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. 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 CART18 (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. 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 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.

2. CONSIDERATION 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.

3. CONSIDERATION 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.
• 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

4. CONSIDERATIONS FOR STAFF ACTIVITIES

Office parties / Holiday celebrations / Federally recognized employee organizations³⁹ / 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.

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.
  • 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.

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.