Does Our Emergency Planning Account for Workers of Different Abilities?

09/03/2020

The one-two punch of Tropical Storm Marco and Hurricane Laura that hit parts of the Gulf Coast last week reminded us all of the importance of emergency planning for both businesses and communities. But do our emergency plans truly account for the diversity of abilities among our workforce, or are we simply assuming that all of our employees are equally able to see, hear, understand and follow evacuation instructions?

Let’s take a closer look at why accounting for workers’ different abilities is crucially important to emergency planning as part of your workplace safety management system, as well as state and local government emergency planning processes.

Emergency Planning as Part of a Safety Management System

Emergency planning is a significant part of any effective safety management system. ISO 45001, the global standard for safety management systems, states in Section 8.2 that facilities patterning their program on ISO 45001 need to develop a planned response which includes first aid, training, periodic testing, communication, and performance evaluation.

A particularly relevant section of ISO 45001 — section 8.2 (g) — states that employers must account for the needs and capabilities of interested parties. This would certainly include the different physical capabilities of individual workers, and the ways those capabilities affect the need for additional support during an emergency.

A non-exhaustive list of other ISO 45001 requirements related to emergency planning and different abilities in the workplace include:

4.1 Understanding the organization and its context — This section states that employers should determine the external and internal issues relevant to its purpose, and affect its ability to achieve the intended outcomes of its management system, such as reductions in numbers of occupational illnesses and injuries.

5.4: Consultation and participation of workers — This section states that the organization must establish and maintain a process for consultation and participation of all workers at all applicable levels, and specifically notes that non-managerial employees must be included. Additional information on this section located in the annex to the standard states that “consultation implies a two-way communication involving dialogue and exchanges. Consultation involves the timely provision of the information necessary for workers, and, where they exist, workers’ representatives, to give informed feedback to be considered by the organization before making a decision.” The idea here is that workers need to participate in a meaningful way in the safety of their workplace, and not just hear after the fact about decisions made without their input. Obviously, this consultation is extremely important for development of emergency plans that account for different worker abilities.

6.1 Actions to address risks and opportunities — Everything in safety management ultimately comes down to identification and control of risks. Failure to identify and address risks related to different employee abilities can have disastrous consequences in the event of an emergency.

7.1 Resources — The organization needs to provide the resources needed to establish, implement, maintain and continually improve safety management. This means it must budget for equipment needed to meet the needs of all employees during emergencies. This equipment may include, but is not limited to, transportation devices, communication devices, emergency control systems, alarms and other warning systems.

7.4 Communication — The organization must establish processes for communicating safety management information to employees. Communications specific to emergency planning might include evacuation routes, details about what emergency alarm systems are in use, and the identities of emergency response team members. It’s important to remember that when making these communications, we should make sure that we’re making them in a language and format that all of our workers can understand, and verify that they’ve understood them.

8.1.2 Eliminating hazards and reducing OHS risks — This is where we are going to do our best to eliminate hazards (which are sources of risk) and reduce the likelihood and severity associated with remaining risks.

Note that our success at eliminating hazards and risks depends on our ability to identify those risks in the first place. In other words, everything comes down to the recognition that our workers have different physical abilities, and making sure we’re factoring those differences into our emergency plans.

Different Abilities in the Workplace

The term “ableism” is used to refer to discrimination against those with disabilities in favor of able-bodied people. One way it plays out in workplaces is by assuming everyone has the same abilities, thereby ignoring and excluding anyone who doesn’t.

I consider ableism a hazard in the workplace that creates risks. Just as we must be proactive about identifying and controlling other kinds of workplace hazards, effective emergency planning demands that we recognize and correct our ableism.

That’s something I didn’t do, at least not at first. Here’s a personal story showing why it’s important to account for different worker abilities when developing our emergency plans.

Before coming to VelocityEHS, I was a safety and regulatory consultant for many years, and then became a Global EHS Coordinator for a large manufacturing company. In my role as EHS Coordinator, I’d inherited an older evacuation plan written by a predecessor, reviewed it with the help of our Emergency Response Team, and considered it pretty good. The plan didn’t address the needs of workers with different abilities, because quite frankly, I’d never thought of it before, and neither had the “able bodied” people who collaborated with me to revise the plan.

We learned of the limitations of our plan when we conducted an evacuation drill. We’d developed our plan on the assumption that everyone in he workplace had equal physical ability to evacuate as quickly and easily as everyone else could, but noticed when doing our initial headcount that we had not yet accounted for one employee who worked in our warehouse building. This employee was an older gentleman who walked using a mobility aid. We had “known” he was there, but somehow hadn’t thought to account for his mobility issues in our evacuation plans. Had this drill been a real emergency, the consequences of that oversight could have been very severe.

That discovery was a wake-up call to our own ableism. We talked to the individual with mobility issues to determine what kind of assistance he’d need. We also undertook an effort to learn of other differences in ability, such as vision, hearing, literacy, and medical conditions, and sought similar input from employees on the support they’d need during an emergency. After all, if we’d done a better job at “consultation and participation,” as detailed in ISO 45001, we probably would’ve accounted for differences in ability much sooner. After that, we revised our plans and retrained our emergency response team.

There are many different categories of abilities we need to review to ensure we’re supporting all members of our workforce, including:

• Hearing: Workers with hearing issues may not hear an alarm
• Vision: Blind workers may need extra assistance
• Mobility: Physical mobility issues may make it more difficult to evacuate
• Dyslexia/learning differences – Affect ability to read and understand directions
• Autism/sensory integration issues – Can cause overstimulation and fear

For this reason, we need to be extra vigilant to make sure we’re accounting for the range of abilities present among our workers. As my personal example shows, it’s very important to conduct evacuation drills on a regular schedule, because those can help us identify previously overlooked problems before a real emergency happens.

How Can We Collect Information About Employee Abilities?

At this point, many employers may rightfully be asking how they can obtain medical information about their workers for purposes of emergency planning. In the United States, the Equal Employment Opportunity Commission (EEOC) has provided guidance on this issue in the form of an online fact sheet.

Here’s a brief summary of this guidance.

EEOC recognizes that employees may need assistance during emergencies because of medical conditions that might not be obvious, and allows employers to ask employees to identify if they would need assistance.

There are three ways an employer may obtain this information:

• After making a job offer, but before employment begins, an employer may ask all individuals if they will need assistance during an emergency.
• An employer also may periodically survey all current employees to determine if they’ll require assistance in an emergency, as long as the employer makes it clear that self-identification is voluntary and explains the purpose for requesting the information.
• Finally, regardless of whether an employer surveys its workers, it may ask employees with known disabilities if they will require assistance in the event of an emergency. That said, employers should take care not to assume that everyone with an obvious disability will need assistance during an evacuation. For example, many individuals who are blind may prefer to walk down stairs unassisted. The best takeaway is that the employees themselves are generally in the best position to assess their particular needs.

During this process, the employer may ask workers what specific assistance they will need, such as a wheelchair for workers with mobility issues or masks for those who have respiratory conditions.

The Americans with Disabilities Act (ADA), which applies to private employers with fifteen or more employees and state and local governments, requires employers to maintain confidentiality of medical information for employees and applicants. A key point here is that employers are entitled only to the information needed to provide assistance during an emergency, not to detailed information about employee medical conditions.

ADA allows employers to share information about the type of assistance that an employee requires during an emergency with medical professionals, first responders, emergency coordinators, members of  in-house emergency response teams and facility security personnel responsible for ensuring that all workers have been evacuated.

So far, we’ve been talking about emergency planning considerations for employers. Next, let’s look at the importance of emergency planning for state and local government agencies in their efforts to protect the safety of the communities they serve.

Emergency Planning for Communities

Accounting for differences in ability is also important to emergency planning at the local government level, because it directly impacts community safety during an emergency.

To understand the consequences of not accounting for these differences in ability, we need only look at the well-documented example of Hurricane Katrina. During that tragic event:

• 71% of all Louisiana residents who died during the storm were over the age of 60
• Many emergency communications were inaccessible to people with disabilities
• Buses used to transport community members out of dangerous areas often lacked wheelchair ramps, and adequately equipped buses only arrived (if at all) after a wait of many hours in temperatures of 90 degrees Fahrenheit or higher.
• Community members with disabilities who were able to evacuate often reached emergency centers only to be turned away because the centers were not equipped to accommodate them.

If anyone wants more information about the impact of Katrina on disabled people within the community, I strongly recommend watching the short but powerful documentary “The Right to be Rescued.” As a disability rights advocate featured in that documentary states, “When you know in advance who is likely to be the most harmed by a disaster and you don’t do anything about it, then that is a choice. It’s about whose lives are more ‘valuable’ and which ones aren’t as ‘valuable.’”

We’ve seen numerous other examples since Katrina where inadequate emergency planning and response has put some members of the community at greater risk during emergencies. The sad truth is that more often than not, state and local governments don’t adequately plan ways of meeting the needs of all community members, and don’t provide help to those who most need it.

To help communities improve their emergency planning, ADA has published a guide called “Making Community Emergency Preparedness and Response Programs Accessible to People with Disabilities.” The guide gives practical tips on how to account for people of many different abilities in the planning phase, making sure that accessible vehicles and shelters are available.

For additional information about emergency planning and its role within your workplace safety management system, check out our on-demand webinar Emergency Planning: Best Practices for Safety and Community Engagement

 Let VelocityEHS Help!

Consider the advantages a modern cloud-based chemical and SDS management software solution from MSDSonline can give you in strengthening your emergency plans and streamlining emergency information sharing. Our Plan 1 service even gives you the ability to map your chemical storage locations onto a footprint of your facility and share that information with emergency responders, making it that much easier for them to develop a safe and effective response strategy in the event of a serious incident. Our Emergency Response Services (ERS) makes it easy to ensure your employees always have the critical safety information they need, including medical and spill response support in the event of exposure.

VelocityEHS is also providing disaster relief support to those along the Gulf Coast recently impacted by Tropical Storm Marco and Hurricane Laura. For a limited time, disaster relief agencies, emergency responders and businesses (customers and non-customers) operating in the affected areas can visit http://www.EHS.com/disaster and search through the millions of safety data sheets (SDSs) in the MSDSonline database to locate critical safety information for hazardous chemicals released during the storms. A dedicated toll-free telephone number (1-844-308-7011) has also been set up to help those who need a safety data sheet, but don’t currently have internet access.

Initially launched in 2017 following the devastation of Hurricane Harvey, our Hazardous Chemical MSDS/SDS Access program has provided fast, easy access to critical chemical safety information to hundreds of businesses and relief organizations. Through the aid of our mobile-optimized, industry-leading SDS database, first responders, businesses, facilities and organizations have been able to better protect their communities from chemical hazards in the wake of natural disasters.

Visit http://www.EHS.com/disaster to learn more.