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Public Entities and TTY Access
Public Entities and TTY Access
(Source: ODHHS, DOJ)
Source: ODHHS, DOJ
The program accessibility requirements for telecommunications are relatively simple. They can be broken into two categories, incoming telecommunications accessibility and on-site
telephone accessibility.
Incoming Calls
In general, public entities that communicate by telephone must provide equally effective communication to individuals with disabilities, including hearing and speech impairments. Although the relay service can be used to meet this requirement, public entities are encouraged to consider the nature of their telecommunications and determine of the use of the relay service is truly equal access. Public entities that use automated attendants, voice mail, automated information systems, and other telecommunication technologies will find that the really is often ineffective. If the relay service is ineffective or otherwise poorly compatible with the telecommunication system, the public entity must provide direct incoming TTY access. This is usually accomplished by setting up a separate analog line with a dedicated number identified as "TTY Number". This dedicated TTY number should be placed on all brochures, business cards, letterheads, and other materials to ensure that persons who use a TTY can reach the agency in an equally effective manner.
For agencies that offer emergency phone services such as 911 or other crisis services there are additional requirements. Please see the excerpts from the DOJ Technical Assistance manual at the end of this document.
Note: It is the position of the Oregon's Deaf and Hard of Hearing Services (ODHHS) that all state, county, and local agencies should have direct TTY access in the interest of true program accessibility and effective customer service. For many persons who use a TTY, the lack of a direct TTY number usually is commensurate with poor customer service. This is especially true for agencies that provide services to persons who use TTY´s on a regular basis or who utilize any of the telecommunication technologies mentioned above.
On-site Telephone Access
If agencies offer the use of a public telephone for persons to make outgoing telephone calls, whether it is a pay phone or agency telephone, a TTY must be available for equal access. This can be accomplished in several ways. The most common and the least expensive is to have a TTY located at the telephone with the necessary set-up or near the telephone with signage directing persons to its location with simple directions on obtaining it. One of the difficulties with these set-ups is the security of the TTY itself and the fact that they often require the attention of staff. Another way to accomplish this (for payphones only) is to have an integrated unit where the TTY is enclosed in a secure stainless steel box that opens only when a TTY number is called. There are several models available and you can contact your phone company for more information.
Note: If a public agency has an employee that needs to use a TTY there are additional considerations. Please refer to "TTY´s and Business Phone Systems" and general Title I information for further understanding of accommodating employees who use a TTY.
Included below are a couple of excerpts from the actual ADA Accessibility Guidelines and the DOJ Title II Technical Assistance Manual:
DOJ ADA Accessibility Guidelines:
ADAAG: One TDD (also known as a "text telephone") must be provided inside any building that has at least one interior pay phone and four or more public pay telephones, counting both interior and exterior phones. In addition, one TDD or text telephone (per facility) must be provided whenever there is an interior public pay phone in a stadium or arena; convention center; hotel with a convention center; covered shopping mall; or hospital emergency, recovery, or waiting room ({4.1.3(17)(c)).
DOJ Technical Assistance Manual:
II-7.2000 Telephone communications.
Public entities that communicate by telephone must provide equally effective communication to individuals with disabilities, including hearing and speech impairments. If telephone relay services, such as those required by title IV of the ADA, are available, these services generally may be used to meet this requirement.
Relay services involve a relay operator who uses both a standard telephone and a TDD to type the voice messages to the TDD user and read the TDD messages to the standard telephone user. Where such services are available, public employees must be instructed to accept and handle relayed calls in the normal course of business.
II-7.3000 Emergency telephone services.
II-7.3100 General. Many public entities provide telephone emergency services by which individuals can seek immediate assistance from police, fire, ambulance, and other emergency services. These telephone emergency services--including "911" services--are clearly an important public service whose reliability can be a matter of life or death. Public entities must ensure that these services, including 911 services, are accessible to persons with impaired hearing and speech.
State and local agencies that provide emergency telephone services must provide "direct access" to individuals who rely on a TDD or computer modem for telephone communication. Telephone access through a third party or through a relay service does not satisfy the requirement for direct access. (However, if an individual places a call to the emergency service through a relay service, the emergency service should accept the call rather than require the caller to hang up and call the emergency service directly without using the relay.) A public entity may, however, operate its own relay service within its emergency system, provided that the services for non-voice calls are as effective as those provided for voice calls.
What emergency telephone services are covered by title II?
The term "telephone emergency services" applies to basic emergency services -- police, fire, and ambulance -- that are provided by public entities, including 911 (or, in some cases, seven-digit) systems. Direct access must be provided to all services included in the system, including services such as emergency poison control information. Emergency services that are not provided by public entities are not subject to the requirement for "direct access."
What is "direct access?
"Direct access" means that emergency telephone services can directly receive calls from TDD´s and computer modem users without relying on outside relay services or third party services.
Does title II require that telephone emergency service systems to be compatible with all formats used for non-voice communications?
No. At present, telephone emergency services must only be compatible with the Baudot format. Until it can be technically proven that communications in another format can operate in a reliable and compatible manner in a given telephone emergency environment, a public entity would not be required to provide direct access to computer modems using formats other than Baudot.
Are any additional dialing or space bar requirements permissible for 911 systems?
No. Additional dialing or space bar requirements are not permitted. Operators should be trained to recognize incoming TDD signals and respond appropriately. In addition, they also must be trained to recognize that "silent" calls may be TDD or computer modem calls and to respond appropriately to such calls as well.
II-7.3200 911 lines. Where a 911telephone line is available, a separate seven-digit telephone line must not be substituted as the sole means for non-voice users to access 911 services. A public entity may, however, provide a separate seven-digit line for use exclusively by non-voice calls in addition to providing direct access for such calls to the 911 line. Where such a separate line is provided, callers using TDD´s or computer modems would have the option of calling either 911 or the seven-digit number.
II-7.3300 Seven-digit lines. Where a 911 line is not available and the public entity provides emergency services through a seven- digit number, it may provide two separate lines -- one for voice calls, and another for non-voice calls -- rather than providing direct access for non-voice calls to the line used for voice calls, provided that the services for non-voice calls are as effective as those offered for voice calls in terms of time response and availability in hours. Also, the public entity must ensure that the non-voice number is publicized as effectively as the voice number, and is displayed as prominently as the voice number wherever the emergency numbers are listed.
II-7.3400 Voice amplification.II-7.3400 Voice amplification. Public entities are encouraged, but not required, to provide voice amplification for the operator´s voice. In an emergency, a person who has a hearing loss may be using a telephone that does not have an amplification device. Installation of speech amplification devices on the handsets of operators would be one way to respond to this situation.
For more information, contact:
Oregon's Deaf and Hard of Hearing Services (ODHHS)
1257 Ferry St SE
Salem, OR 97310
(503) 378-3142 (V/TTY)
(503) 378-3599 (Fax)