>From the web page http://www.usdoj.gov/crt/ada/911ta.htm

U.S. Department of Justice

Civil Rights Division

Disability Rights Section

Americans with Disabilities Act

Access for 9-1-1 and Telephone Emergency Services

I. Introduction

Dialing 9-1-1 is the most familiar and effective way Americans
have of finding help in an emergency. The Americans with
Disabilities Act (ADA) requires all Public Safety Answering
Points (PSAPs) to provide direct, equal access to their services
for people with disabilities who use teletypewriters (TTYs),
which are also known as "telecommunications devices for the deaf
(TDDs)."

This document is part of a technical assistance program to
provide State and local governments and persons with
disabilities with information about the requirements of the ADA
for direct, equal access to

9-1-1 for persons with disabilities who use TTYs. This guidance
is an updated version of the Department of Justice's earlier
guidance entitled, "Commonly Asked Questions Regarding Telephone
Emergency Services." It explains in practical terms how the
ADA's requirements apply to 9-1-1 services, including equipment,
standard operating procedures, and training, and should be
useful to 9-1-1 service providers, equipment vendors,
participating telephone companies, and individuals with
disabilities.

Different emergency providers may have different capabilities
and features. For instance, some larger providers have "Enhanced
9-1-1" or "E9-1-1," which automatically identifies for 9-1-1
call takers the telephone number and/or address of callers. Some
providers have call distribution systems, which place incoming
calls in a queue and distribute them to the next available call
taker. Other, smaller providers, may not have these
capabilities. This guidance can be useful to all types of
telephone emergency providers, both small and large.

A. ADA Coverage of Telephone Emergency Services

Title II of the ADA covers telephone emergency service providers
and other State and local government entities and
instrumentalities. The Department's regulation is published at
28 C.F.R. Part 35. To obtain a copy of the ADA or its
implementing regulations, or if you have questions about the
ADA, contact the Department of Justice ADA Information Line at
(800) 514-0301 (voice), or (800) 514-0383 (TTY), or access the
Department's ADA Home Page at
http://www.usdoj.gov/crt/ada/adahom1.htm

     Q: What types of telephone emergency services are
     covered by Title II of the ADA?

     A: The phrase "telephone emergency services" applies
     to basic emergency service -- police, fire, and
     ambulance -- that are provided by public safety
     agencies, including 9-1-1 (or, in some cases,
     seven-digit) systems. Direct, equal access must be
     provided to all services included in the system,
     including services such as emergency poison control
     information.

     Q: In areas without 9-1-1 services, are PSAPs still
     required to provide access for TTY users to the
     telephone emergency services?

     A: Yes. Where 9-1-1 is not available and a PSAP
     provides emergency services via a seven-digit number,
     it still must provide direct, equal access to TTY
     callers. It may do so either by having one line for
     both voice and TTY calls, or it may provide two
     separate lines -- one for voice calls, and another for
     TTY calls. Requiring TTY callers to call a separate
     seven-digit number is not allowed in areas where 9-1-1
     is offered, because having to dial a seven-digit
     number is not equal to the ease of having to dial the
     simple, familiar 9-1-1.

     As with 9-1-1, services for TTY calls on seven-digit
     numbers must be as effective as those offered for
     voice calls in terms of time of response, hours of
     operation, and other features. Also, PSAPs must ensure
     that TTY numbers are publicized as effectively as
     voice numbers and displayed as prominently as voice
     numbers wherever telephone emergency numbers are
     listed.

     Separate Telephone Lines for TTY Users

     Q: Can a PSAP dedicate a separate seven-digit line for
     TTY calls?

     A: Yes, but TTY users must also have direct, equal
     access to all call-taking positions on 9-1-1 lines. A
     PSAP cannot require TTY users to call a seven-digit
     number when voice callers may dial the more familiar
     9-1-1.

B. TTYs & Telephone Relay Services

A TTY is a device that is used in conjunction with a telephone
to communicate with persons who are deaf, who are hard of
hearing, or who have speech impairments, by typing and reading
text. To communicate by TTY, a person types his or her
conversation, which is read on a TTY display by the person who
receives the call. Both parties must have TTYs to communicate.
When typing on a TTY, each letter is transmitted by an
electronic code called Baudot, which is sent from the TTY on the
sending end of the call through the telephone line in the form
of tones to the TTY on the receiving end of the call, the same
way voiced communications occur between two parties. The
receiving TTY transforms the tones back to letters on a small
display screen.

Communication between two persons using standard TTYs can only
occur in one direction at a time. Thus, both persons who are
conversing cannot type to each other at the same time; they must
take turns sending and receiving. A person sending a
communication by TTY indicates that he or she has finished
transmitting by typing the letters "GA," which stand for "go
ahead."

A person can also use a computer with a TTY modem and related
software to communicate with someone who has a TTY or who has a
computer with TTY software and a modem. Computers generally
operate in American Standard Code for Information Interexchange
(ASCII), an electronic "language." A person who uses ASCII must
use an ASCII/Baudot modem and related software to convert the
ASCII code into Baudot code, in order to communicate with
another person who is using a Baudot-based system. Similarly, a
person who is using a Baudot-based TTY must utilize conversion
software to communicate with a person using an ASCII-based
computer.

Telephone relay services are provided by States, as required by
Title IV of the ADA, and are regulated by the Federal
Communications Commission. Relay services involve a
communications assistant who uses both a standard telephone and
a TTY to type voice communication to a TTY user and read a TTY
user's typed communication to a voice telephone user. Telephone
relay services are not as effective for emergencies, because
they are far more time-consuming than calls between two TTYs.

     Q: Does Title II require that telephone emergency
     service systems be compatible with all codes used for
     TTY communications?

     A: 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 State or local government agency is not
     required to provide direct access to computer modems
     using formats other than Baudot.

     Q: Can PSAPs rely on State relay services to answer
     emergency calls from persons who are deaf, hard of
     hearing, or who have speech impairments?

     A: No. The Title II regulation specifically prohibits
     emergency telephone service providers from relying on
     relay services. Relay services do not provide "direct
     access," because they require the services of a third
     party and are far more time-consuming than direct TTY
     calls. However, if a person placing a call to a PSAP
     voluntarily chooses to rely on a telephone relay
     service, the PSAP must answer and respond
     appropriately to such a call.

II. Direct, Equal TTY Access

A. General Requirements for Telephone Emergency Service Providers

The ADA regulation requires 9-1-1 or other telephone emergency
service providers to provide TTY users with:

  * direct access; and
  * an opportunity to benefit from the emergency services that
    is equal to the opportunity afforded others.

Direct access means that PSAPs can directly receive TTY calls
without relying on an outside relay service or third-party
services.

Equal access means that the telephone emergency services
provided for TTY users are as effective as those provided for
persons who make voice calls, in terms of:

  * response time;
  * response quality;
  * hours of operation; and
  * all other features offered (e.g., automatic number
    identification, automatic location identification, automatic
    call distribution).

Direct, equal access requires PSAPs to have the appropriate
equipment to communicate with people who use TTYs. It also
requires them to use the proper procedures and practices when
TTY calls are received.

B. Equipment

     Number of TTYs

     In order to afford equal access to TTY users, every
     call-taking position within a PSAP must have its own
     TTY or TTY-compatible equipment. PSAPs must have
     systems that enable call takers to handle TTY calls as
     properly, promptly, and reliably as voice calls. Every
     call-taking position needs its own TTY equipment
     because experience has shown that:

       * With TTY or TTY-compatible equipment at each
         call-taking position, call takers can handle TTY
         calls as effectively as voice calls.
       * Call takers at PSAPs that had only one TTY per
         center had significant difficulties handling TTY
         calls within their standard answering time.
       * Sharing a TTY among several call takers may result
         in undue delay in obtaining the TTY and connecting
         it to the answering position.
       * Transferring a TTY call from a non-TTY-capable
         answering position to a TTY-dedicated position may
         result in the call being disconnected or undue
         delay in answering the call. In some cases,
         transfers may result in the loss of enhanced
         features, such as automatic number identification
         and automatic location identification information.
       * Each call taker needs to query every silent, open
         line call as a potential TTY call, as described in
         Section D, below. Because most PSAPs receive many
         silent, open line calls, often more than one at a
         time, each calltaker must have his or her own TTY
         equipment to be able to query all of those calls
         with a TTY.

     Thus, PSAPs may not provide TTY equipment at only a
     limited number of positions, such as, at only a
     supervisor's position, or at only one dedicated call
     taker's line. PSAPs must have systems that respond to
     TTY calls as promptly and reliably as they respond to
     voice calls. Call takers cannot be required to
     transfer TTY calls to specific phone lines or
     locations, unless voice calls are also transferred
     under the same circumstances. Transfers consume
     critical time, greatly increase the risk that the call
     will be disconnected, and may result in the loss of
     enhanced features, such as automatic number
     identification and automatic location identification
     information.

     People other than "dedicated" call takers often act as
     call takers and therefore must have their own TTY
     equipment. For instance, dispatchers will often take
     overflow emergency calls when all dedicated call
     takers are busy, and supervisors may take calls on
     occasion. Every person who takes emergency calls from
     the public under any circumstances must have their own
     TTY equipment for the same reasons that dedicated call
     takers must have their own TTY equipment.

     Q: If a PSAP has only received a few TTY calls per
     month over the past year, why does it need TTYs at
     every call-taking position?

     A: Most PSAPs receive many silent open line calls,
     which may be TTY calls. In order for call takers to
     know if silent calls are TTY calls, each call taker
     will need TTY equipment to query every silent call
     with a TTY. It is possible that call takers have been
     receiving more than a few TTY calls per month, but
     have treated them as silent lines or hang-ups rather
     than TTY calls. This is likely if the call takers have
     not been querying all silent lines with TTYs. Some of
     those silent lines or hang-ups may have been TTY users
     waiting for a TTY response.

     Historically, many persons who use TTYs have not had
     confidence in the accessibility of 9-1-1 services and
     have not attempted to make direct TTY calls to their
     PSAP. The number of TTY calls each PSAP receives is
     likely to increase in the future, as PSAPs become more
     accessible to TTY users, and as TTY users learn of
     PSAPs' improved accessibility.

     Q: If a PSAP complies with a State law, which requires
     only one TTY per PSAP, is that PSAP also in compliance
     with the ADA?

     A: No. Satisfying State law requirements does not mean
     that a PSAP is also in compliance with the ADA. Some
     State laws require only one TTY per PSAP. The ADA,
     however, requires direct, equal access, which means
     that PSAPs must have enough TTY equipment so that each
     call-taking position has its own TTY capability. Also,
     if a PSAP has extra voice telephone equipment in case
     of malfunction, which most do, the ADA would also
     require them to have back-up TTY equipment. Therefore,
     under the ADA, virtually all PSAPs must have two or
     more TTYs.

     Enhanced Features

     Many PSAPs have advanced features that facilitate
     prompt responses to callers. Many PSAPs have, for
     example, automatic number identification (ANI) and
     automatic location identification (ALI), which tell
     the call taker the phone number and address from which
     a call originates. PSAPs that have these features must
     ensure that TTY calls have the same access to enhanced
     features as do voice telephone calls. TTY calls may
     not be required to be transferred to a third line,
     because those transfers often result in the loss of
     the automatic phone number and address information.
     Another feature employed by PSAPs is automatic call
     distribution (ACD), which places incoming calls into a
     queue, sends out a programmed message to callers to
     let them know that their calls have been received, and
     distributes calls to the next available call taker.
     This feature, if offered, must also be made accessible
     for TTY calls, with a programmed TTY message.

     Relationship Between Primary and Secondary PSAPs

     Primary PSAPs (9-1-1 answering points) often transfer
     calls to secondary PSAPs (such as fire or emergency
     medical services) if they do not dispatch those
     services directly from the primary PSAP. In those
     transfer situations, PSAPs must correctly transfer TTY
     calls, as they do voice calls. Secondary PSAPs have
     the same responsibilities under the ADA as do primary
     PSAPs, and they must be able to receive transferred
     TTY calls as efficiently and as effectively as voice
     calls.

C. Other Requirements for TTY Equipment

     Maintenance and Back-Up

     The ADA regulation contains a specific provision
     requiring that covered entities maintain their
     accessibility features and equipment in operable
     working condition. In addition to this specific
     maintenance requirement, the ADA's equal access
     requirement obligates PSAPs to implement equally
     effective procedures for maintenance and back-up
     capability for TTY equipment as they provide for voice
     telephone equipment. For example:

       * TTY equipment must be maintained and tested at
         least as often as voice telephone equipment, to
         ensure that the equipment is operating properly.
         If PSAPs check their voice telephone equipment
         every day to make sure it is working, they must do
         so every day for TTY equipment. Similarly, if
         PSAPs have contracts with outside companies for
         maintenance of their voice telephone equipment,
         they must employ equally effective methods for TTY
         equipment.
       * Most PSAPs have plans for using back-up equipment
         in case some of its equipment or telephone lines
         malfunction, or in case there is a power failure.
         If a PSAP has such a plan for voice calls and
         equipment, it must provide for TTY calls and
         equipment in that plan. For instance, PSAPs should
         keep extra TTY equipment on hand, in case the
         primary equipment fails, if they have back-up
         voice telephone equipment for such a situation.

     Switching Between Voice and TTY Modes

     All call takers must have the capability to switch
     back and forth easily from TTY mode to voice mode
     during the same call. This capability is necessary
     especially for silent calls, since call takers are
     required to first query the line by voice and then
     quickly switch to query the line by TTY. This
     capability is also necessary for VCO and HCO, which
     are described below. VCO and HCO shorten the lengths
     of calls that would otherwise be conducted exclusively
     by typing. Call takers who use stand-alone TTYs can
     switch from TTY mode back to voice mode simply by
     removing the telephone handset from the TTY couplers.
     TTY-compatible consoles for call takers should have
     built-in switching capability.

     Q: What is VCO? Who uses it?

     A: VCO is voice carryover. It is a communication
     hybrid of TTY and voice. VCO allows a person with
     hearing loss to speak directly to the call taker and
     read the response that is typed back. Many persons who
     became deaf or hard of hearing later in life prefer to
     speak instead of type. They use what is called voice
     carryover (VCO). With VCO, the caller speaks directly
     into the phone, and the call taker types back via TTY
     to the caller. VCO can be accomplished with standard
     stand-alone TTY equipment simply by having the call
     taker alternate between listening on the handset when
     the caller is speaking and placing the handset in the
     TTY couplers to type a response.

     Q: What is HCO? Who uses it?

     A: HCO is hearing carryover. People with speech
     impairments who are not deaf or hard of hearing often
     prefer HCO. HCO allows them to type their words on a
     TTY to call takers and hear call takers' spoken
     responses through their handset. HCO can be
     accomplished by a call taker using standard
     stand-alone TTY equipment by alternating speaking into
     the handset and placing the handset in the TTY when
     the caller types a response.

D. Procedures for Handling TTY Calls

In addition to proper equipment, direct, equal access for TTY
calls requires that PSAPs use effective procedures for
recognizing and responding to TTY calls.

     Recognizing TTY Calls/Treating Silent, Open Lines as
     Potential TTY Calls

     All call takers must be able to recognize and handle
     TTY calls properly. There are three types of TTY calls
     a call taker may receive. Some TTYs emit a recorded
     spoken announcement to the call taker that a TTY call
     is being placed, such as "HEARING IMPAIRED CALLER. USE
     TTY." Other times, TTY callers may press TTY keys to
     emit audible tones and more quickly notify the call
     taker that a TTY call is being placed. Most often,
     however, a person using a TTY will make a call that is
     perceived by the call taker as a silent, open line
     call. This is because the caller's equipment does not
     recognize that the call has been answered until the
     call taker sends a TTY response.

     The only way for PSAPs to properly identify all TTY
     calls is for call takers to recognize TTY tones and to
     query every silent, open line call with a TTY to
     determine if it is a TTY call after it has been
     queried by voice.

     Requiring Callers Using TTYs to Press a Key

     In the past, some PSAPs have required callers using
     TTYs to press the space bar or other keys after they
     call, to emit tones and notify call takers that it is
     a TTY call. This requirement violates the ADA.
     Requiring TTY callers to press keys repeatedly until
     recognized is unfamiliar to most TTY callers, and
     callers cannot be relied on to perform such unfamiliar
     tasks, especially in emergency situations. Further, in
     many emergency situations there may not be time or
     opportunity to press keys repeatedly until recognized.

          ILLUSTRATION: A 9-1-1 call taker answers a
          call, responds with a standard spoken
          greeting, and expects to hear a spoken
          response. If the call taker receives a
          silent, open line, the call taker should
          query the line verbally a second time, and
          then query the line using a TTY to determine
          if the call is from a TTY user.

     TTY Detection Equipment

     Q: If a PSAP uses TTY detection equipment, does it
     still have to query every silent call with a TTY?

     A: Yes. Some PSAPs have installed equipment that
     detects TTY calls and produces a voice announcement to
     the call taker that a TTY call has come in. TTY
     detection equipment, however, only recognizes TTY
     calls that transmit tones, such as when callers press
     keys to emit tones. This equipment will not recognize
     TTY calls when the caller does not emit tones and
     instead waits for a TTY response before transmitting.
     Thus, TTY detection equipment does not eliminate the
     need for call takers to query every silent line with a
     TTY.

     Dispatching Police to Origin of Silent Calls

     It is not sufficient merely to dispatch police to the
     origins of all silent, open lines, in lieu of querying
     the lines with a TTY. Precious time may be lost by
     sending the police if the caller needs another type of
     response, such as fire or emergency medical services.
     All silent, open lines must be queried with a TTY to
     assess the basis for the call and to dispatch the
     appropriate emergency equipment and personnel.

     Conducting TTY Calls

     After TTY calls are recognized, call takers must
     effectively communicate with callers during the calls.
     Effective communication by TTY will require call
     takers to be familiar with the use of TTY equipment
     and TTY protocols.

E. Training

PSAPs must train their call takers to effectively recognize and
process TTY calls. Call takers must be trained in the use of TTY
equipment and supplied with information about communication
protocol with individuals who are deaf or hard of hearing, or
who have speech impairments. For instance, callers who use
American Sign Language use a syntax that is different from
spoken English. In addition, in TTY communication, certain
accepted abbreviations are frequently used. A list of some of
those abbreviations is attached to this document.

The ADA does not specify how call takers must be trained, but
the Department believes that the following are essential to
proper training:

     Training should be mandatory for all personnel who may
     have contact with individuals from the public who are
     deaf, hard of hearing, or who have speech impairments.

     PSAPs should require or offer refresher training at
     least as often as they require or offer training for
     voice calls, but at a minimum, every six months.

Comprehensive training should include:

     Information about the requirements of the ADA and
     Section 504 of the Rehabilitation Act for telephone
     emergency service providers;

     Information about communication issues regarding
     individuals who are deaf or hard of hearing, or who
     have speech impairments, including information about
     American Sign Language;

     Practical instruction on identifying and processing
     TTY calls, including the importance of recognizing
     silent TTY calls, using proper syntax, abbreviations,
     and protocol when responding to TTY calls and relayed
     calls; and

     Hands-on experience in TTY communications, especially
     for new call takers, as part of their initial training
     orientation.

To ensure the effectiveness of training, PSAPs may want to
consult the Emergency Access Self-Evaluation program, published
as a manual by Telecommunications for the Deaf, Inc., under a
Department of Justice grant. The EASE manual, which was reviewed
by the Department, can be obtained for a fee by calling TDI at
(301) 589-3786 (voice), (301) 589-3006 (TTY), or (301) 589-3797
(FAX).

F. Testing

The Department believes that frequent testing is essential to
ensure direct, equal access. Testing call takers and their
equipment is also the one of the most effective ways to ensure
compliance with the ADA's requirement that accessibility
features are maintained in operable working condition. The ADA
does not specify how testing is to be conducted. We believe,
however, that PSAPs should conduct an internal testing program
in which they conduct random TTY test calls of each call-taking
position. The tests should be designed to ascertain whether TTY
equipment functions properly and whether personnel have been
adequately trained to recognize TTY calls quickly, to operate
TTY equipment, and to conduct TTY conversations. The Department
recommends the following for an effective testing program:

     To test whether call takers have been trained
     adequately to recognize TTY calls, a PSAP should
     conduct two types of test calls--silent, open line
     calls in which no tones are emitted and calls in which
     the caller introduces the call by transmitting TTY
     tones. Tests should be unannounced.

     It is best for PSAPs to keep records of the results of
     all test calls, including, at a minimum: the date and
     time of each test call; identification of the call
     taker and call-taking position; whether each call was
     silent or transmitted tones; whether the caller
     received a TTY response and the content of the TTY
     response; the time elapsed and number of rings from
     the initiation of the TTY call until the call taker
     responded by TTY; and whether the call was processed
     according to the PSAP's standard operating procedures.
     The testing program should cover each call taker and
     each position.

Some Helpful TTY Abbreviations

     ASAP - As soon as possible

     CD or CLD - Could

     GA - Go ahead, your turn to talk

     GA or SK - Go ahead or Goodbye

     HCO (Hearing Carry Over) - TTY user will use his/her
     hearing during call

     HD or HLD - Hold, Please

     MSG - Message

     NBR or NU - Number

     PLS - Please

     Q or QQ - Question mark

     R - Are

     SHD - Should

     SKSK - Stop Keying, means end of conversation

     TMW - Tomorrow

     TTY - Teletypewriter

     U - You

     UR - Your

     VCO - (Voice Carry Over) TTY user will use his/her
     voice during the call

     XXXX - Error, Erase

This document is available in the following formats for persons
with disabilities --

       * Braille
       * Large print
       * Audiocassette
       * Electronic file on computer disk and electronic
         bulletin board, (202) 514-6193

To obtain these documents in alternate formats, call the
Department of Justice ADA Information Line, (800) 514-0301
(voice), (800) 514-0383 (TDD).

Note: Reproduction of this document is encouraged.

July 15, 1998

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