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Recreation Facility Accessibility - Planning to Get Out Safely Guideline

Version 1.0   Issue Date: February 2022   I   Download PDF (AODA)


Introduction

The Evacuation Plan For This Facility Includes The Safety Of People With Disabilities

“Facility accessibility comes with responsibility and accountability”

The intent of this resource is to raise awareness of the legal and moral responsibilities of public safety as it relates to people with disabilities. The ORFA is focused on assisting its members in understanding the complexities associated with being prepared for an emergency that can quickly and safely evacuate all persons. Ontario’s accessibility laws have improved access to many public buildings which now allows people with disabilities to enjoy all forms of recreational experiences.  However, one segment of the Accessibility for Ontarians with Disabilities Act (AODA) that requires more focus and investment by all facility mangers is equal access for everyone to exit during emergencies. New construction and retrofits often adopt minimum Building Code requirements so that occupancy permits can be obtained. In reality, “minimum code” falls short in many needs including preparing for safe evacuation of persons with disabilities from these same public facilities. Most design improvements focus on mobility related disabilities and fail to consider solutions for invisible disabilities, or people who are deaf, hard of hearing, blind, or people with a speech or intellectual disability that may not always be visibly apparent. The increasing accessibility of buildings to people with disabilities requires that buildings are not only designed properly but also managed to provide accessible means of escape for all. It is important for building owners to understand the wide range of abilities people have to evacuate a facility in an emergency and to communicate their needs in a stressful setting. The challenges may shift with each facility use.

Lessons Learned But Not Embraced From 9/11

There were a number of lessons learned during and immediately after 9/11 about preparation and accommodations for people with disabilities. The most prominent and disturbing conclusion was that -- even though many of these lessons had been learned before 9/11 - systemic preparation conceived of, or conducted by, mainstream emergency responders and relief agencies did not consistently consider the specific needs of people with disabilities. Relief agencies cannot wait until they are in the middle of a disaster to start training their staff in disability awareness. Training volunteers and staff ahead of time in disability awareness and etiquette, and how to accommodate needs that commonly arise for people with disabilities is required under the AODA. The day after a disaster is too late for agencies to start doing outreach to make their services known to people with disabilities. For example, the learned lessons from the World Trade Centre disaster.

Children Evacuation Safety

Recreation facilities often have unattended children present that can pose additional challenges in emergency evacuation situations that must be considered as part of the planning process. During a situation that requires emergency evacuation, children cannot be expected to understand or comply with directions designed for adults. If they have become separated from their caregivers, their link to appropriate action has been severed and they may require special assistance from facility staff. Facility managers must consider the benefits of requiring close supervision by parents, or other responsible adults, who can provide explicit direction and support during an emergency as part of the operations policies. If this support is not present, then the responsibility rests with facility staff to act as the responsible caregiver.

Basic Fire Code Responsibilities

Most building owners fail to understand that under the Fire Code it is their duty to formulate the building’s total evacuation – not the fire department. The fire department’s primary responsibility is to respond to the root cause of the emergency and control it. Facility staff are to be in-charge of the evacuation process. This includes false alarms. Facility owners and managers have the legal and moral responsibility to provide emergency plans for their facilities. This includes having the proper immediate emergency equipment, current emergency evacuation plans, and properly trained staff. While most facilities have some sort of plan, either formal or informal, most are outdated and do not provide for the special needs that will arise during evacuation of the most vulnerable occupants including but not limited to people with disabilities, older adults, and children. Under the AODA, architectural barriers must be removed or redesigned to accommodate access for people with disabilities. Unfortunately, emergency routes have, in many cases, been neglected as part of this responsibility. Facilities that have the convenience of elevators must accept that they also offer additional emergency evacuation challenges as stairwells cannot be navigated by many people with disabilities without assistance. Additionally, to provide the required assistance, the facility employees must know where these people are and how to evacuate them safely without increasing the danger to them or to the people they are trying to assist. Too many operations lack the required resources to perform a proper and safe facility evacuation.

Note: the AODA requires employers to prepare individualized accommodation plans (IAPs) for employees with disabilities and include emergency procedures for such employees, where required due to their disability. Fire safety plans shall be made available to the public, in an accessible format, and include a list of people that require assistance. The list should correspond with the IAP and be updated regularly. Fire drills should include specific evacuation drills for people listed in the fire safety plan.
More Than Fire

Recreation facility evacuation plans include preparedness for a variety of emergencies beyond traditional fire. As Ontario’s recreation facility inventory continues to age, the likelihood of a noxious gas or chemical leak happening is higher than a fire breaking out. Even if a fire did, most buildings are well designed to contain them. Significant chemical or gas leaks can quickly enter HVAC systems or leach into all areas making them more difficult to prepare for and effectively respond.  Facility managers that maintain the infrastructure in a formally scheduled manner that is supported by a detailed asset management plan will significantly reduce the potential for an unplanned emergency.

Human Nature Evacuation

As part of facility evacuation planning, try activating the alarm during a meeting of 25 people or less to leave the building… most will gather their personal belongings and head towards the door they came in…few will take any of the other available emergency egress points in the same room. It’s human nature.

Facility managers must consider the limitations of building accessibility design as often evacuation cannot occur at the point of original entry which is where most people head as a natural reaction when there is an emergency. During emergencies, people generally look to authority figures for direction. The public normally expects this direction to come from facility employees and will, in most cases comply. For employees to provide proper direction and leadership in an emergency they must have had proper training in the procedures to be followed and this implies that management has a detailed plan for them to implement. In the absence of an effective plan and training, employees are left to their own choices in a crisis. This can result in abandonment of responsibility, counter productive actions, and even increase the severity of the emergency situation. Employees must be trained to act in concert with each other and in accordance with the facility's policies and emergency plan. While no plan can cover all contingencies, the absence of a formal program and continuing employee training will result in unnecessary endangerment of people and property. A gap that often occurs is utilizing seasonal or support staff who are inadequately trained for these types of responsibilities. Often, they are left in complete care and control of multi functional recreation facilities.

Aged Emergency System Assets

Many of Ontario’s recreation facilities remain equipped with the original emergency systems installed at the time of the construction. Consider that a building that is 40-50 years of age was built to the Building Code standards of the day. Unless specifically directed by an authority to update any portion of the system, the responsibility to consider improving any part of the infrastructure rests with the owner. As long as the maintenance of the existing equipment is performed, there is no set legal requirement to update the design. Often facility managers become comfortable with receiving the inspection certificate from the required fire equipment technician’s annual system review as their internal check and balance of compliance. Again, minimum compliance is not always the best approach to human safety, but rather a conformation of meeting a projected operational expense.

Alarms

Original audible emergency signals are most often designed for people who have no limitation in hearing sound.  Today’s buildings would be better served with visual and audible signals that can attract the attention of people with all abilities, including people who are deaf or who are wearing headphones. Alarm signal, which has a periodic element to its signal, such as single stroke bells, hi-low and fast whoop are considered best choices however, seeking professional advice as to what is considered current best practice prior to purchase is strongly recommended. It is recommended to avoid continuous or reverberating tones. Selecting a signal that has a sound characterized by three or four clear tones without a great deal of "noise" in between is proven to be helpful. Visual alarms, to be effective, must be located and oriented so that they will spread signals and reflections throughout a space or raise the overall light level sharply and be included in washroom areas. Facility asset management should include reviewing facility alarm systems and updating them to meet current standards every 10-years of a building’s life cycle.

Evacuation Aids

The marketplace holds a variety of tools to assist facility managers in their efforts to be properly prepared. Evacuation aids have three (3) main classifications:

  1. Evacuation chairs
  2. Evacuation mattresses
  3. Evacuation sheets

With an evacuation chair, a person can be evacuated while sitting, while an evacuation mattress and an evacuation sheet are designed to evacuate a person lying down. Other types of evacuation aids are available that can assist in moving people include: stretchers, slide mattresses, evacuation cords, evacuation aprons, evacuation ladders and evacuation mats. Selection would be best based on facility design.

Facility Signage

Traditional facility signage must be re-evaluated to include persons with disabilities. There are several methods that are used to better assist people with visual impairment in navigating unfamiliar surroundings. They include but are not limited to:

  • Tactile maps that depict facility layout (including emergency routes and instructions)
  • Auditory-recorded instructions.
  • Positioning of signs perpendicular to the path of travel.
  • Raised and brailed characters and pictorial symbols
  • Signage with sufficient contrast and size.
For certain demographics, low-level signage increases visibility through exit pathways, ensuring safety for the most vulnerable occupants, including people with disabilities. Besides being more visible, low-level signs are especially important in emergency situations, such as fires. When a fire spreads in a building, smoke typically makes it necessary for all those inside to crawl on the ground to avoid the poisonous air. Exit signs with proximity to the floor can assist in reaching safety when in a smoke-filled environment.

Exit signs are available in both traditional red and now green. Green is not a legal requirement under the Building Code. The colour change aligns with the “red” means stop and “green” means go mental thought processes that are installed in all of us at very young age. The best readability is achieved with light-coloured characters or symbols on a dark background.

Designating Areas For Safe Evacuation

Facility managers should consider designating specific areas for people with disabilities to exit towards that will have support for safe evacuation.  These areas may not always have direct access to an exit but are considered a safe place to remain to await further instructions or assistance during emergency conditions. These areas would be clearly marked and identified to persons with disabilities that might limit their ability to use emergency routes unassisted. Facility managers would be diligent to seek support from a Accessibility Advisory Committee if in place, local EMS and fire safety officers to best understand compliance, design, and preparedness obligations.

One known Ontario facility included public transit in the design of their new recreation facility. An area that allowed for inclusion was designed as to not highlight persons with disabilities but did allow for seamless evacuation as public transit was immediately notified when an emergency occurred, and public buses responded along with all other EMS to a designated area where individuals with disabilities could leave the building onto a cooled or warmed waiting transit vehicle with no barriers.

Designated Emergency Centres

Recreation facilities that are designated as warming or cooling areas during a community disaster will need to consider the points being discussed in this document as part of their planning process.

Being Rendered Disabled During an Emergency

At times significant events can result in persons being injured requiring additional assistance to leave the building.

Facility Emergency Drills

Under the Fire Code, each facility must conduct routine drills to ensure that employees can perform assigned tasks and that the plan works. These drills can be used to finely tune the facility's response to emergencies and greatly reduce the possibility of inappropriate actions that could lead to unnecessary endangerment of people and property. Aquatic managers have a more complicated responsibility when designing emergency plans for their operations. Getting persons with disabilities out of the water and to a safe location in cold weather needs to be addressed as going back to a change area may not be an option. Training drills should include briefs to all employees on the expected response from emergency personnel from both on-site and off. Facility staff should be cautioned not to attempt any actions that they are not trained for unless inaction would result in a Life-Threatening Danger. Reconfirm that staff should not be expected to unnecessarily endanger themselves while carrying out their assigned duties.

Hosting Events

Facilities that host events that include inviting persons with disabilities to compete must enhance their emergency preparedness plans. This must be included in event pre-planning activities. It is important to understand that event organizers also have a responsibility to ensure that all persons who attend these events are safe. Cost for this safety does not have to solely rest with the facility. Event safety costs can be built into rental fees as additional costs to be paid by the event organizers.

Co-ordinated Planning with All Stakeholders

A reminder that our responsibility as leaders is to manage community assets. This responsibility always starts with making senior staff aware of issues and formulating plans on how best to address these operational challenges. Often, we have operated for long periods of time in the current conditions, so having both short and long-term investment plans that are implemented overtime as to not require large amounts of investment at once, is sound facility management.

ORFA continually raises the issue of aging recreation infrastructure. Although there is no legal obligation to improve existing infrastructure to current standards until a planned retrofit is undertaken – there is a moral obligation to consider that all users are safe under the Occupiers Liability Act. Pro-active facility managers would benefit from hosting a meeting of all community first response stakeholders to evaluate the level of preparedness as well as identifying gaps that might be easily rectified or prepared for. The invites should include persons with disabilities as they will be invaluable to the process. Communities with populations that exceed 10,000 are required under the AODA to have an Accessibility Advisory Committee. This committee will be an important resource to facility management’s goal of being adequately prepared to respond for all persons during an emergency.

Recreation Facility Accessibility - Planning to Get Out Safely Guideline

The Province of Ontario has many resources available to organizations to help them meet the AODA on the Ontario Provincial Website. The “Recreation Facility Accessibility - Planning to Get Out Safely Guideline” resource should be reviewed as part of a facility managers research.

Conclusion

Recreation facility management is asset management. The ORFA continues to focus on creating industry leaders that are well positioned to keep pace with change and act accordingly. Accessibility management is a diverse subject matter. The facility manager of the future will need to be prepared to adapt to change. Be sure to KEEP US POSTED on your challenges and the way you have championed them by using the following COMMENT form.

 

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DISCLAIMER: While the Ontario Recreation Facilities Association Inc. (ORFA) does its best to provide useful general information and guidance on matters of interest to its members, statutes, regulations and the common law continually change and evolve, vary from jurisdiction to jurisdiction, and are subject to differing interpretations and opinions. The information provided by the ORFA is not intended to replace legal or other professional advice or services. The information provided by the ORFA herein is provided “as is” and without any warranty, either express or implied, as to its fitness, quality, accuracy, applicability or timeliness. Before taking any action, consult an appropriate professional and satisfy yourself about the fitness, accuracy, applicability or timeliness of any information or opinions contained herein. The ORFA assumes no liability whatsoever for any errors or omissions associated with the information provided herein and furthermore assumes no liability for any decision or action taken in reliance on the information contained in these materials or for any damages, losses, costs or expenses in any way connected to it.