Overview
During our audit period, Greenfield Community College (GCC) did not have an emergency evacuation plan that took into account the needs of students with disabilities. Although the college had an emergency evacuation plan that discussed assisting students in need, it did not specifically discuss how to assist students with disabilities. This places the health and wellbeing of these students at risk.
Authoritative Guidance
Section 35.130(b)(7) of the Americans with Disabilities Act of 1990 (ADA) Title II Regulations states,
A public entity shall make reasonable modifications in policies, practices, or procedures when the modifications are necessary to avoid discrimination on the basis of disability.
Additionally, according to Section II-8.2000 of the ADA Title II Technical Assistance Manual, published by the US Department of Justice, all public entities, including community colleges, are expected to ensure that their current policies and practices do not exclude individuals with disabilities from their programs, activities, and services:
A review should be made of the procedures to evacuate individuals with disabilities during an emergency. This may require . . . special procedures for assisting individuals with disabilities from a facility during an emergency.
Establishing specific procedures for how to properly notify students with mobility, vision, or hearing issues and/or other disabilities of emergency situations, and how to properly assist these students in emergency evacuations, is consistent with the purposes of the ADA and therefore a best practice.
Reasons for Issue
GCC officials stated that the college had overlooked the requirement to address the needs of its students with disabilities in its emergency evacuation plan.
Recommendation
GCC should take the measures necessary to ensure that it complies with all of the requirements of the ADA and with its own newly created procedures for the emergency evacuation of students with disabilities.
Auditee’s Response
The College recognized that the emergency evacuation plan in place at the time of review was incomplete with regard to providing explicit directions regarding the emergency evacuation of students with mobility, vision, hearing, and/or other disabilities and steps to revise the plan were underway. Since meeting with the auditors, the College has taken additional steps to address the noted deficiencies by updating of the emergency procedures page on the Public Safety web page to provide evacuation instructions for people with disabilities. . . . Additionally, the information is replicated on the Disability Services web pages. . . . Finally, the College has incorporated a link to the . . . instructions titled “Emergency Procedures” in the footer of every page on our web site.
| Date published: | June 20, 2018 |
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