Cross, International Court of Justice, foreign ministries in other nations.) No individual simultaneous interpreter is allowed to work for more than 30 minutes at a time.' The letter continues, 'This is also done for the protection of the users. After 30 minutes the accuracy and completeness of simultaneous interpreters decrease precipitously, falling off by about 10% every 5 minutes after holding a satisfactory plateau for half an hour.' The reason, Obst explains, is that 'The human mind cannot hold the needed level of focused concentration any longer than that. This fact has been demonstrated in millions of hours of simultaneous interpretation around the world since 1948. It is not a question of opinion. It is simply the result of empirical observation.'" *131 Code of Ethics (Registry of Interpreters for the Deaf) *132 The Registry of Interpreters for the Deaf, Inc. [RID] is the national professional association for sign language interpreters in the United States. RID maintains and administers the certifying examination system for interpreters nationwide. RID has set forth the following principles of ethical behavior to protect and guide interpreters, transliterators, and hearing and deaf consumers of interpreting services. Underlying these principles is the desire to ensure the right to communicate for all. This Code of Ethics applies to all members of the Registry of Interpreters for the Deaf, Inc. and to all certified non-members. 1. Interpreters/transliterators shall keep all assignment-related information strictly confidential. 2. Interpreters/transliterators shall render the message faithfully, always conveying the content and spirit of the speaker using language most readily understood by the person(s) whom they serve. [Page 85] SIGN LANGUAGE INTERPRETERS-Code of Ethics (continued) 3. Interpreters/transliterators shall not counsel, advise or interject personal opinions. 4. Interpreters/transliterators shall accept assignments using discretion with regard to skill, setting, and the consumers involved. 5. Interpreters/transliterators shall request compensation for services in a professional and judicious manner. 6. Interpreters/transliterators shall function in a manner appropriate to the situation. 7. Interpreters/transliterators shall strive to further knowledge and skills through participation in work-shops, professional meetings, interaction with professional colleagues, and reading of current literature in the field. Interpreters/transliterators, by virtue of membership or certification by the RID, Inc., shall strive to maintain high professional standards in compliance with the Code of Ethics. [Page 86] 6. Assistive Listening Devices *133 Assistive listening devices (ALDs) increase the volume of a desired sound, such as the soundtrack of a movie or the voice of a tour guide, without increasing the loudness of background noises. Some assistive listening devices are also used to convey audio descriptions to visitors with visual impairments It is estimated that one out of every 10 people in the U.S. has a significant hearing loss, ranging from 25 dB (mild) to 90 dB (severe). About half of them are older adults. Among people with hearing loss, some wear hearing aids or use other devices to enhance what hearing they have, and some read lips. ALDs are made up of two parts: the transmitter and the receiver. The transmitter picks up the sound and converts it to a signal, which it then sends out. The receiver picks up a signal and transmits it to the user. Several receivers can pick up the signal from a single transmitter. There are several types of ALD systems: