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Fire safety for students with disabilities at institutions of higher education

Prepared under Department of Homeland Security Fire Prevention and Safety Grant EMW-2007-FP-01856

Executive Summary

On May 12, 2008, the Michael H. Minger Foundation was awarded a Fire Prevention and Safety Grant (grant EMW-2007-FP-01856) by the Department of Homeland Security to conduct a review of fire safety policies relating to students with disabilities at a variety of institutions of higher education across the country.  A broad selection of institutions was chosen ranging from large to small, public, private, urban, and rural.  In addition to the policy review, a review of the applicable requirements in national model building, fire and life safety codes in relation to accessibility and egress for people with disabilities was undertaken.

To accomplish this, the following actions were implemented:

• A steering committee of thirteen national experts was formed to help guide the project
• A fire safety specialist was retained to conduct a review of national fire, building and life safety codes
• A survey was developed and distributed to 225 schools
• A series of meetings were held by grant staff to learn more about the issues of fire safety for students with disabilities
• Web-based research was undertaken to identify resources and information relevant to the grant project

The conclusions in this report were drawn from a survey of colleges and universities (which will be referred to by the generic term “schools”) and from an analysis of model building, fire and life safety codes.  Over 200 schools were identified across the nation as a representative sample and asked to fill out an online survey.  Fifty responded and provided the information for this report.  Based on this response, the reader is cautioned that this is not necessarily a scientific sampling of the over 4,000 institutions across the country but is, instead, a snapshot of policies and procedures at a variety of schools.  We strove to include a diversity of schools (public/private, large/small, geographically diverse) to ensure a wide variety of conditions, policies and procedures among the respondents.

It is important to clarify the term “disability” that is used throughout this report.  According to one report, there are over 60 definitions of the word disability in Federal regulations which points to the difficulty with reaching consensus on how to apply the term.  For the purposes of this report, the word “disability” (unless clarified further in the text) refers to a person with either a physical, sensory, cognitive or learning disability.

As was learned in the course of this research, there is a lack of consistency among the schools surveyed in terms of how they are approaching the issue of fire safety for students with disabilities.  Further compounding this is the range of cognitive disabilities that exist and the difficulty to develop broad, yet focused and effective, procedures for these students.

There are three entities involved in fire safety for all students, including those with disabilities:  the school, the local fire department/community and the student.  Each has a specific role and function, yet they are all intertwined when it comes to taking a holistic approach.

The school has the responsibility for ensuring that the built environment meets the applicable codes and the requirements detailed in state and local building codes and in the American with Disabilities Act (ADA).  It is also responsible for developing policies, procedures and training relating to fire safety for all students, staff and faculty, including those with disabilities.  The school may have its own first responders whose plans and operations must be integrated with external responders.

The fire department/community is responsible for responding to, controlling and mitigating emergencies.  Depending upon the jurisdiction, the fire department may also have the responsibility for building construction plan review, inspections and fire prevention education and training.  Additional jurisdictional authority can include the local building or state building departments.

The student has responsibility for his or her personal safety at all times, no matter where he or she may be - in the residence hall, classroom, a restaurant or a movie theater.  At all times, it is incumbent upon the student to have a basic awareness of his or her surroundings and what actions to take in the event of an emergency.  This is true of all students, with or without disabilities, and is a life-long skill that they need to master and apply.

Students with disabilities also have the responsibility to identify themselves to the schools so that any necessary procedures can be developed or implemented to either notify the student of an emergency or to assist in evacuation or sheltering-in-place if necessary.  The schools then have a responsibility to notify the first responders and/or the local fire department of the presence of a student with disabilities so that they, in turn, can also develop procedures for ensuring the safety of the students as well as the first responders during an emergency.

The question arises as to how to best arrive at an acceptable level of fire safety that encompasses all of these aspects and responsibilities in an effective manner.  It is hoped that through the results of this project, schools and communities will work together towards effective solutions.

Findings

Identifying students with disabilities

One of the issues of greatest concern that emerged as a part of this study is that a school cannot take action to prepare for an emergency in relation to a student’s disability unless the student self-identifies as needing assistance.  While the school can prepare, in general, for emergencies involving students with disabilities, unless the student specifically identifies as needing assistance, the school cannot develop alert and evacuation contingencies that meet the needs of a specific student.  This is an area where there is a lack of full agreement as to what the ADA exactly requires as to identifying students with disabilities and requires further study.  (NOTE: The modern building codes address a number of access and egress requirements relating to mobility impairment.  However, there is more needed in the areas relating to cognitive disabilities).

Absence of consistency and understanding among schools

For a number of schools, there was a noted absence of consistency and understanding in regards to the importance of fire safety for students with disabilities and the need for focused procedures and education.  Some schools relied upon the local fire department to provide any training that was determined by the school to be needed.  Others had procedures in place such as a list of names of students with disabilities in the fire alarm panel that first responders could use during an incident.  This is a procedure that assumes the student is in that room (as in a residential occupancy), which certainly is not the case at all times, and may cause the incident commander to divert resources during an emergency, placing other occupants and emergency responders at risk.

A number of schools reported there are no specific provisions in place or the person on campus responsible for disability services was not aware of any required procedures for addressing fire safety for students with disabilities.  The model codes do address issues of fire drills in occupancies found at schools (i.e., residence halls), but are silent when it comes to issues relating to fire safety for students with disabilities.

This indicates the lack of a coordinated and holistic approach to fire safety for the population of students with disabilities.  As on any campus, there are different departments responsible for different areas (fire safety, disabilities, housing, physical plant, student services, and facilities management).  However, there appeared to be a disconnect between these departments in addressing the vital need for emergency response for students with disabilities.  In fact, several of the respondents to the survey stated that the first time they had a conversation with the department responsible for fire safety was while gathering information for the survey.

Absence of uniform, broadly-distributed information

In conducting research for this project, no national campus fire safety programs that included information for students with disabilities were found.  There are a number of campus fire safety education programs that have been developed over the past few years due to the increased awareness of the importance of campus fire safety, but none of them included information for students with disabilities.  This apparently was not a deliberate oversight; it was just not a topic that was considered in the development of these programs.

Absence of details in model codes pertaining to students with disabilities and fire safety

Many of the building, fire and life safety codes address the issue of building accessibility through references to the American National Standards Institute (ANSI) A117.1 Standard on Accessible and Usable Buildings and Facilities which is the most commonly referenced standard on building accessibility for people with disabilities.  However, there is a noted lack of information regarding how to accommodate the needs of the full spectrum of the disabled population, particularly those with cognitive disabilities, when it comes to evacuating a building, particularly in the area of procedures to be followed in providing information or assistance to people with disabilities.  This is a combination of both the built environment, design features (such as means of egress, areas of refuge, etc.) and building operations where it is necessary to have a procedure in place to assist people with disabilities in ensuring their safety.

The provisions associated with mobility disabilities have been addressed within the documents with the referencing of an independent standard associated with accessibility, ICC/ANSI A117.1, Accessible and Usable Buildings and Facilities, and incorporating additional provisions within the respecting documents.  It was also noted that the individual states have additional accessible guidelines and requirements that may be applicable.

Specific provisions associated with occupants with cognitive disabilities have not been addressed within these applicable documents.  This finding is based on the recognition that these documents were developed on the principals of establishing minimum requirements from which the intended building occupants will have an appropriate and reasonable response that is associated with that of a “general public population.”

The documents establish minimum requirements for particular occupancies for the determination and notification of an emergency condition to the building occupant but it is recognized that the occupants of these facilities will generally be able to respond without additional assistance. 

The construction, compartmentation and suppression requirements for particular occupancies that limit the fire spread are provided when it is determined that the occupant’s response may be delayed such as those found in residential occupancies where they sleep and may have a delay in response.  Newly constructed residential occupancies consisting of multiple dwelling units within a structure are required to be protected by a fire sprinkler system.   The installation of a fire sprinkler system provides benefits to all occupants and especially those with mobility and cognitive disabilities by increasing the available time to react and respond to an emergency and by limiting the effects of the fire emergency.

Training and educational requirements are detailed within the fire codes for particular occupancies.  Each use or occupancy establishes the applicable minimum requirements related to the building’s occupants and/or employees.  These requirements are generally related to the evacuation of the facility in the event of an emergency.  There is no direct referencing within these training or educational requirements that the cognitive disabilities or abilities of the occupants are to be identified and addressed. 

Absence of awareness of the importance of fire safety specifically for students with disabilities

As with fire safety for the general population, the ultimate responsibility lies with the individual in ensuring his or her personal safety.  This is accomplished by raising the awareness of the importance of selecting housing, schooling and workplace environments that have an acceptable level of fire safety both in design and operation.  The individual is also responsible for knowing what actions to take in the event of an emergency, no matter where they are.  The awareness of fire safety as an issue in selecting on- or off-campus housing needs to be included in housing information for students and their families who are involved in housing decisions.  This awareness can only come through education and training and this is a shared responsibility between the individual, the school and the fire department/community.

 A review of the responses to the questions posed in the survey regarding policies and procedures for assisting students with disabilities during emergencies revealed that many respondents simply answered “none” or “don’t know”.  Since the survey was directed to the office on each campus that dealt with disability issues, it is of concern that 1) there may not be any policies in place and/or 2) that this office is not aware or familiar with these policies and/or 3) there is no assigned internal department to specifically address this issue.  This suggests that schools may not be addressing the needs of this segment of the population as completely as may be needed.

Recommendations

Clarify the legal requirements and restrictions when dealing with emergency planning for students with disabilities

There were two specific areas identified through the course of this project that need clarification:

• The responsibility of a school for providing a tailored fire safety plan in response to a student who does not self-identify as having a disability or requiring special assistance.
• The ability of a school to restrict where students may live based on their disability.

In both cases, there were no definitive answers that could be found and more clarity and guidance is needed for schools to use in developing their policies and practices for students with disabilities.

Raise awareness among administrators

School administrators must be made aware of the importance of being able to provide effective fire safety procedures for students with disabilities that address all levels and types of physical and cognitive disabilities. Since the students can be at any location on the campus at any time, it is important that there are policies and procedures in place to provide the student with the needed level of fire safety in all buildings - housing, academic, administrative, support and other locations on campus.  Furthermore, it is critical that this awareness be made across the different departments within the institution’s structure that will deal with the various aspects of a disabled student’s academic experience (housing, office of disabilities, public safety and student services).  It is also vitally important that the student understand their role in interacting with these fire safety provisions, whether they are built-in features or policies and procedures.

Develop effective model procedures

There is a wide diversity of procedures reported by schools in addressing the fire safety needs of students with disabilities – or none at all.  While it is impossible to develop a “one size fits all” solution to the myriad of disabilities associated with students that may be enrolled at a school, particularly in the area of cognitive disabilities, guidance documents that would serve as models would be invaluable in helping a school develop policies and procedures. 

Engage the student

Fire safety is a shared responsibility between the school (a safe environment, effective policies and procedures, a well-trained staff), the community (well-trained and prepared emergency responders) and the individual person.  As with all students, with or without disabilities, the individual is ultimately responsible for his or her own fire safety.  It is vitally important for the student with a disability to be aware of his or her surroundings at all times, what actions need to be taken if an emergency breaks out and to be prepared at all times with the knowledge of how to react. Most importantly, the student needs to be able to react immediately whenever there is a perceived or real threat.

Implement code changes

One of the most significant results of this project was identifying a need for changes in the model building, fire and life safety codes in regards to all people with disabilities, not just students.  For a number of years the codes have been working towards achieving universal access which provides everyone with the ability to access a building or facility, no matter what their disability may be.  One area that the codes are not as clear in relation to students with disabilities is what action they are to take when an emergency occurs and there is the need for emergency evacuation.  While much of the built environment focuses on design of the building, egress, fixed and passive fire protection, there is an absence of information on procedures and policies for evacuation for occupants to take if they are disabled or for other non-disabled occupants to assist in an evacuation.

The building codes and fire codes have addressed building usability for a mobility impaired occupant.  It is recognized that these provisions will generally be applicable to only those buildings that have been built since the accessibility requirements became mandatory starting in the early 1980’s or have had some level of renovation performed on an existing structure.  At the completion of the review of this report, it will be noticed that the model building and fire codes do not specifically address those occupants that may have cognitive disabilities.  The current code provisions have been developed with the assumption that the general public occupant in these occupancies will be able to respond to the emergency and the emergency notification with appropriate action without assistance and in some occupancies without any additional training being provided.  Training and educational requirements within the fire codes should be enhanced so that the building occupants with cognitive disabilities are included and the appropriate training and/or information can be provided to assist in their appropriate response to an emergency event in a given building.

As a result, a series of code changes have been proposed for the International Code Council Building Code and Property Management Code (see section 5 of this report for more details). 

Develop resources

As noted earlier, there is an absence of broadly-distributed information and education resources available for schools to use in providing fire safety education and training to students with disabilities.  While it is difficult (if not impossible) to develop a “one size fits all” approach to fire safety since each school is going to be different because of their staffing, built environment and available emergency resources, it would be extremely helpful to have some templates available that schools can use in developing their own tailored educational programs based on fundamental concepts associated with teaching students with disabilities.